Independent accountability mechanisms (IAMs) were born out of crises, such as major environmental disasters and large-scale resettlement gone awry on development projects. Starting in the 1990s, international financial institutions (IFIs) established mechanisms to allow people affected by their operations to directly bring their complaints relating to noncompliance by the IFIs with their environmental and social policies. While IAMs differ in nature and structure, collectively they share a common objective to independently assess people’s environmental and social complaints and seek to address their concerns.
The Project-affected People’s Mechanism (PPM) is AIIB’s IAM or independent complaints-handling mechanism. The PPM conducts an independent and impartial review of submissions from project-affected people who believe they have been or are likely to be adversely affected by AIIB’s failure to implement its Environmental and Social Policy (ESP).
The PPM promotes compliance with the ESP and minimizes the reputational risk to the Bank by providing an opportunity for an independent and impartial review of submissions by Project-affected People who believe they have been or are likely to be adversely affected by AIIB’s failure to implement its ESP.
The Complaints-resolution, Evaluation and Integrity Unit (CEIU) is responsible for the functioning of the Project-affected People’s Mechanism (PPM) through its Managing Director (MD-CEIU).
As head of the PPM, the MD-CEIU reports directly to AIIB’s Board of Directors and oversees the handling of submissions to the PPM, the issuance of PPM reports, and PPM’s outreach, learning and training activities.
The PPM is assisted by a Secretariat (PPM Secretariat), headed by a CEIU staff (Head-PPM Secretariat). The MD-CEIU supervises and provides guidance and direction to the Head-PPM Secretariat and PPM personnel. More details can be found in the PPM Rules of Procedure, Attachment 1. CEIU functions are outlined in the Bank’s Oversight Mechanism and Terms of Reference for the Complaints-resolution, Evaluation and Integrity Unit.
A key consideration in designing the CEIU was to ensure it could exercise relevant functions, including the PPM’s complaints-handling function, independent of AIIB Management (Management). The MD-CEIU is therefore not part of AIIB Management and reports directly to AIIB’s Board of Directors.
The Bank requires all of its Clients to inform Project-affected people about the availability of the PPM. Information on the availability of the PPM is provided in an accessible and understandable manner in locally appropriate language(s), including on the Client’s Project-related website. Information about the PPM is also available on the AIIB website and in the project documents of an approved project.
The PPM applies to all AIIB-financed projects that predate the creation of the PPM (PPM Policy, Section 1.5).
The IAMnet is a virtual network of dedicated practitioners who contribute to the regular exchange of ideas and assist with institutional capacity building in accountability and compliance as components of corporate governance.
The IAMnet includes the accountability mechanisms of multilateral development banks and bilateral financing institutions. Participation in the IAMnet allows for exchange of IAM good practices and strengthening of collaboration on institutional accountability and compliance.
Please refer to the IAMnet website for further information.
Additional information can also be found in the IAMnet video.
Yes. The PPM is a member of the IAMnet.
The PPM has three functions as follows: (See Policy on the PPM, Section 2)
- Project Processing Query (PPQ)
The PPQ function enables Project-affected people to obtain rapid resolution of their concerns over simple matters which arise during AIIB’s environmental and social due diligence of a Project, and which do not require dispute resolution. They may include inquiries about:
- The consultation process related to a Project.
- Requests to address any environmental nuisance such as dust, noise or mobility restrictions experienced during Project preparation.
- Dispute Resolution (DR)
The DR function facilitates a dialogue between AIIB, the Project-affected people and/or the Client with a view to agreeing on actions to mitigate known and quantifiable, potential or actual material adverse environmental or social impacts that arise during AIIB’s environmental and social due diligence of a Project or during Project implementation.
- Compliance Review (CR)
The CR is designed to investigate allegations by Project-affected people that AIIB has failed to comply with its obligations under the ESP in its environmental and social due diligence of a Project or its oversight of the Project during implementation, thereby causing or being likely to cause material adverse environmental or social impacts on the Project-affected people and, if the allegations are substantiated, to review any action plan proposed by Management to address these impacts.
Typical steps for all three PPM functions are summarized in the Annex of this FAQ.
The PPM recommends the most suitable processing option based on submission content, timing and eligibility criteria, taking the Requestors’ proposal, if any, into account. The Requestors’ decision on which process they wish to pursue will, however, be final (PPM Policy, Section 6.3).
