A CAO investigation found that IFC violated its own Sustainability Framework’s requirements in its investments in six banks providing microfinance in Cambodia, and this noncompliance contributed to predatory lending practices that have led to the loss of land and livelihoods, hunger, increased suicide risks, and threats of retaliation against the very communities that are supposed to benefit from microfinance programs.

The harms caused by the microfinance industry in Cambodia are well documented and were confirmed by CAO. However, in an unprecedented fashion, the World Bank Group Board rejected CAO’s noncompliance findings and recommendations to address the harm from its investments. In direct contradiction to the CAO investigation, and without any evidence, the Board published a statement on June 24th declaring that, ”there has been no policy noncompliance under IFC’s Policy on Environmental and Social Sustainability.” Although required by the Board-approved CAO policy, IFC refused to develop and submit to the Board a management action plan with time-bound commitments to address the noncompliance. Instead, it has promised piecemeal actions in a “Special Management Action Plan” that do not address most of CAO’s recommendations. Furthermore, according to unofficial reports, IFC has suggested that victims of predatory micro-finance lending or other consumers harmed by IFC-financed products will no longer have access to recourse through CAO. This is completely unacceptable.

It is not the role of the Board to determine whether or not IFC Management has acted in compliance with its Sustainability Framework. CAO was established to serve as an independent arbiter and hold the institution accountable to the policy commitments made by IFC’s shareholders. If the Board can reject CAO’s policy on a case-by-case basis, then it means that CAO is no longer a reliable and predictable mechanism and can no longer credibly shield IFC from legal liability.

This decision sets a dangerous precedent for accountability at the World Bank Group. It comes at a time when the Board has already shaken the public’s confidence in its accountability architecture by approving a hasty merger of the institution’s public and private sector accountability mechanisms. At this point, the only conclusion we can reach is that the Board prioritizes its investment portfolio over environmental and social protections.

We call upon the Board to:

1) Meet with us to explain how they reached this decision.
2) Publish the voting record of each member of the Board.
3) Require IFC to accept CAO’s findings and develop an effective Management Action Plan
in consultation with the complainants.
4) Disclose how any other current and future cases to CAO alleging environmental and
social harms stemming from its microfinance portfolio will be handled fairly and
predictably.
5) Explain who will be leading CAO following Janine Ferretti’s departure and before the
new mechanism is established, and how this leadership vacuum will not further
undermine accountability on other CAO cases.
6) Commit to a transparent and inclusive leadership selection process, which includes civil
society participation on the selection committee, to ensure the independence and
integrity of the new World Bank Group accountability mechanism. Despite the Board’s
assertion that a transparent recruitment process has been underway since June 9th, the
job posting, terms of reference, and recruitment process have not been publicly
disclosed.
7) Reaffirm its commitment to strong due diligence and supervision to ensure that the costs
of economic development do not fall disproportionately on poor or vulnerable people.
8) Reaffirm its commitment to strong accountability and ensure that the institution’s new
independent accountability mechanism is equipped to do its work effectively.

