Conflict Resolution Commissioner

Asian Development Bank (ADB)

• Anticorruption and Integrity
  • Report Fraud or Corruption

African Development Bank (AfDB)

• Integrity and Anti-Corruption
  • Complaint Form
    • Anti-Corruption and Fraud Investigation services: Contacts

European Bank for Reconstruction and Development (EBRD)

• Integrity and compliance
  • Investigating fraud, corruption and misconduct

Food and Agriculture Organization of the United Nations (FAO)

• The Office of the Inspector General – Investigations
• Investigations Hotline

Inter-American Development Bank (IADB)

• Independent Consultation and Investigation Mechanism
• How to file a complaint

International Fund for Agriculture Development (IFAD)

• Accountability and complaints procedures

United Nations Development Programme (UNDP)

• How to report wrongdoing
• Accountability / Investigations
• Social and Environmental Compliance Review and Stakeholder Response Mechanism

United Nations Environment Programme (UNEP)

• UNEP Complaints Hotline
• Reporting wrongdoing

United Nations Industrial Development Organization (UNIDO)

• For reporting misconduct
• For reporting environmental and social concerns

The World Bank Group (WBG)

• The Inspection Panel (for IBRD/IDA)
• Compliance Advisor Ombudsman (CAO) - independent recourse mechanism for the International Finance Corporation (IFC) and Multilateral Investment Guarantee Agency (MIGA)
• Integrity Vice Presidency

Conservation International (CI)

• Accountability and Grievance Mechanism
• Accountability and Grievance Mechanism (for GEF)

Development Bank of Latin America (CAF)

• Transparency Committee

Development Bank of Southern Africa (DBSA)

• Independent Grievance Redress Mechanism
• Fraud reporting
• Project Grievance Procedure

Foreign Economic Cooperation Office, Ministry of Environmental Protection of China (FECO)

• Accountability and Grievance Mechanism

Brazilian Biodiversity Fund (FUNBIO)

• Ethics Committee
• Policy for Grievances

International Union for Conservation of Nature (IUCN)

• Project Accountability (For complaints regarding ethics, harassment, fraud, corruption, etc.)
• Environmental and Social Management System Grievance Mechanism

West African Development Bank (BOAD)

• Grievance Service

World Wildlife Fund (WWF)

• Investigating Fraud and Misconduct

Project: “Integrated and Transboundary Conservation of Biodiversity in the Basins of the Republic of Congo” (GEF Grant USD 281,273), part of the Global Wildlife Program, implemented by UNDP

Date complaint received: August 2, 2018

Summary of allegations: Survival International, a UK-based NGO, filed a complaint with the Social and Environmental Compliance Unit (SECU) of UNDP on behalf of six indigenous communities in the Sangha region in the north of the Republic of Congo. The indigenous Baka alleged that their access to the area, which is their traditional homeland and is essential to their livelihoods, has been severely restricted. They also claimed there was no proper consultation process including free, prior and informed consent, that the project would unlawfully evict Baka communities, and expressed human rights concerns. The Baka also alleged that eco-guards subject them to beatings and arrests. Further details are available on the SECU registry.

Date case put under formal review: October 24, 2018

Status and findings: The SECU report was completed June 2020 (final SECU report). It found that: UNDP’s over-arching commitment to human rights was not adhered to with respect to the rights of indigenous peoples. Investigation obtained credible testimony during the fieldwork in February 2019 not only from representatives of the indigenous (Baka) communities, but also from government and non-governmental sources, that armed eco-guards engage in violence and threats of violence against the indigenous Baka people in the Messok Dja area. The eco-guards are employed by the Government of the Republic of Congo’s MEFDDE (UNDP’s implementing partner). The Social and Environmental Screening Procedure (SESP) failed to identify critical project risks; as a result, Social and Environmental Standards (SES) were not implemented. No evidence that a due diligence review had taken place of partnerships with the private sector. UNDP’s Policy on Due Diligence and Partnerships with the Private Sector identifies industrial logging and palm oil as high-risk sectors requiring a due diligence review)