The PPM facilitates a constructive dialogue between AIIB Management, the Client, the Requestors and any other relevant parties to identify solutions to address the concerns raised. The Project processing queries are handled as promptly as possible in order to facilitate resolution of concerns during Project preparation.
The PPM aims to facilitate the formulation and signing of a dispute resolution agreement containing a time-bound, monitorable implementation schedule for specific agreed actions.
The PPM seeks consent of the parties to the dispute to undertake dispute resolution and document the agreed approach and methodology, as well as identified issues and timelines for the dispute resolution process. Once dispute resolution agreement is reached, the PPM monitors the implementation of the agreement in accordance with the agreed schedule.
The PPM encourages the parties to the dispute to reach an agreement. However, if agreement is unlikely to be reached within a reasonable period of time, the PPM may terminate the review of the submission (PPM Policy, Section 6.7.7).
Any party to the dispute may terminate the dispute resolution process at any stage of the review. In such case, the Requestors may submit a request for Compliance Review, provided that it meets the eligibility criteria for such submission (PPM Policy, Section 6.7.8).
Based on the information provided in the submission, Management’s response (including any actions proposed by Management to address the issues raised in the submission), and additional information obtained during site visits from the Board Director concerned and any local authorities or agencies involved in the Project, the PPM determines whether the submission meets the eligibility criteria set out in Section 5.2 of PPM Policy, and decides whether to recommend that the Board of Directors approve the commencement of the Compliance Review.
If the PPM recommends approval of the commencement of the Compliance Review, the Board of Directors decides whether to sanction a Compliance Review (PPM Policy, Section 6.8.2).
If the Board of Directors approves the PPM’s recommendation to commence the Compliance Review, the PPM finalizes the terms of reference for Compliance Review in consultation with the Board. The PPM forms a Project-specific task force chaired by the MD-CEIU to carry out the Compliance Review. The Requestors, the Client, local authorities and agencies involved in the Project, the Board Director concerned, Management and other AIIB staff are provided an equal opportunity to be heard during the Compliance Review. If there is a finding of noncompliance, Management prepares an Action Plan after consulting with the Client and the Requestors. The final Compliance Review report is sent to Board together with all responses including the Management Action Plan.
If the PPM determines that there has been noncompliance with the ESP, AIIB Management will prepare a proposed Management Action Plan (MAP) which includes actions to address issues set out in the PPM’s Compliance Review report, and is subject to the approval of the Board of Directors.
The final Compliance Review report, together with Management’s response and the Board-approved MAP, are circulated by the PPM to the Requestors and by Management to the Client and are disclosed by the PPM within 10 working days following the Board’s decision.
Management monitors and submits monitoring reports to the Board of Directors on the implementation of the MAP in accordance with timelines specified in the MAP. The PPM reviews Management’s monitoring reports and prepares a status report on MAP implementation, at least annually.
If the PPM determines that the Bank was in compliance, the final Compliance Review report, together with Management’s response, are circulated by the PPM to the Requestors and to the Board for information, and by Management to the Client. These are publicly disclosed by the PPM within 10 Working Days following their circulation to the Board.
If at any point during the Compliance Review the PPM learns of arbitral or judicial proceedings involving substantive issues raised in the submission, the PPM assesses the implications of such parallel processes and submits a recommendation to the Board of Directors on whether to continue with the Compliance Review. As an interim measure, the PPM may suspend the Compliance Review until the AIIB Board of Directors decides on the matter (PPM Policy, Section 6.8.5).
Detailed guidance on filing a submission is provided on the AIIB website (File Your Submission). Please send your submission to the address below. You can also contact the PPM Secretariat for guidance on how to correctly file your submission at the same address:
Managing Director, Complaints-resolution, Evaluation & Integrity Unit (CEIU)
Asian Infrastructure Investment Bank (AIIB)
Tower A, Asia Financial Center, No.1 Tianchen East Road, Chaoyang District, Beijing 100101 China
Email address: firstname.lastname@example.org
Fax Number: +86-10-8358-0003
AIIB provides information about its proposed and approved projects on its website. You can search projects by approval year, member, sector, financing type and status. Project-related documents are also disclosed on the project sub-page in accordance with AIIB’s Policy on Public Information.