Signatories

Organizations

1. AbibiNsroma Foundation – Ghana
2. Accountability Counsel – International
3. Alternative Law Collective – Pakistan
4. Arab Watch Coalition – United States
5. Asia Indigenous Peoples Network on Extractive Industries and Energy (AIPNEE) –
   Philippines
6. ASOCIACIÓN AMBIENTE Y SOCIEDAD – Colombia
7. Asociación unión de talleres 11 de septiembre – Bolivia
8. Association for Farmers Rights Defense, AFRD – Georgia
9. Bank Climate Advocates – United States
10. Bank Information Center – United States
11. BankTrack – The Netherlands
12. CEE Bankwatch Network – Czech Republic
13. Center for Economic and Social Rights (CESR) – Global
14. Centre for Human Rights and Development – Mongolia
15. Cohesión Comunitaria e Innovación Social – Mexico
16. Colectivo Voces Diversas – El Salvador
    3
17. Community Empowerment and Social Justice Network (CEMSOJ) – Nepal
18. Deep Sea Mining Campaign – United Kingdom
19. Equitable Cambodia – Cambodia
20. FIAN Germany – Germany
21. Fundación Acue – Chile
22. Fundación Ambiente y Recursos Naturales (FARN) – Argentina
23. Fundación CAUCE: Cultura Ambiental – Causa Ecologista – Argentina
24. Fundación Libera contra la Trata de Personas y la Esclavitud en Todas sus Formas –
    Chile
25. Fundeps – Argentina
26. Germanwatch – Germany
27. Green Advocates International – Liberia
28. HRM “Bir Duino -Kyrgyzstan” – Kyrgyzstan
29. Inclusive Development International – United States
30. Indigenous Peoples Alliance Of the archipelagos Chapter Sumbawa (AMAN
    SUMBAWA) – Indonesia
31. Indigenous Peoples Rights International-IPRI – Philippines/Global
32. Inisiasi Masyarakat Adat (IMA) – Indonesia
33. International Accountability Project – Global
34. Jamaa Resource Initiatives – Kenya
35. Just Finance International – The Netherlands
36. Just Ground – United States
37. Kapaeeng Foundation – Bangladesh
38. KTNC Watch – Republic of Korea
39. Liberia Artisanal Fishermen Association LAFA – Liberia
40. Manushya Foundation – Thailand
41. Mekong Watch – Japan
42. MenaFem Movement for Economic, Development And Ecological Justice –
    SWANA/Morocco
43. MiningWatch Canada – Canada
44. Nash Vek PF – Kyrgyzstan
45. Oil Workers’ Rights Protection Organization Public Union – Azerbaijan
46. Oxfam International – United States
47. Oyu Tolgoi Watch – Mongolia
48. Peace Point Development Foundation -PPDF – Nigeria
49. People Ecology Network – India
50. Philippine Movement for Climate Justice – Philippines
51. Recourse – International
52. Rivers & Rights – Southeast Asia (Regional)
53. Rivers without Boundaries – International
54. Rivers without Boundaries Coalition – Mongolia
55. Sinergia Animal – Global South
56. Society For Women Rights & Development ( SWoRD) – Pakistan
57. Sustentarse – Chile
    4
58. The William Gomes Podcast – United Kingdom
59. Transparentem – United States
60. Trend Asia – Indonesia
61. Uganda Consortium on Corporate Accountability – Uganda
62. Urgewald – Germany
63. WEED – World Economy, Ecology & Development – Germany
64. Wemos – The Netherlands
65. Witness Radio – Uganda
66. Yemeni Observatory for Human Rights – Yemen
67. Uzbek Forum for Human Rights – Uzbekistan/Germany

Individuals

61. Dr. Guljakhon Amanova – Uzbekistan
62. Ms. Sophia Cramer – Independent Researcher and Policy Advisor
63. Ms. Fiona Faye, University of Kassel, Afrique-Europe-Interact
64. Prof. Arntraud Hartmann, SAIS Europe Johns Hopkins University
65. Prof. David Hunter, Peregrine Environmental Consulting, LLC
66. Prof. Aram Ziai, University of Kassel and Global Partnership Network

The post World Bank Board Denies Recourse to Millions of Victims of Predatory Lending, Sets a Dangerous Accountability Precedent appeared first on Inclusive Development International.

Protecting independence: The Policy must be truly independent and impartial. We’re calling for stronger authority, clear conflict-of-interest rules, and “cooling-off” periods to prevent undue influence. 

Strengthening Board oversight: The EIB Board of Directors should play a clearer role in overseeing how complaints are handled. Regular updates and stronger supervision are needed to ensure action plans are properly implemented and disputes are addressed fairly. 

Make the advisory function meaningful: The EIB Group should actively use recommendations from complaints in its decision-making. Accountability only works if failures lead to institutional change. 

