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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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

The post Civil Society Organizations Respond to CAO Targeted Policy Review appeared first on Inclusive Development International.

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. 

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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.

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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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The fourth edition of the Lead the Charge Auto Supply Chain Leaderboard finds that automaker commitments and supplier requirements for responsibly sourced minerals have grown substantially since 2023. Companies such as BYD, Geely, Hyundai and Kia have established new commitments and requirements, while others such as Renault, Volvo and BMW have expanded existing ones. Additionally, over 80% of the indicators on responsible mineral sourcing have now been met by at least one company.

Notably, the number of automakers with explicit commitments and supplier requirements to respect Indigenous Peoples’ rights—whose traditional lands encompass approximately 50% of the world’s energy transition mineral resources—has also grown from just six out of 18 companies in 2023 to 12 in 2026.“By pushing for improvements across a variety of issues, electric vehicle makers are demonstrating that they have the ability to help transform mineral supply chains,” said Ellen Moore, the Mining Program Director at Earthworks. “As influential buyers, they can steer the mining industry towards practices that respect Indigenous Peoples’ rights, workers, human rights, and the environment.”

“By pushing for improvements across a variety of issues, electric vehicle makers are demonstrating that they have the ability to help transform mineral supply chains,” said Ellen Moore, the Mining Program Director at Earthworks. “As influential buyers, they can steer the mining industry towards practices that respect Indigenous Peoples’ rights, workers, human rights, and the environment.” 

The report also finds that some of the top performing companies are starting to go further to ensure the minerals in their EVs are mined responsibly, imposing more stringent requirements for specific minerals and undertaking on-the-ground due diligence to verify supplier compliance. For example: 

• Ford, Tesla and Renault have disclosed direct mineral sourcing agreements that include specific human rights and environmental requirements in contractual terms.
• Mercedes, Volkswagen and Tesla publish detailed raw material reports on their progress to prevent, mitigate and remedy human rights and environmental harms across a range of supply chains such as lithium, cobalt and nickel. In these reports, the companies disclose multiple examples of direct engagement with extractive companies and impacted rights holders to address specific harms — including with copper and cobalt suppliers in the DRC, lithium suppliers in Chile and Australia, and nickel suppliers in Indonesia.
• Mercedes, Ford and Volkswagen require suppliers of battery minerals to undergo audits by the Initiative for Responsible Mining Assurance (IRMA), the most robust and comprehensive third party standard on responsible mining according to analysis from Lead the Charge and others. Ford has made IRMA verification a condition of its direct sourcing agreement for lithium from Australia.

“By rejecting weak systems that drive a race to the bottom like the Consolidated Mining Standard, automakers can demonstrate their commitment to human rights and the environment,” said Chelsea Hodgkins, senior ZEV policy advocate with Public Citizen’s Climate Program. “Automakers must join civil society and demand high road mining practices.”  

Taken together, this progress shows a clear trajectory of growing automaker demand for responsibly produced minerals, laying down a challenge for mining companies—which have long been associated with human rights and environmental abuses—to deliver or risk losing business.

Foundations mostly in place, but implementation gaps remain

The analysis shows automakers have made strong progress on due diligence fundamentals, with the average score across all automakers on overall human rights due diligence now up to 47%—up 16 percentage points since 2023. 

Ford and BMW lead in this area, both achieving 73%. However, Chinese companies BYD and Geely were among the biggest improvers in this area in 2026. BYD achieved a 20 percentage point increase in its overall due diligence score after establishing a new supplier code of conduct and supply chain grievance mechanism. Geely published standalone Human Rights and Sustainable Raw Material policies. 

Whilst the industry is moving in the right direction, these foundational practices are not yet translating into consistent, targeted action to address major sources of human rights risks and impacts in EV supply chains. Average scores drop sharply—to just 20%—across the three issue-specific human rights subsections evaluated by the Leaderboard, covering transition mineral sourcing, Indigenous Peoples’ rights, and workers’ rights in the supply chain. 

“As Climate Rights International has documented in Indonesia, the world’s largest producer of nickel, the consequences of the rush for battery minerals can be disastrous for local communities and the climate, including land grabbing, severe air and water quality pollution, attacks on environmental human rights defenders, and the buildout of new captive coal plants to power the nickel industry,” said Krista Shennum, Senior Researcher with Climate Rights International. “But it doesn’t have to be this way. Electric vehicle companies have unique leverage to demand that the minerals used in their supply chains are mined and processed in an environmentally sustainable and rights-respecting way and could position themselves as global leaders in the fight against climate change if they step their due diligence.” 

Leaders are pulling ahead with more meaningful due diligence

The analysis shows a core group of industry leaders – Ford, Mercedes, Tesla, Volvo and Volkswagen – are pushing further ahead. While these companies have significant room for improvement, they have achieved a rate of progress that is double that of the remaining 13 companies since the first edition of the Leaderboard.

When it comes to human rights due diligence and responsible sourcing, what separates these better performers from the rest of the industry isn’t just having many of the right commitments and policies in place — it’s implementing more targeted due diligence processes at the mineral and issue-specific level, along with disclosing more granular and disaggregated reporting of progress and policy enforcement in specific contexts. 

These leaders are starting to conduct more sophisticated risk assessments, developing tailored strategies for different supply chains, and engaging directly with suppliers and rights holders to address specific harms.

“EV makers are in a position to raise the bar for the mining industry at a critical time, as demand for ‘transition’ minerals surges. We have been pleased to see  some companies beginning to engage more meaningfully and directly with upstream suppliers and with affected communities, but there is so much more they could be doing,” said David Pred, Executive Director of Inclusive Development International. “For example, automakers should routinely use site visits to engage with affected communities to understand their concerns, and they should be using their leverage to address harms and enable remedial actions where needed. EV makers also have an opportunity to prevent harm and secure genuinely responsible supply chains by supporting upstream mineral suppliers to negotiate and enter into fair and equitable land access agreements with communities before new projects start.”  