Management action: The project was suspended on March 11, 2019. The UNDP Administrator took his Decision in November 2020 in response to the SECU report available here. As described in more detail in the Decision, in follow-up to the SECU Report and other considerations, including the exceptional circumstances relating to the COVID-19 pandemic, the UNDP Administrator decided to close the project and consider options for a new phase of work to support community-based conservation and livelihoods with indigenous peoples. In April 2021, the UNDP Administrator responded to SI’s request for an update on progress. The project was financially closed in January 2023 and the remaining project funds returned to the GEF.

Status: Case completed.

Project: “Integrated and Transboundary Conservation of Biodiversity in the Basins of the Republic of Cameroon”. (GEF Grant USD 147,000). Link to Project Document)

Agency: UNDP

Date complaint submitted by stakeholder: August 2, 2018

Allegations: Survival International, a UK-based NGO, filed a complaint with the Social and Environmental Compliance Unit (SECU) of UNDP and asserted that TRIDOM II will support the continued eviction and displacement of Baka and Bantu communities – eviction and displacement that began, they state, when the Nki National Park (herein Nki) was created in 2005, and that continued through TRIDOM I. Because the Baka rely mostly on traditional hunting and gathering activities for their livelihoods and wellbeing, their exclusion from the area is deeply affecting their way of life and survival.

Eviction and displacement have occurred (and are occurring), they assert, through measures that function to restrict community access to areas – including areas both within and adjacent to Nki - and to natural resources traditionally accessed by these communities within these areas. The complaint indicates that one such key measure is the use of wildlife guards who are preventing community members from pursuing their traditional hunting and resource gathering within these areas. This and similar measures, they argue, fail to recognize the communities’ rights to access these areas and resources. The complaint implies that TRIDOM II will be advancing the same measures, with the same results for communities. Further details are available on the SECU registry.

Date case was put under formal review: October 24, 2018

Investigation Findings: The SECU report was completed in August 2020 (final SECU report). It found that UNDP did not screen project activities in TRIDOM II in a manner consistent with SES requirements. As indicated in the SECU report, the project did not accurately identify all communities that might be impacted, and how they might be impacted. Experts documented that hunter-gatherer communities, including those with villages in Zoulabot Ancien, have:

• traditionally relied on access to Nki, a protected area determined to be part of the scope of the project, for natural resources;

(ii) been significantly adversely impacted by access restrictions advanced by national law and policy; and

(iii) have been subjected to violence as a means of enforcing such restrictions. 

UNDP Cameroon confirmed that eco-guards can be a source of problems, and some use their power to intimidate communities, but measures were taken to reverse the situation. The project document did not include (or reference) a required ‘management plan’ to address risks for indigenous peoples identified during the screening and assessment process. 

The SECU report noted that while an MOU related to the project acknowledged the need to respect the rights of the Baka and the importance of Baka access to resources, it does not include a description of these rights or areas to which communities have access. The MOU indicated that such details would be included in an action plan, but this had not yet been developed – and the MOU did not clearly have the consent of all parties. The project document did not describe a project-level grievance mechanism that meets SES policy requirements. In September 2022, SECU released an Interim Monitoring Report and SECU will continue to monitor.

Management actions: The project was suspended on March 26, 2019. UNDP responded to GEF Council member comments to the draft SECU report in June 2020. UNDP Administrator took his Decision in February 2021 in response to the SECU Report. The Decision is available here. Reformulation of the project continues.