Read the full comments here.

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To demonstrate for automakers what better practices can look like in the real world, Lead the Charge members have published a series of case studies, including one from Inclusive Development International focused on how car companies that source from Guinea’s largest bauxite mine, Compagnie des Bauxites de Guinée (CBG), should be engaging with and supporting communities who are at risk from the planned expansion of CBG’s mining operations—an expansion that is being driven in part by demand for aluminum for use in electric vehicles and batteries.  

The study pulls from our recent report, “I Will Do Anything to Stay Here”: What a Just Energy Transition Means to Communities at Risk from Bauxite Mining in Guinea, presenting perspectives from these communities and a list of their specific requests for CBG and its buyers, including that mining should proceed only once there has been a true dialogue and affected communities have agreed to the terms on which the project can proceed. As our case study explains, companies that use CBG bauxite in their products—including the car companies Audi, BMW, Ford, GM, Mercedes-Benz, Porsche and Toyota—have a role to play supporting communities in the proposed agreement-making process. They can do this by, among other things: 

• Engaging directly with CBG to express their expectation that CBG earn broad community support through agreement making for the expansion of the mine  

• Providing pooled resources to enable communities to access technical and legal advisers who can support them in the agreement-making process, including through generating options for avoiding harm and designing development benefits 

• Instituting material consequences if the company fails to respect its responsibilities or agreements with local communities 

• Enabling or contributing to remedy if harms occur   

The Lead the Charge Leaderboard report serves both as an incentive for automakers to do better, and a tool to help them assess and improve their supply chain due diligence practices. This case study, along with our Policy Proposal to Advance a Just Energy Transition for Project-Affected Communities set out what it takes in practice to ensure that at-risk communities have agency in decision making about how mining projects proceed. The six-measures in our policy proposal lay out a road map for automakers and their suppliers to fulfill their human rights due diligence responsibilities and promote a just energy transition for project-affected people, as they seek to bring renewable energy technologies to scale.  

Read the case study here.

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Building on recommendations we jointly submitted earlier this year, alongside more than 30 other civil society organizations, our latest submission urges the IFC to incorporate a new client-focused Broad Sustainability Support requirement in the updated Performance Standards. Our submission highlights extensive evidence showing that projects that fail to secure community support often face costly delays, conflict, litigation, reputational damage, and, in some cases, violence. Research across the mining, infrastructure, agribusiness, and other sectors demonstrates that meaningful engagement with affected communities is not only a human rights imperative but also a sound business strategy. 

Ultimately, up-front investment in communities saves money and would help ensure the IFC projects meet their development objectives.  In that context, we welcome the IFC’s proposal to develop a new, standalone Performance Standard on Stakeholder Engagement, and we urge leadership to ensure this new standard includes a requirement for clients to secure and maintain Broad Community Support. Our policy proposal to advance a just energy transition outlines six core principles to engaging project-affected people, including through early engagement, equitable negotiations, and enforceable community benefit agreements. The new Broad Community Support requirement should incorporate these principles and must go well beyond the IFC’s current consultation requirements, which have not proven effective. 

Our submission also calls on the IFC to ensure that the Broad Community Support requirement is met before financing is approved and disbursed (i.e., when IFC leverage is highest) and to take steps to ensure that Broad Community Support is maintained throughout the project lifecycle. 

Everyone loses when development projects create social conflict, and there is already broad agreement that up-front investment in communities is the best and most cost-effective solution. It is time for the IFC Performance Standards to reflect that reality.  