Requestors can file requests with the PPM which relate to environmental and social issues on AIIB-financed projects.
No. Such complaints should be submitted to the Integrity function of CEIU. More details on reporting fraud and corruption can be found here.
No. Such complaints should be submitted to AIIB Management.
No. Such complaints should be submitted to AIIB Management through the Ethics Hotline.
Two or more Project-affected people (Requestors) may file a submission to PPM.
Yes. In principle, an individual or a CSO/NGO can represent the Project-affected people. Requestors may authorize an in-country representative to file a submission on their behalf (PPM Policy, Section 3.1).
In exceptional situations, when in-country representation is unavailable, the requestors may designate an individual or organization outside of the country as their authorized representative to file a submission (PPM Policy, Section 3.1).
No. This is because the PPM needs sufficient detail to communicate with those who approach it (PPM Rules of Procedure, Section 3.5).
A submission needs to include the following information: (PPM Rules of Procedure, Section 6.1):
- Name of Requestors, as well as address, contact details and preferred mode of contact. Please note that two or more Project-affected people (or Requestors) may file a submission and send it directly to the PPM.
- If designated, the Authorized Representative’s name and contact details and Requestors’ authorization to the Authorized Representative to file a submission on their behalf.
- Any request for confidentiality of the identity of the Requestors or of an in-country Authorized Representative or other information, and reasons for such request.
- Name and location of the AIIB-financed Project concerned.
- What Requestors consider to be the direct and material adverse environmental or social issues to be addressed.
Requestors, are encouraged, but not required, to provide the following additional information:
- The provisions of the AIIB Environmental and Social Policy that Requestors consider as not having been complied with, and details about the alleged noncompliance.
- Any steps Requestors have taken to resolve the issue (e.g., approaching the Client, the Project-level Grievance Redress Mechanism, AIIB Management, government, judicial or law enforcement bodies) and the outcome.
- The unresolved issues.
- Requestors’ view of the best way to approach the issue and the most satisfactory result.
- Whether Requestors would like their submission to be treated as a Project Processing Query, Request for Dispute Resolution or Request for Compliance Review.
- For further information on the content of a submission, please see the PPM Rules of Procedure, Section 6.1 and Attachment 2 (Sample Submission Form).
Please ensure that the submission is made in accordance with the requirements of Section 4 (Time Limits for Filing a Submission) and Section 5 (Eligibility of Submissions) of the PPM Policy. See this FAQ for more information.
More information can be found in File Your Submission at aiib.org
Section 4 of the PPM Policy spells out the Time Limits for Filing a Submission.
For every project that AIIB intends to finance, it issues a Project Summary Information (PSI) on its website.
A Project Processing Query may be submitted after the PSI has been disclosed by AIIB and before the approval of the financing.
Requests for Dispute Resolution or Compliance Review may be submitted (i) after the PSI has been disclosed by AIIB, in case of Dispute Resolution and (ii) after approval of the Financing, in case of Compliance Review, and before one of the following dates:
- For Sovereign-backed Financings1: The Closing Date.2 In exceptional circumstances where the Client continues to be bound by environmental and social undertakings beyond the Closing Date, the PPM may consider the request as eligible if it is submitted during the 24 months following the Closing Date.
- For Nonsovereign-backed Financings:3 The date 24 months following the date of the last disbursement of AIIB’s funds or, in the case of guarantees, the date 24 months following the date of the last disbursement under the underlying obligation or, in the case of equity funding, prior to AIIB’s exit from its investment.
1Sovereign-backed Financing means: (i) a loan to, or guaranteed by, a Member; or (ii) a guarantee that: (a) covers debt service defaults under a loan that are caused by a government’s failure to meet a specific obligation in relation to the Project or by a borrower’s failure to make a payment under the loan; and (b) is accompanied by a Member indemnity.
2 Closing Date means: (a) for loans, the date specified in the Loan Agreement (or such later date as the Bank shall establish by notice to the Loan Parties) after which the Bank may, by notice to the Loan Parties, terminate the right of the Recipient to withdraw from the Loan Account (For details, see General Conditions for Sovereign-Backed Loans, Appendix, No. 8.); and (b) for guarantees, the date of completion of the Project.