Status: SECU case on-going

Project: “Ridge to Reef: Integrated Protected Area Land and Seascape Management in Tanintharyi” (GEF Grant USD 5,250,000) (project document)

Agency: UNDP

Date complaint submitted by stakeholder: September 20, 2018

Allegations: The civil society organization ‘Conservation Alliance Tanawthari

(CAT) filed the complaint on behalf of indigenous communities in the Tanintharyi Region of

Myanmar. The complaint advances several claims, including the following:

(1) In the development and inception phases of the project, UNDP is violating complainants’ right to free,prior, informed consent (FPIC);

(2) the project violates the rights of Internally Displaced Persons (IDPs) and refugees to return to areas from which they were displaced by armed conflict;

(3) the project threatens to contravene the ‘interim arrangements’ of the National Ceasefire Accords agreed by the Government of Myanmar and Ethnic Armed Organizations;

(4) the project violates the UN Declaration on the Rights of Indigenous Peoples (herein ‘UNDRIP’) and the land and resource rights of the indigenous Karen Communities in the Tanintharyi Region of Myanmar; and

(5) the project fails to recognize and support indigenous community-driven initiatives to protect indigenous territories, strengthen local institutions and practices, and protect forests and resources in the project area. Further details are available on SECU registry.

Date case put under formal review: September 26, 2018

Update reported to Council: November 10, 2021; March 27, 2020

Investigation Findings: Ongoing. Second field mission due to be undertaken end February

2020 was postponed due to coronavirus travel restrictions. As a result of the COVID-19 pandemic and its inability to conduct its second field mission in 2020, SECU modified its approach to split the case into two stages and a two-part report; stage one was to focus on the geography the SECU team visited during its first field mission. Stage two was to focus on the geography to be visited during a second field mission. The stage one draft report’s release for public comment was delayed due to the violence and political situation in Myanmar that emerged in February 2021. SECU continues to monitor the situation in Myanmar to determine when it could proceed with a public comment process on the stage one draft report, and when it could return for its second field mission to complete stage two. 

Management Action: Project was suspended on December 26, 2018 and is in the process of being cancelled. In light of this project cancellation, SECU is determining appropriate next steps to finalize its case in a manner that will be useful in the circumstances, particularly with regard to identifying lessons for the future.

Status: SECU case on-going; Project suspended.

Project: “Finance and Technology Transfer Centre for Climate Change (FINTECC)” (GEF Grant USD7,000,00).

Agency: EBRD

Date complaint submitted by stakeholder: The complaint was received by the EBRD’s Project Complaint Mechanism (PCM) on June 5, 2018 and it was registered and published on the PCM Register on June 21, 2018 in English and Ukrainian.

Allegations: The Complainants (community members from Olyanytsya, Zaozerne, and Kleban villages in Vinnitsa Region of Ukraine with the help of CEE Bankwatch, Accountability Counsel, and Eco Action) raised environmental and social concerns as well as concerns about limited access to information in relation to the operations of MHP and the EBRD investments. The Complainants requested a Problem-solving Initiative be undertaken by the PCM and if not successful, a Compliance Review. A similar Complaint was also submitted to the International Finance Corporation’s Compliance Advisor Ombudsman (CAO). In order to avoid duplication of efforts, the Parties agreed for a co-facilitated process by PCM and CAO (the facilitation team). 

Date case put under formal review: The case was registered on 21 June 2018 as Complaint 2018/09, according to the PCM Rules of Procedure (para 11-13).

Update reported to Council: January 9, 2024; March 20, 2020

Investigation Findings: In June 29, 2018, a PCM Expert was appointed to conduct the Eligibility Assessment jointly with the PCM Officer. The Eligibility Assessment Report was completed and shared with all parties on September 25, 2018, and disclosed on the PCM Registry. The Complainants and MHP (the Parties) agreed to discuss the issues raised in the complaint through a voluntary and constructive mediation process facilitated by the PCM jointly with the CAO. On October 1, 2018, the EBRD President's Decision to accept the recommendation to start the Problem-solving Initiative was publicly released and posted. The Problem-Solving process was conducted until August 2021. Overall, the Parties held 23 joint meetings with the support of the facilitation team, who also organized several bilateral meetings over the course of three years.

