Sustainability Report 2013


Project Complaint Mechanism

The Project Complaint Mechanism (PCM) is the EBRD’s accountability mechanism for assessing and reviewing complaints about projects that we finance. It provides individuals and local groups that may be directly or adversely affected by an EBRD project, as well as civil society organisations (CSOs), with a means of raising complaints or grievances with the Bank independently from our banking operations.

In 2013, the PCM registered three (compared with four in 2012) new complaints and continued working on the different stages of the review process for the six complaints registered in 2012 and 2011. Five of these complaints were closed following completion of the compliance reviews.

Additionally, six complaints were received during the year and their registration was suspended either because the projects had not yet reached the appropriate stage in our appraisal process or because the complainants had not previously attempted to bring their concerns to the attention of the client or the relevant operations teams in the Bank. Each of these cases was referred to the relevant Bank team for consideration and follow-up, providing the complainant with an opportunity to re-submit the complaint to the PCM if they felt their concerns remained unresolved. A further 13 complaints received were determined to be ineligible for consideration by the PCM.

Five compliance reviews were completed by the PCM during the year, all of which resulted from complaints registered in 2012 and 2011. Two of these cases (the Rivne Kyiv high voltage line project in Ukraine and the Sostanj thermal power plant project in Slovenia) did not conclude with findings of non-compliance. Three cases resulted in findings of non-compliance: the Boskov Most hydropower plant project in FYR Macedonia, the Ombla hydropower plant project in Croatia and the Paravani hydropower plant project in Georgia. In each of these three cases, the findings of non-compliance related to PR6 of our Environmental and Social Policy on Biodiversity Conservation and Sustainable Management of Living Natural Resources. The Compliance Review Report on the Paravani project also made findings of non-compliance regarding PR1 on Environmental and Social Appraisal and Management and PR10 on Information Disclosure and Stakeholder Engagement.

These findings were made following a detailed and comprehensive review process that included several meetings with various representatives of management, the clients and the complainants, and examination of a large number of project documents.

In order to address these three findings of non-compliance, the Bank’s management carried out assessments of the experts’ recommendations and agreed to Management Action Plans. Implementation of the Management Action Plans is monitored by the PCM officer and monitoring reports are issued at least biannually or until the PCM officer determines that all implementation issues are completed.

In the case of Ombla, the EBRD and the developer HEP agreed to cancel the EBRD loan for the project before the completion of the PCM compliance review. This agreement was made following detailed consultations between HEP and relevant Croatian authorities regarding the findings of the independent biodiversity study.

Further information on the PCM – including a register of complaints and all published reports, together with the PCM’s Annual Report for 2013 – is available from the Project Complaint Mechanism website.