Read the full comments: https://www.inclusivedevelopment.net/wp-content/uploads/2026/06/Stakeholder-Engagement-and-Broad-Community-Support-May-15-2026-1.pdf

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Yesterday, Inclusive Development International supported ten affected individuals, alongside the non-governmental organizations FIAN, Misereor and Watch Indonesia, to file a complaint under the German Supply Chain Act against Heidelberg Materials over its plans to build a limestone mine and cement factory in the middle of the Kendeng Mountains of Central Java.  The complaint was submitted to Germany’s Federal Office for Economic Affairs and Export Control (BAFA) ahead of Heidelberg Material’s annual general meeting today. It alleges that the company violated its corporate due diligence obligations under the Act by failing to properly assess or develop plans to mitigate serious environmental and human rights risks posed by the project to affected communities, including the Samin people, who self-identify as an Indigenous.   

“If the project is implemented, we face an ecological catastrophe, impoverishment, and violations of our human rights,” said Bambang Sutikyo, one of the complainants who lives in the affected region.  

The complaint cites several scientific studies and a 2017 study commissioned by the Indonesian presidential office that point to the significant risks of mining in the region, which is characterized by a complex and fragile underground aquifer system that has long sustained local people and agriculture, and that is of vital spiritual significance to the Samin. It also acts as a natural carbon sink. Implementation of the cement project plans would irrevocably impair water availability and soil quality, threatening to cause serious consequences for the livelihoods, food security, and health of between 35,000 and 200,000 people, including Indigenous people and farmers, in the Kendeng region. “We are losing our livelihoods, such as our land and agriculture, which allow us to feed our families, meet our daily food needs, and pay for our children’s schooling,” complainant Bambang Sutikyo continued.  

Heidelberg Materials AG, one of the world’s largest building materials companies, has been aware of the human rights risks for years, yet is sticking to its plans. “The Supply Chain Act obliges Heidelberg Materials to comprehensively investigate the risks and prevent negative impacts. This is only possible by halting the project,” explains Insa Heinke of FIAN. “We expect the Federal Office for Economic Affairs and Export Control (BAFA) to order appropriate measures and, if necessary, impose fines to enforce them.” 

“If Heidelberg Materials wants to position itself as a responsible business leader that follows the law, it cannot move forward with a project that poses such severe risks to the Samin People, including their vital water sources and sacred sites, without their agreement,” said Natalie Bugalski, Senior Legal and Policy Director at Inclusive Development International.  “They have never meaningfully engaged with affected communities about whether this project should proceed, which is why we brought this legal action today.” 

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We welcome the Boards’ decision to commission this review, and we appreciate many of the draft recommendations, including regarding increased transparency and accountability throughout complaint processes, and the importance of sending a clear and consistent message about preventing harm in the first place. Additionally, we fully endorse their recommendation that the policy be reviewed every 5 years.  

But there are also suggestions that, as an organization that has accompanied numerous communities in their engagement with CAO, we believe should be avoided or treated with caution, including: 

• Any codification of dispute resolution timelines. We worry that this recommendation, as written in the draft, runs the risk of promoting a complaint analysis process that overly focuses on the length of time of a given case, rather than the likelihood of successful resolution. 

• Further defining what it means for a complaint to be “within scope” or what constitutes a “material link”. There is a lot at stake for affected communities if any new definitions narrow financial intermediary eligibility narrows the scope of eligible complaints. 

• Any non-transparent, closed-door processes for developing any new definitions related to eligibility criteria.  

 
Most importantly, any policy changes should be led by the CAO and go through a formal and robust public consultation process. Read more: https://www.inclusivedevelopment.net/wp-content/uploads/2026/06/May-2026-CAO-Targeted-Review-comments.pdf

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Last year was brutal for the cause of human rights that we hold dear, but together with our community and civil society partners around the world, we were still able to deliver some of the most meaningful impacts in our organization’s history.

These wins included:

• Helping displaced Cambodian communities secure a groundbreaking financial settlement from Asia’s largest sugar supplier.
• Supporting Guinean communities to negotiate crucial water access and protection agreements with one of the world’s largest bauxite mines, which has wreaked havoc on their rivers and streams. 
• Training dozens of advocates in Africa and Latin America on our Follow the Money research and advocacy methods. 
• Launching and gaining momentum behind our policy proposal for a new, rights-based approach to community participation in decision-making about mining and other large-scale investment projects that impact their land and lives.  