Management Action: In August 2021 it became evident that the Problem-Solving Initiative could not assist further in the trust building, so they informed the facilitation team of their decision to withdraw from the initiative as they considered that no further progress could be made within that dialogue space. As a result, the process was terminated as per Paragraph 2.4 c) ii of the Project Accountability Policy^[1]. IPAM has prepared a Problem-Solving Report in consultation with the Parties which provides a high-level summary of the process as the Parties had requested for the process and its outcomes to be confidential. In October 2022, the Case was found eligible for Compliance Review and IPAM issued the Compliance Assessment Report. The Compliance Review process for the Case has been ongoing since October 2022, and IPAM is currently at the stage of preparing the consultative draft of their Report for the Parties of the Case. Additional information can be found in the Web Case Summary in the IPAM Registry here.

Status: Investigation complete – case closed.

Project: “Sustainable Land Management for Increased Productivity in Armenia (SLMIP)”

(GEF Grant USD 3,937,500) (IFAD notes that the allegations in this grievance case are not related to the GEF funded components of the project).

Date complaint received: The complaint was received by IFAD on September 3, 2018. On January 17, 2019, IFAD began a process to determine whether the allegation was eligible for consideration.

Allegations: The complaint was made by an NGO in Armenia, on behalf of a village. The allegations are related to the investment component 2 (Rural Areas Water Infrastructure) of the project, funded by another IFI as co-financier with the Government of Armenia. The complaint is related to water infrastructure investments in a village which, the claim states, is contributing to water scarcity for a community in a neighboring village.

Date case put under formal review: Although this complaint was not related to activities financed by IFAD, at the request of the co-financier, a fact-finding mission was undertaken between June 16-29, 2019 under IFAD’s Social Environmental and Climate Assessment Procedures and based on IFAD’s Complaints Procedure. Following that mission, IFAD invited the Government of Armenia and the co-financier to verify further the facts and, as appropriate, to identify potential actions to address the issue, as in our view the complaint warrants further detailed investigation.

Investigation findings: Subsequently, an investigation was carried out by the Republic of Armenia Human Rights Defender Office. This investigation followed the earlier fact-finding mission under IFAD’s Social, Environmental and Climate Assessment Procedures. The investigation concluded that proper procedures and permitting had been followed, and there was no evidence of any social or environmental effects due to the water supply investments of the project. The Office terminated its consideration of the complaint on May 11, 2020 and communicated its decision to the complainants.

Management actions: No suspensions or other significant management actions have been undertaken and are not deemed necessary at this time. 

Status: Case completed.

Project: “Mainstreaming Biodiversity into the Management of the Coastal Zone in the Republic of Mauritius” (GEF Grant USD 4,664,521). (project document)

Agency: UNDP

Date complaint submitted by stakeholder: 23 March 2019

Allegations: The complaint was filed by Aret Kokin Nu Laplaz (AKNL), an NGO coalition located in Mauritius asserting that UNDP's work in the country to protect Environmentally Sensitive Areas is tantamount to “greenwashing” in light of the permits being issued by the government for construction projects along the country's coast. According to the complaint, the GEF and UNDP were grossly negligent in continuously channeling funding to the government despite “...a number of critical GEF-funded projects ending up in Government drawers, or coffers rather, with very little effective results.” The complaint further alleges that in 2007- 2009 GEF and UNDP funded a complete inventory of all ESAs, as well as the drafting of an Act that would have ensured solid legal protection for all ESA, but the draft ESA Act was never presented to Parliament, nor was the national ESA inventory made public. According to the complaint, ten years down the road, “the results are catastrophic: the ESA protection system, which was to be fully integrated in the procedures for development clearances, has become purely cosmetic as development licenses and permits are issued with scant regard for ESAs.

