Why Every IAM Should Have the Power to Self-Initiate Investigations

This article draws from existing instances of self-initiated compliance investigations by IAMs and analyzes such investigations’ role in bridging the accountability gaps in preventing and mitigating harm in cases of environmental and human rights grievances, financial intermediary lending, and where there are reprisal risks.

Introduction

The fundamental “do no harm” mandate, as iterated across the sustainability policies and frameworks of Development Finance Institutions (DFIs), requires readiness to prevent, mitigate, and remediate environmental and social harm when risks come to light. In this regard, the Independent Accountability Mechanisms (IAMs) of DFIs – which connect impacted communities with the financial institutions – are integral risk prevention, mitigation, and remediation tools.

Most IAMs currently require complaints to be filed by people directly harmed by projects in order to be eligible. Although IAMs should be community-centered justice tools, the requirement that complainants must be from directly impacted people can limit access to justice. While it would be ideal if directly impacted people were able to file cases and demand justice whenever harm occurs, significant barriers to access can make it nearly impossible for that to happen.

There is an obvious solution: equipping IAMs with the ability to self-initiate compliance investigations.

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