… and so much more.  

Read the full report online here. 

The post Against All Odds: Our 2025 Impact Report appeared first on Inclusive Development International.

This week, we transferred the final payments to more than 600 families who were forcibly dispossessed to make way for the company’s sugarcane plantations in Northwestern Cambodia in 2008 and 2009—allowing them to move on and focus on rebuilding lives that were upended by violence and displacement so many years ago. 

We are thrilled to share this news, along with a new short film documenting how the Oddar Meanchey families, with the support of our team and partner organizations, were able to secure a measure of justice after so many years.

A follow-the-money model for success

The film tells the story of how, after our follow-the-money research revealed that the Thai sugar giant Mitr Phol—supplier to global brands including Coca-Cola and Nestlé—was behind the land grabs, affected communities were able to leverage buyer advocacy, a series of complaints to international human rights and corporate accountability mechanisms, and a groundbreaking transboundary class action lawsuit to hold Mitr Phol accountable. 

This process was not easy and no community should have to wait more than 15 years for justice. But contrary to the adage, justice delayed is still justice in the eyes of these families, who fought long and hard for this outcome and are thrilled that it has finally come.

We are beyond proud of our team, partners and especially the community leaders and plaintiffs in this case for their tireless advocacy and perseverance.

This story is a testament to what is possible when communities affected by harmful investment projects have the support they need to follow the money and gain leverage to hold powerful corporations accountable. It is an example that our team, as well as other advocates and communities, can learn from for a long time to come.

The post A sweet ending for plaintiffs in the Cambodian sugar case appeared first on Inclusive Development International.

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For many years, there was an urgent need to review the mechanism’s policy to improve access to accountability and remedy for communities harmed. In the past year, Both ENDS, IDI and SOMO have participated in the consultation process, together with other CSOs that have supported communities through complaints procedures, as well as experts on the topic of DFI accountability. We are very pleased to see a strengthened mechanism, that is a result of commitment by all actors involved. Nevertheless, there are still critical gaps that we believe need to be addressed.

The new policy introduces significant improvements that strengthen the ICM’s mandate and
operational capacity. We particularly welcome the:

• Structural improvements including creation of a structurally distinct, single mechanism with its own website and creation of the ICM’s advisory and outreach functions.
• Possibility to file complaints post-exit: the ICM is allowing complaints to be submitted up to 12 months after project exit. However, for a complaint to be admissible post-exit, it is required to show “compelling reasons” that the complaint could not be submitted prior to exit, which is still outside of best practice.
• Enhanced references to international standards including IFC Performance Standards, UN Guiding Principles on Business and Human Rights, and OECD Guidelines. Although the language used in the policy still uses the Bank’s own environmental and social policies as point of reference, which leaves some room for confusion: if FMO, DEG or Proparco weaken their policies, it may cast confusion about whether or not the above mentioned standards apply.
• Explicit recognition of retaliation risks against marginalized populations including women, Indigenous Peoples, and human rights defenders, and measures to mitigate risks in contexts where these risks are present.
• Procedural improvements including shorter timelines, clear explanations about the procedures, a clear mandate to monitor Management Action Plans (MAPs), and a possibility to also monitor non-compliances beyond the MAP.
• Deferral process improvements including important changes made between the draft and final policy that give more agency to complainants, particularly language making it clear that the Independent Expert Panel will not defer complaints if complainants object and clarifying that deferral can be terminated at any time. This represents a positive step forward in respecting complainant agency throughout the process.
• Steps toward greater independence including a strengthened secretariat, more autonomy over budget, and independent communications channels.
  