Date case put under formal review (SECU): June 7, 2019

Investigation Findings:  

1. Limited Progress on ESA Legislation: Despite recognition and advocacy efforts, there was minimal advancement in adopting legislation (by the Government of Mauritius) to protect Environmentally Sensitive Areas (ESAs), particularly wetlands.
2. Risk Framework Reevaluation: The UNDP Chief Technical Advisor (for the project) amended the project risk log as per the Management Action Plan, validated during a Project Steering Committee (PSC) meeting. However, the UNDP CO reported a moderate to high risk level for all biodiversity projects managed by the CO (due to context in Mauritius).
3. Decline in NGO Engagement: Despite commitments to strengthen stakeholder engagement, communication, and outreach, engagement with NGOs decreased following the SECU report and Administrator's decision, except for the Relaunch Workshop in March 2022.
4. Challenges in Implementation and Oversight: Efforts to ensure effective implementation and oversight towards project completion faced setbacks. Key elements, including the recruitment of a Social and Environmental Safeguards specialist, were not realized, contributing to a moderate unlikelihood of sustainability and several unsatisfactory evaluations in the project's Final Evaluation. SECU issued its Final Compliance Report in October 2020. The Administrator issued his decision in March 2021. SECU monitored the decision and commitments made by the institution until April 2024, when the case was formally closed, and a Closure Note was issued. Further details are available via this link SECU case registry.

Management Action: The project has been financially closed and reported to Donors in August 2024. The TE and the SECU case provide vital learning and are informing on-going and future UNDP programming in Mauritius.

Status: Investigation complete – case closed. As the project is closed and reported to donor, and key project personnel are no longer available, SECU assessed that further progress was unlikely and closed the case.

Date of case closure: April 11, 2024

Project: “Integrated Natural Resources and Environmental Management Sector Project (INREMP) in the Philippines” (GEF Grant USD 2,500,000)

Agency: Asian Development Bank (ADB)

Date complaint received: In June 2019 a petition from local community members was submitted to the Provincial Environmental and Natural Resources Office (PENRO) to immediately stop the on-going implementation of Reforestation and Agro projects under the INREMP under BAAGMADOLI WMU awarded to Dagupan Women’s Organization. 

Investigation Findings: A series of consultations was facilitated by the Department of Environment and Natural Resources (DENR) and Local Government Unit (LGU) to address and settle the issues. These included the standing and role of clan owner of the land, possible relocation of already implemented subprojects, and the purpose and intention of the conducted survey and mapping.

DENR Staff and Project Officers (POs) agreed to raise the issue to the Watershed Management Council. Based on the consultative stakeholder process, the issue was resolved in July 2020 by relocating the Reforestation and Agroforestry site to another area within the same municipality. The project areas of INREMP are mostly within ancestral domains of various tribes especially in the Chico River Basin (project site), where traditional and cultural practices still exist.

Conflict resolution of the grievance response mechanism is mainly being done using these traditional practices wherein the Council of Elders are the jury and judge in any disputes or conflicts and even crimes and domestic issues. In areas outside ancestral domains, the Barangay is the local government unit, in-charge or handling conflicts and grievances. For the project-related case, conflicts are being handled at the Council of Elders and Barangay Levels with the participation of other government agencies as needed.

Management Action: No complaints were brought to the attention of ADB’s Accountability Mechanism as these were all resolved through the project’s own grievances redress mechanism. All grievances filed were reported and monitored through the project’s Social and Environmental monitoring reports. ADB’s grievance mechanism was publicly disclosed to all project beneficiaries. 

Status: Case completed.

Project: “Zambia Lake Tanganyika Basin Sustainable Development Project” (GEF Grant USD 7,334,247)

Agency: AfDB

Date complaint submitted by stakeholder: June 16, 2020

Allegations: This case involves a land dispute raised by the Royal Lungu Chiefdom in Mpulungu District (Zambia) regarding the siting and construction of a Jetty, Landing Site and Fish Market in the same district. These are activities in project components financed through the AfDB loan (not GEF grant). As noted above, the claim is that the site involved is used for traditional rites and as such has to remain as open land.