Companies acting now are building regulatory resilience

The emerging best practices in this year’s Leaderboard represent what more meaningful implementation of international human rights due diligence frameworks – such as the UN Guiding Principles and OECD Guidelines – looks like in practice. Because incoming regulations, from the EU Corporate Sustainability Due Diligence Directive to the EU Battery Regulation, are grounded in these same frameworks, automakers making genuine progress now will face lower compliance costs tomorrow.

“The EU’s green rules have turned sustainability from a nice-to-have to the price of entry,” said Franziska Gruning, Raw Materials Officer with T&E. “The Batteries Regulation requires carmakers to trace key battery materials and take action on related risks if they want to sell cars in Europe.”  

However, despite the progress being made, the Leaderboard shows there is still a long way to go. Some companies, such as Toyota, GAC and SAIC, are still failing on the basics, whilst even industry leaders are still showing patchy performances, with no company reaching 50% of the total scores obtainable in the analysis. 

“At a time when critical mineral extraction continues to drive environmental damage and human rights abuses, the poor performance of some automakers is unacceptable. With an industry average score of just 25%, and some companies failing basic due diligence, the human and environmental costs remain severe,” said Eric Ngang, Program Director with Afrewatch International. “Box-ticking audits are not enough. Automakers must go beyond formulaic compliance and scale up targeted, supply chain-specific actions that create real impact. Policymakers, especially in major consumer markets, must enforce strong, mandatory regulations to ensure minimum standards across the industry. This year’s Leaderboard shows that meaningful progress is achievable and already demonstrated by leading companies. There is no justification for leaving producing countries and affected communities to shoulder the burden of the transition alone.”

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Inclusive Development International (IDI) and the Data Science Institute at the University of Chicago (DSI) have launched expanded versions of our free-to-use Shareholder Tracker and Development Bank Investment Tracker (DeBIT) tools, providing users with up-to-date information on the investments of a vast universe of financial actors that would otherwise be prohibitively expensive or time consuming to track down.

Join us on Tuesday, March 10 at 10am EST for a practical demonstration of what the new tools can do. Register here.

New Shareholder Tracker covers thousands of additional global investors 

The new and improved Shareholder Tracker allows users to instantaneously search the shareholdings of 4,200 global investors, a more than 5,000 percent increase from the 80 included in the original version. While the initial version covered the world’s largest investment firms, scraping information from quarterly filings to the U.S. Securities and Exchange Commission (SEC), the new version covers every investor filing a 13F form to the SEC—that is, any investor with more than $100 million in assets under management that does business in the United States, including pension funds, socially responsible investors and impact-driven funds. The tool also directly scrapes the websites of 17 European pension funds that do not disclose to the SEC and have historically been responsive to engagement from human rights advocates. 

“Shareholders are important targets in corporate accountability advocacy because they have leverage over companies that harm people and the planet, and a responsibility to use that leverage. The Shareholder Tracker brings them out of the shadows so that advocates can identify and engage them to effect change,” said Dustin Roasa, IDI’s senior research director.

Data in the Shareholder Tracker is now automatically refreshed on a quarterly basis (as soon as new 13Fs are filed with the SEC), giving users real-time insight into the shareholders of an estimated 17,500 publicly traded companies around the world that may be harming people and the planet. Advocates can also use the tool to access a comprehensive and searchable list of the current equity holdings of specific investors, allowing them to, among other things, assess how well those investors are upholding commitments to divest from specific companies or sectors—for example, fossil fuels. The tool has also been updated to allow users to sort investors according to the market value of their shareholdings in specific companies—meaning they can easily identify those actors with the most potential leverage. Users can also filter results by investor type (i.e., pension funds vs. institutional investors) and download search results, making shareholder research and engagement quicker and easier. 

DeBIT tool provides easy access to real-time information on development bank investments 

The DeBIT tool allows users to search investments made by 16 development finance institutions that have independent complaint mechanisms that are accessible to affected communities. DeBIT has been updated to streamline the user experience and ensure it reliably represents the most up-to-date information available. For researchers investigating a specific harmful project or company, DeBIT can quickly establish which, if any, of the 16 development banks are directly exposed to it. This would otherwise require users to search 16 separate websites for every company or project of interest. The tool is especially useful for people trying to uncover development bank connections to harmful projects through complex, multilayered business relationships such as financial intermediary lending, which can be time-consuming and difficult when done manually. Campaigners focused on influencing the policies of one development finance institution can also easily use the tool to get an overall picture of what that institution is financing, with numerous possibilities for sorting and filtering by project status, sector, country or year. 

Democratizing access to financial information  

The Shareholder Tracker and DeBIT tool updates are part of Inclusive Development International’s ongoing work to develop a suite of tools that gives community environmental and human rights advocates and other public interest researchers access to important financial data that is currently only available through paid subscription services—such as Bloomberg Terminal and LSEG Workspace—that are prohibitively expensive for most civil society organizations and public interest researchers. 

As part of this work, Inclusive Development International, BankTrack and DSI will soon be launching a complementary tool allowing users to track commercial bank loans and bond underwriting. This Commercial Debt Tracker will help users quickly identify private-sector financial institutions that are exposed to a harmful project, expanding the universe of potential advocacy targets. 

By automating key steps in investment and supply chain research, these tools—combined with our Follow the Money research support, in-depth trainings and do-it-yourself resources—play a central role in our efforts to grow a wider community of advocates who are employing these proven  methods in their efforts to hold corporations and development institutions accountable for their harmful impacts on  human rights and the environment.

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