Grievance mechanism procedure
Grievance mechanism related to projects financed by IFU and IFU managed funds
IFU encourages its investees to establish a procedure to handle grievances from individuals and communities, who may be adversely affected by the activities of the investee. Such grievance mechanism should be used as an early-warning risk-awareness system and as a mechanism to prevent conflicts and provide redress. Investees are defined as any business activities directly invested by IFU or IFU managed funds.
The grievance mechanism should complement other judicial and non-judicial mechanisms including the National Contact Points (NCPs) under the OECD MNE guidelines.
Nonetheless, there may be cases where grievances from those affected by an IFU investee are not resolved by the investee. In such cases, affected individuals and communities can use IFU’s Grievance Mechanism.
IFU’s Grievance Mechanism is established to respond in a timely manner to legitimate concerns and complaints by persons or their representatives, who are adversely impacted by IFU’s investees.
This mechanism offers an avenue for addressing grievances between IFU’s investees and external stakeholders. IFU’s Grievance Mechanism is not a legal enforcement mechanism and does not confer any rights of access to justice to the persons lodging a grievance.
3. Applicable standards
Grievances are concerns and complaints that can be raised related to an investee including its conformance with IFU’s sustainability policy and exclusion list, available at http://www.ifu.dk/en/values/sustainable-investments/ifus-sustainability-policy. This policy is amongst others based upon relevant international laws, principles and guidelines, such as the UN Guiding Principles on Business and Human Rights, the ILO Core Standards and the IFC Performance Standards.
4. How to use IFU’s Grievance Mechanism
Any person who is adversely impacted can lodge a grievance, preferably in English, by using the form on IFU’s homepage. Grievances can also be sent to IFU or any member of IFU’s staff by sending an email, a letter or a fax.
Although response times will depend on the nature of the grievance, persons who have lodged a grievance will be kept informed about expected response times and progress made in addressing grievances.
Grievances should preferably contain the following information:
- Contact person lodging the grievance (name and address, telephone number and email address). Anonymous grievances will also be considered.
- Persons impacted and how they are impacted.
- The investee to which the grievance is related, including investee address.
- Overview of actions (e.g. legal, contacts with project company, local authorities) that have already been taken to solve the issue.
5. Confidentiality issues
The identity of the person lodging a grievance will be kept confidential. If a grievance is deemed legitimate, it will typically be necessary for IFU to contact the relevant investee.
6. IFU’s procedures
All grievances are received by IFU’s Sustainability Unit, who is responsible for investigating the grievances and implementing the procedures described below on behalf of IFU, unless otherwise indicated.
Once a grievance is received, IFU sends an acknowledgement of receipt of the grievance and an expected time frame for addressing the grievance.
IFU determines whether a grievance is legitimate. IFU will review the issues raised in the grievance. Gathering the required information for the review may include reviewing relevant documentation and records, ensuring internal coordination of IFU staff involved and holding meetings with external stakeholders.
IFU prepares an internal report on the grievance including recommendations. Recommendations may be operational corrective actions or improvements to existing policies or procedures in the investee. Where possible and appropriate a corrective action plan is drafted and presented to the investee.
The report will be presented to IFU’s executive board, who will decide on the most appropriate course of action. If IFU’s executive board is deemed to be in a conflict of interest, the report will be handled by IFU’s general counsel and presented directly to the chairman and deputy chairman of the board of directors of IFU.
IFU informs the person lodging the grievance about the decision made by IFU.
7. Reporting and evaluation
IFU will report to its board of directors and in the annual report on the status and outcome of grievances received on an aggregated basis, taking into account confidentiality regulations and agreements.