Date case put under formal review: July 23, 2020

Update reported to Council: November 10, 2021; October 28, 2020

Investigation Findings: Based on the supervision mission findings, a management letter informed the Ministry of Water Development, Sanitation and Environmental Protection (Executing Agency) that civil works on the affected sites have been suspended. The same letter stressed that AfDB may suspend disbursement to the whole project if all environmental and social non compliances are not satisfactorily addressed before the end of the year 2020. Finally, AfDB management would lift the suspension when the Ministry of Water Development, Sanitation and Environmental Protection would take the necessary actions (alternative appropriate ceremony sites are allocated by the Government and accepted by the affected people) to resolve the case.

Project: “Tonga Outer Island Renewable Energy Project” (GEF Grant USD 2,639,269)

Agency: ADB

Date complaint received: During training sessions in May 2020.

Allegations: During training sessions in May 2020, members of four local communities complained at the project level, that they were not consulted properly with the idea of removing the old generators from the powerhouse and putting the new OIREP generator inside. These still-working generators were brought by the community themselves with their own hard-earned money and they did not want to see all their efforts go to waste. It has been requested by all communities if the project could help out and build a new small shed to shelter their old generators so when they switch from the old system to the new system built by OIREP, they still have these generators for back up and stand by.

Investigation Findings: The complaints have been reported to the Project Steering Committee, which has requested funding from ADB to resolve the issues. The Ministry of Meteorology, Energy, Information, Disaster Management, Environment, Climate Change and Communications (MEIDECC) has housed the old gen-sets in temporary shelters, while more permanent measures are being considered, in consultation with communities, through the project. The situation is now resolved as of end 2020.

Management Action: For this case, no complaints were brought to the attention of ADB’s Accountability Mechanism as these were all resolved through the project’s own grievances redress mechanism. All grievances filed were reported and monitored through the project’s Social and Environmental monitoring reports. ADB’s grievance mechanism was publicly disclosed to all project beneficiaries.

Status: Case completed.

Project: “Tuvalu - Outer Island Maritime Infrastructure Project” (GEF Grant USD 500,000)

Agency: ADB

Date complaint received: October 2020 - issues and concerns raised during visit of project grievance response mechanism.

Allegations: Local community raised concerns about the strength and resilience of a “flex mat” being put on the beach to prevent erosion (see photo below); they raised doubts as to whether it could serve its purpose in times of strong winds based on their past experience, and questions as to why it was not laid in a concrete foundation. 

Management Action: A discussion was held between the community and Project Management Unit. The Safeguards officer explained that the mat is designed to flex with the beach, thus not laid in the cement foundation, and the issue was resolved. The issue was resolved. Since this is a pilot site this is continued to be monitored. The matter was resolved through the project-level grievance mechanism (no claim was filed with the ADB mechanism).

Status: Case completed.

Project: “West Africa Coastal Areas Resilience Investment Project” (GEF Grant USD 20,247,607). (https://projects.worldbank.org/en/projects-operations/project-detail/P162337?lang=en; https://projects.worldbank.org/en/projects-operations/project-detail/P176313?lang=en)

Agency: World Bank (WB)

Date complaint submitted by stakeholder: August 4, 2021

Allegations: WB inspection panel alleges that the project will adversely impact the fishermen, residents and property owners along the Togolese coast. the Project’s insufficient understanding of artisanal fishing, its value chain and its specificities in particular beach seine fishing and the different demographics reliant on it, meant that the Project could not identify the full nature of the impact, and therefore did not have appropriate mitigation measures to address these impacts on the different groups.