3 Nonsovereign-backed Financing means any financing extended by the Bank that is not a Sovereign-backed Financing; it includes any financing to or for the benefit of a private enterprise or a sub-sovereign entity (such as a political or administrative sub-division of a Member or a public sector entity) that is not backed by a guarantee or counter-guarantee and indemnity provided by the Member to the Bank.
As per Section 5 (Eligibility of Submissions) of the PPM Policy, a submission shall be ineligible to be considered by the PPM, if:
- It does not relate to a Project that has been approved for financing by AIIB or in relation to which a PSI has been disclosed;
- It is anonymous;
- It raises allegations of Prohibited Practices or relates to procurement;
- It relates to any AIIB policy other than the ESP;
- It relates to the adequacy of the ESP;
- The Project is co-financed with another multilateral development bank (MDB) or bilateral development organization and AIIB has agreed to the application of the environmental and social policies and procedures and to rely on the Independent Accountability Mechanism (IAM) of such institution;
- It is filed outside of the time limits set out in this Policy;
- The Requestors have not made good faith efforts to resolve the issues with the Project-level grievance redress mechanism (GRM) and with Management or have not indicated to the satisfaction of the PPM why they have been unable to do so;
- It raises issues that have already been considered by the PPM, unless there is new evidence or circumstances not known at the time of the previous submission; or
- It has been filed fraudulently, with frivolous, malicious or improper intent or to gain undue competitive advantage.
Further, a request for Compliance Review shall be ineligible if it relates to:
- Actions or inactions that do not involve AIIB’s failure to comply with the ESP or otherwise raises issues unrelated to AIIB’s failure to comply with the ESP;
- Activities, parties or impacts beyond the reasonable control of AIIB (including the conduct of the Client or any third party, unless that conduct is directly relevant to assessment of AIIB’s compliance with the ESP);
- Laws, policies, or regulations of AIIB’s Member government, unless they directly relate to AIIB’s compliance with the ESP;
- Matters concurrently under arbitral or judicial review, save when the Board of Directors authorizes the PPM to process such request; or
- The subject matter of an ongoing Project Processing Query or a Dispute Resolution.
Requestors may file submissions and subsequent communications to the PPM in English or in any official or national language of their country. (PPM Rules of Procedure, Section 6.2.) The sample submission form is now available in several languages on AIIB website (See “File Your Submission” in AIIB website)
Substantive parts of the submission will be translated by the PPM. Requestors will be informed if translation will delay the processing of their submission and in such case, they will be informed of the new submission processing dates.
Yes, unless the Member in which the Project is located objects. Site visits help the PPM better understand submission issues and possible ways to address them.
In the spirit of AIIB’s partnership with its Members, assistance from Members in facilitating timely PPM site visits is anticipated. In case the AIIB Member rejects a site visit request, the PPM informs the Board of Directors and conducts its review on the basis of available evidence.
CSOs can act as representatives of Requestors, if they authorize the CSO to represent them. CSOs can also be advisors to Requestors and also raise awareness among communities and project-affected people about the PPM.
The fact that a submission has been found eligible does not affect ongoing Project preparation or implementation. The review by the PPM of an eligible submission does not prevent Management from addressing the issues it raises directly with the Requestors or the Client. During its review, the PPM may consider actions taken by Management to address issues raised in the submission (PPM Policy, Section 7.1).
If, during its review of the submission, the PPM concludes that continued Project preparation or implementation may potentially result in irreversible material adverse impacts that have not been adequately addressed in accordance with the ESP, the PPM will inform Management in writing of such possible impacts and the reasons for reaching this view. The PPM may also request Management to consider the matter and take appropriate action to address the situation. In such cases, the MD-CEIU shall inform the AIIB President if Management fails to take action to address these matters within a specified period of time following the PPM’s notice to Management, in order to enable the President to work with Management to address such matters. If appropriate action is not taken within a set period of time following the PPM’s notice to the President, the MD-CEIU shall inform the Board of Directors of the situation on a confidential basis (PPM Policy, Section 7.3).
You can do so by clicking Track All Submissions.
Yes. When the PPM acknowledges receipt of a submission, it also reminds Requestors (and their in-country Authorized Representative, if applicable) of a 10-day window to request confidentiality. The PPM takes this confidentiality request into account during any further communications with third parties. (PPM Rules of Procedure, Sections 6.4.3 and 9 and Attachment 4).
