United Nations Development Programme (UNDP) | Social and Environmental Compliance Unit (SECU) & Stakeholder Response Mechanism (SRM)

Accountability Counsel has worked to ensure that UNDP’s Social and Environmental Compliance Unit (SECU) and Stakeholder Response Mechanism (SRM) are effective avenues for remedy and accountability.

Ensuring Meaningful Implementation of SECU’s Policies

We actively contributed to the creation of UNDP’s accountability office, comprised of SECU and the SRM, and have pushed office to operate according to best practice. Our advocacy has included work to ensure that SECU fully implements its own policy. SECU’s policy allows for the accountability office to make recommendations to UNDP to bring non-compliant projects into compliance and mitigate any harm that results from the breach of UNDP’s social and environmental commitments. The general public, as well as the complainants and UNDP staff, are able to make comments on these recommendations, which are typically contained in draft compliance review reports.

We sent a joint letter to SECU in February 2018 in response to one of SECU’s draft compliance review reports regarding the accountability office’s authority to provide recommendations for corrective action. The letter, which was also co-authored by the Center for International Environmental Law (CIEL) and Bank Information Center (BIC), expressed appreciation for SECU’s ability to make recommendations and called on SECU to make recommendations in all SECU cases that are clear, actionable solutions for enabling full project compliance and monitoring. We also encouraged SECU to ensure that these recommendations are based on meaningful consultation with the aggrieved party or parties so that the remedy best reflects their needs.

In December 2018, we took the lead on a joint letter to the UNDP administrator, Mr. Achim Steiner, calling on the administrator to fulfill his important oversight role in the SECU complaint process. Although SECU’s investigation guidelines require the UNDP administrator to expeditiously make a final decision regarding steps to bring a project into compliance and/or mitigate any harm to affected people, the investigation reports for some of SECU’s cases had been awaiting the administrator’s review for months. We called on the administrator to follow the investigation guidelines and address the cases as soon as possible. In his response, Mr. Steiner highlighted UNDP’s responsibility to ensure accountability to those individuals and communities with whom UNDP works, and stated that final decisions in the cases would be forthcoming. The decisions were published on 4 February, 2019.

Strengthening the Procedures for Proactive Investigations

In April 2017, we submitted comments on SECU’s draft Standard Operating Procedures (SOPs) for proactive investigations, which allow SECU to initiate an investigation without requiring receipt of a formal complaint. We urged SECU to ensure that a proactive investigation would not prevent or prejudice a subsequent complaint to SECU on the same project. As a result of our advocacy, The final SOPs, which are included in the August 2017 update to SECU’s investigation guidelines, include safeguards to prevent such prejudice and ensure that proactive investigations complement, rather than replace, external complaints.

Strengthening UNDP’s Engagement with Stakeholders

In addition to our advocacy to strengthen UNDP’s accountability office, we have also worked to ensure that the institution has a strong approach to engagement with communities. In June 2017, we joined our partners at CIEL and the International Accountability Project (IAP) on a submission of recommendations for strengthening UNDP’s draft Guidance Note on Stakeholder Engagement. Our submission included recommendations for early and continuous engagement with communities throughout the project cycle. Additionally, we called on UNDP to ensure that information related to the existence, role of, and access to SECU and the SRM, including brochures and other resources, be publicly available in local languages.

See here for more information on Accountability Counsel’s advocacy to the UNDP.