Date case put under formal review: September 7, 2021

Investigation Findings: The Panel found that the Project did take steps to minimize resettlement by reducing its footprint. However, it also found that Management did not ensure that the Project had in place sufficient support to assist Project Affected Persons to improve their livelihoods and standards of living or at least restore them. More information can be found in:

1. First Inspection Panel Report and Recommendation: (https://www.inspectionpanel.org/sites/default/files/cases/documents/153-Non-Technical%20Summary-21%20March%202024_0.pdf) https://www.inspectionpanel.org/sites/default/files/cases/documents/153-Inspection%20Panel%20Report%20and%20Recommendation-8-Nov-2021.pdf
2. Second Inspection Panel Report and Recommendation: https://www.inspectionpanel.org/sites/default/files/cases/documents/153-Inspection%20Panel%20Report%20and%20Recommendation-8-Jun-2022.pdf
3. Inspection Panel Investigation Report: https://www.inspectionpanel.org/sites/default/files/cases/documents/153-Inspection%20Panel%20Investigation%20Report-%2020%20April%202023.pdf
4. Bank Management Report and Response: https://www.inspectionpanel.org/sites/default/files/cases/documents/153-Management%20Report%20and%20Recommendations-2%20June%202023.pdf
5. Press Release: https://www.inspectionpanel.org/panel-cases/west-africa-coastal-areas-resilience-investment-project-p162337-additional-financing
6. Non-Technical Summary of the Panel investigation: https://www.inspectionpanel.org/sites/default/files/cases/documents/153-Non-Technical%20Summary-21%20March%202024_0.pdf

Management Action: Management indicated that it agreed with the Government of Togo and consulted with the affected communities on an Action Plan. The Action Plan details how the Bank will work together with the Government of Togo and the communities to address the Panel’s findings. The Government of Togo has confirmed its commitment to implement the Action Plan while the World Bank will support and monitor its implementation. Management committed to submit annual progress reports on the implementation of the Action Plan. On September 15, 2023, the World Bank Board of Executive Directors discussed the Inspection Panel’s Investigation Report. The Board also approved Bank Management’s action plan to address the Panel’s Investigation Report findings.

Status: Investigation complete – case closed.

Date of case closure: October 7, 2024.

Management Action - Remedies: Please refer to the Proposed Management Action Plan (pages 34-36) in the Bank Management Report and Recommendation: https://www.inspectionpanel.org/sites/default/files/cases/documents/153-Management%20Report%20and%20Recommendations-2%20June%202023.pdf

Project: The complaint was triggered by the communities’ belief that a UNDP supported project known as The Private Sector and Agenda 2030, which is not funded by GEF, conflicts with another project known as the Sustainable Amazon for Peace Project (GEF ID 9663), which is funded by GEF.

Date complaint received: May 11, 2021

Summary of allegations:  A key concern of the communities is that UNDP’s support for the Private Sector and Agenda 2030 non-GEF project will be harmful and not consistent with the needs of the Sustainable Amazon for Peace Project funded by GEF, and through which communities would be providing sensitive information.  The complaint further alleges that the Private Sector non-GEF project poses threats to the rights of communities, compromises the trust communities had in UNDP Colombia, and otherwise violates UNDP’s social and environmental standards. UNDP reports that the Siona communities were beneficiaries of the GEF-funded Sustainable Amazon for Peace Project and have since declined to participate further in this project.   

Date case put under formal review; Status:  September 7, 2021.  As indicated in SECU’s eligibility report (eligible), the complaint is eligible for a social and environmental compliance review.  SECU has opened an investigation into the non-GEF Private Sector Project, which “will focus on how the two projects intersect, identify possible non-compliance with SES, and recommend a way forward as a means of rebuilding trust with indigenous communities in the Putumayo Department of Colombia.”

Project: “BIO Clima: Integrated climate action to reduce deforestation and strengthen resilience in BOSAWÁS and Rio San Juan Biospheres, funded by the Green Climate Fund (GCF) and co-financed by GEF through FAO” (GEF Grant USD13,031,427). Nicaragua Mesoamerica Forest IP Project: Protection and conservation of forests of global importance located in the BOSAWAS Biosphere Reserve and the Indio Maíz Biological Reserve | GEF

Agency: FAO

Date complaint submitted by stakeholder: June 30, 2021 - submitted to Independent Redress Mechanism (IRM) of the GCF (no complaint has been received by FAO).