In some cases, complete confidentiality may not be possible. See in particular, Section 9 of the PPM Rules of Procedure which provides that “the PPM considers the request for confidentiality and makes all reasonable efforts to grant the confidentiality requested. If, however, confidentiality becomes an impediment to eligibility assessment or effective resolution of issues raised, the PPM advises the Requestors of these concerns and seeks to agree with the Requestors on how to proceed. Failing such agreement, the PPM may terminate the review of the submission.”
The PPM takes any confidentiality requests, if granted, into account in its communications with AIIB management, the Client and any other party. The PPM also initiates a due diligence review to assess possible risks of retaliation and thereafter makes all reasonable efforts to reduce the risk of retaliation to the Requestors. For further information on how the PPM handles issues of confidentiality, see the PPM Rules of Procedure, Sections 6.4.3 and 9. Attachment 4 of PPM Rules of Procedure lists five steps that the PPM takes to mitigate retaliation risk.
AIIB requires the Client to establish, in accordance with the ESP and applicable environmental and social standards (ESSs), a suitable Project-level GRM to receive and facilitate resolution of the concerns and complaints of people who believe they have been adversely affected by the Project’s environmental or social impacts, and to inform Project-affected people of its availability.
No. Project-level GRMs are established and implemented by the Client.
However, if PPM receives a submission related to a project, it informs Management in writing if, during its review of the submission, it identifies that the information about the Project-level GRM has not been adequately disclosed or that the Project-level GRM has not been established or that it is ineffective.
The MD-CEIU informs the President if Management fails to take action to address such matters within a specified period following the PPM’s notice to Management, in order to enable the President to work with Management to address such matters. If appropriate action is not taken within a set period of time following the PPM’s notice to the President, the MD-CEIU informs the Board of Directors of the situation on a confidential basis (Ref. Section 7.2, PPM Policy).
You can send your request to the to the project-level GRM again and Cc the AIIB Project team or Management and the PPM (email@example.com). You can also send your request to the Project team and Cc the PPM – contact information of the Project team leader is provided in the relevant project sub-page on AIIB’s website. If your concerns remain unaddressed, you can directly make a submission to the PPM.
It is not required under the PPM Policy that the issue be first resolved under the GRM or with AIIB Management. Rather, Project-affected people need to make a good faith effort to resolve the issues using the GRM or with Management or indicate to the satisfaction of the PPM why they have been unable to do so (PPM Policy, Section 5.1.8).
AIIB’s ESF allows AIIB to apply a cofinancier’s environmental and social (E&S) policies in case of co-financed projects.
If AIIB has agreed to apply the cofinancier’s E&S policies and has also agreed to rely on the IAM of the cofinancier, the submission is ineligible for consideration by the PPM. In such cases, submissions should be made to the IAM of the co-financier which handles all submissions under the Project in accordance with its policies and procedures. AIIB Management may work with the cofinancier to address the issues raised in the complaint. The PPM will coordinate closely with the cofinancier’s IAM on the handling of the submissions and report to the Board of Directors on the outcome of the review by the co-financier’s IAM of these submissions (PPM Policy, Section 10).
Submissions can be made to the PPM if there is no agreement for AIIB to rely on the IAM of the cofinancier, even if the confinancier’s E&S is applied.
If PPM and/or lead co-financier’s IAM receive(s) any submissions related to E&S issues, both mechanisms will deal with their complaints separately; however, they will work in close collaboration to solve issues raised in the submission. PPM conducts regular exchanges with IAMs of lead co-financiers on ongoing basis to share updates on submissions on co-financed projects.
PPM discloses a list of co-financed projects in CEIU page in AIIB website. This list shows the applicable E&S and IAM for each project and is updated on bi-annual basis.
Yes. The PPM actively organizes a range of outreach activities, often in collaboration with the IAMs of other IFIs, to raise awareness of the opportunities it provides with Clients and other stakeholders that may be interested in, or affected by, AIIB-financed Projects. The PPM organizes in-person as well as virtual outreach activities with local communities, government authorities, local, national and international CSOs and other stakeholders to increase local awareness and capacities to use the PPM. The PPM closely collaborates with the IAMs of other MDBs to organize join outreach activities.
Please send an email to firstname.lastname@example.org with your request and the PPM Secretariat will contact you.