Independent Complaint Mechanism (IKI ICM)

Illustration: Two people sitting on the floor, three people discussing with each other and two people shaking hands.

The mechanism is intended to enable people who suffer (potential) negative social and/or environmental consequences from IKI projects, or who wish to report the improper use of funds, to voice their complaints and seek redress. In doing so, it should also contribute to:

monitor and improve the environmental and social outcomes of projects,
avoid unintended negative impacts of projects that go unnoticed by ZUG and BMWK, BMUV and AA,
support the appropriate use of public funds, and
comply with international good practice

The complaints mechanism is based at Zukunft - Umwelt - Gesellschaft (ZUG) gGmbH, Federal Goverment's project management agency for the IKI funding programme. With the change of leadership of the IKI, the lead responsibility for the complaint mechanism also lies with the Federal Ministry for Economic Affairs and Climate Action (BMWK), which also works closely with the Federal Ministry for the Environment, Nature Conservation, Nuclear Safety and Consumer Protection (BMUV) and the Federal Foreign Office.

IKI ICM Policy (02/2022) (English, PDF, 345 KB, barrier-free)

The Independent Complaint mechanism of IKI (IKI ICM) follows established international good practice of other accountability mechanisms associated in the Independent Accountability Mechanism Network. Its procedure is based on Germany’s human rights treaty obligations as well as standards such as the UN Guiding Principles on Business and Human Rights.

Everybody who – as a consequence of an IKI-supported project – either claims to have suffered negative consequences arising immediately from the implementation, or wants to report serious negative environmental impact resulting immediately from the implementation of an IKI-funded project, and/or wants to report misuse of funds or corruption.

For the protection of complainants and whistle-blowers, the anonymity of complainants can be ensured, among others through an anonymous mailbox, which allows communication back and forth.

IKI ICM addresses complaints regarding noncompliance with negative social and/or environmental impacts and/or misuse of funds and corruption. It does not consider complaints regarding rejection of funding proposals.

Complainants can choose between a mediation-based alternative dispute resolution procedure in which the IKI ICM facilitates a voluntary process between the parties to reach a mutually accepted solution to the issues raised in the complaint, and a compliance review, in which the IKI ICM assesses compliance of ZUG and implementing organisations with IKI safeguards and budgetary and funding law as well as their direct management by ZUG.

IKI ICM is located within ZUG, but structurally and financially independent. It consists of a panel of three independent experts (currently being recruited) and a complaint office. It can be reached at: iki-complaints(at)z-u-g.org.
The expert panel of the independent complaint mechanism, which consists of 3 persons, is responsible for investigating and/or mediating complaints by project-affected persons and whistleblowers reporting negative social and/or environmental consequences from IKI projects, or the improper use of funds.

To the members of the expert panel …
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Andrea Kämpf

Andrea Kämpf, LL.M., is a lawyer and mediator and heads the Complaints Office of the IKI Independent Complaint Mechanism. Andrea has over 20 years of experience in human rights, accountability, sustainability standards, participatory governance and stakeholder management – working with public, private and civil society sector organizations.

She led the process to the establishment of the IKI Independent Complaint Mechanism since January 2021 when she joined ZUG gGmbH. Prior to this, as a Senior Policy Adviser at the German Institute for Human Rights (Germany’s NHRI), she advised and worked with the German government and development cooperation agencies GIZ and KfW, as well as the European Union on implementing a human rights based approach to development. As an associate expert for the panel of the Independent Complaint Mechanism of DEG/FMO she laid the groundwork for the implementation of an alternative dispute resolution procedure. Previously, she worked for international governmental and non-governmental organisations, as part-time professor and consultant for state and non-state development organizations. Next to public sector complaint mechanism, she is interested in complaints practice of the private sector, and is co-author of a German legal commentary on the recently enacted German Supply Chain Due Diligence Act.

A German national, she speaks German, English, French and Spanish.

To the CV of Andrea Kämpf on LinkedIn
In 2020, BMU requested ZUG to explore options for a complaint mechanism for IKI and the necessary legal and practical means for its establishment. A draft policy for the mechanism was consulted between 18.10. to 28.11.2021. In three online seminars and in the form of written comments, more than 20 participants from all regions of the world provided ZUG and BMU with valuable suggestions.
Written submissions

Accountability Counsel (PDF, not barrier-free)

Urgewald (PDF, German, not barrier-free)

FIAN Deutschland e.V. (PDF, German, not barrier-free)

IKI BBL

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IKI Brown Bag Lunch: IKI Independent Complaint Mechanism (ICM)

Recording COP29 Event

At COP29 in Baku, the head of the complaints office of the IKI Independent complaints mechanism, Andrea Kämpf, took part in the event ‘Why Accountability is Key to a Successful Just Transition’.

Watch the recording of the event

Contact

Office of the IKI Independent Complaint Mechanism (IKI ICM)

iki-complaints@z-u-g.org

File a complaint

Do you want to submit a complaint or are you looking for more information?

Notes on data protection

IKI ICM Notes on data protection (English, PDF, 162 KB, barrier-free)

Online seminar

To accompany the work of the IKI Complaint Mechanism Policy, the IKI offers an online seminar for interested implementing organisations and implementing partners as well as potentially affected persons and non-governmental organisations to inform themselves about the new aspects resulting from the IKI Independent Complaint Mechanism policy.

IKI ICM presentation outreach (English, PDF, 755 KB, barrier-free)

Stay up to date with ICM newsletter!

Further information

The complaint mechanism is also handling complaints regarding the grants programme again maritime litter.

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