Despite these advances, several fundamental gaps persist that limit the ICM’s ability to fulfill its mandate and ensure that the banks are accountable and communities have access to remedy: Financial Intermediaries Gap: While the policy acknowledges complaints against financial intermediaries (FIs) and provides much needed clarification for how the ICM will handle FI complaints, it also creates a significant remedy gap that is out of line with best practice, as well as the UN Guiding Principles. The policy denies access to Dispute Resolution for all FI complaints in which the DFI applied a Portfolio Approach, even if the sub-project that is the subject of a complaint falls within the scope of the DFI’s loan to the FI (e.g. inside the “use of funds” or the “ring fence.”).Moreover, the policy effectively limits the scope of Compliance Review in such cases and attempts to preemptively distance the DFIs from playing any role in contributing to remedy. This is a significant departure from how other independent accountability mechanisms (IAMs) and DFIs handle FI complaints, and it directly contradicts the well-established human rights principle that financial institutions that contribute to harm must contribute to remedy.

Given that the Banks’ preferred approach to FI lending is the Portfolio Approach, this policy will effectively block communities from accessing remedy for the majority of cases in which these DFIs finance harmful projects through intermediaries. Moreover, it creates complicated rules which may be difficult for many CSOs and complainants to understand. Additionally, increased transparency is a necessary condition to be able to be accountable for FIs. Although the Banks have committed to revising their disclosure policies on FIs, this has yet to materialize.

Early Complaint Timeline Gap: There remains confusion about when complaints can be filed
during the project lifecycle. The policy states complaints are not eligible when “there is not yet an active financial relationship.” This creates contradictory guidance, especially when combined with the definition of DFI-financed operation as “any activity or any asset of the Client that is or is going to be financed by DFI funds.” The lack of clarity on early complaint filing is problematic from both a complainant perspective and a prevention of harm perspective, as it limits opportunities to address issues before they cause harm or otherwise escalate.

Dispute Resolution Timeline: The strict 24-month cut-off for Dispute Resolution is inappropriate. Some productive and promising dispute resolution processes may require longer timeframes to reach meaningful resolution. Looking across IAMs, there are many examples of dispute resolution process that ultimately achieved successful results, but where such results took longer than 24 months. Forcing otherwise productive processes to close simply due to a policy timeline can be counterproductive and undermine the effectiveness of the mechanism.

Inadequate Retaliation Protections: The policy fails to establish robust measures to address
retaliation against human rights defenders. Critical missing elements include: the ICM’s authority to publicly recommend project suspension in cases of unresolved retaliation, and mandatory publication of disaggregated data on all documented retaliation cases including investigation findings and recommended actions.

Insufficient Capacity and Independence: While the policy acknowledges the need for greater capacity, the language remains vague and non-committal. We recommended an explicit commitment to sufficient ICM dedicated staffing (a minimum of 3 committed positions) and adequate budgetary resources to execute its mandate effectively and independently. 

Limited Mandate and Scope: The policy maintains restrictions on self-initiation by the ICM and excludes climate-related complaints, limiting the mechanism’s ability to address emerging environmental and climate justice concerns. 

Some of these gaps can be addressed immediately via improved practices of both the ICM and the Banks, without any changes to the new policy. The Banks can improve their transparency on FIs, but they must live up to that commitment, which has been outstanding for several years without result. It is also well within the power of the Banks to contribute to remedy in FI cases, in particular where a compliance review helps establish their contribution to harm. Additionally, in terms of zero tolerance for retaliation, the Banks and the ICM can take a step forward when the risk occurs by taking meaningful action. 

The revised ICM policy represents a significant advancement over its predecessor, demonstrating that stakeholder engagement and civil society input can yield meaningful improvements in institutional frameworks. We commend the adoption of numerous recommendations that emerged through the consultation process. The trajectory shown through this policy revision provides a foundation for further advancement, but the journey toward genuine accountability and effective remedy is far from complete. We remain committed to working collaboratively while holding the institutions accountable to the highest standards.

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