Allegations: the complaint is by an afro descendent indigenous community located in the BOSAWÁS Biosphere Reserve in Nicaragua. The complaint welcomes the project objectives but alleges that it will harm the communities because prior to approval there were no proper consultations with communities including no Free Prior Informed Consent (FPIC). It also expresses a fear that the project will repeat history, including leading to environmental degradation and attacks by non-indigenous settlers against indigenous communities, resulting in the continuing usurpation of traditional and ancestral lands.

Date case put under formal review: Under the procedures of the GCF IRM, the complaint has been declared eligible for further processing on July 21, 2021. The Eligibility report can be found here and the project proposal presented to the GFC Board can be found here.

Update reported to Council: December 2021

Investigation Findings:

(a)The IRM finds that there are ongoing recurrent violent conflicts of a serious nature in the project areas, especially in the north. The IRM also found the human rights situation relating to indigenous people in the project areas problematic in certain respects detailed in the report, and that this situation will likely impact the implementation of the project, particularly when conducting informed consultation and participation, and FPIC of indigenous communities. The IRM finds that due diligence under the GCF’s safeguards required proper data gathering and assessment through a conflict sensitivity analysis report and a human rights due diligence report. These reports ought to have been prepared during the design phase of the project but have instead been postponed and will be carried out at a later stage when sub-projects are developed under the project. The IRM finds that this constitutes non-compliance with GCF safeguard policies and procedures and that it may adversely impact the complainant(s) and other indigenous communities in the project areas.

(b) The IRM finds that the GCF’s safeguard provisions on informed consultation and participation (ICP) required in every GCF project have not been complied with in the Bio-CLIMA project. ICP involving indigenous people is often the beginning of the process leading to FPIC. In the Bio-CLIMA project, key aspects about the project, especially dealing with peaceful co-habitation regime agreements (PCRAs) should have been adequately disclosed and consulted with indigenous communities. The GCF’s guidelines under the Indigenous Peoples Policy requires a “framework agreement” to be developed as part of such consultations setting out how, when and where FPIC will be conducted and the disclosure of key elements of the project. There is no evidence of such a framework being discussed as part of project disclosures and consultations with indigenous peoples. While the Bio-CLIMA project promises FPIC will be conducted at the sub-project level, the mandatory informed consultation and participation (ICP) process required under GCF safeguards prior to this project being presented to the Board for approval has not been conducted as expected. The IRM finds this to be non-compliance and one that has and will adversely impact the complainant(s) and other indigenous communities in the project areas.

In light of these findings, the IRM recommends the following actions to bring the project back into compliance with GCF policies and procedures:

(1) prepare a conflict sensitivity analysis at the project framework level as set out in paragraph 186 of this report;

(2) prepare a human rights due diligence report as set out in paragraph 187 of this report;

(3) carry out a meaningful informed consultation and participation (ICP) process with indigenous communities in the project areas as set out in paragraphs 180 and 188-89 of this report;

(4) modify the Board’s conditions so that the GCF Secretariat holds approving authority for the selection of the third-party monitor; and

(5) request the GCF Secretariat to prepare a remedial action plan. These recommendations are set out in more detail in Section VIII of this report. The IRM has also made recommendations based on lessons learned from this case with regard to the need for policy guidance from the Board on developing projects/programmes in conflict and post conflict areas and fragile states (paragraph 194 of this report) and regarding the Sustainability Unit of the Secretariat. Additional information on the investigation, findings and outcomes of the GCF IRM relating to this case is here.

Management Action: Not applicable as FAO has not received nor processed the grievance. FAO and GEF SEC has closely monitored outcomes of GCF grievance redress

Status: Investigation complete – case closed

Date of case closure: refer to GCF IRM

Project: “Lakes Edward and Albert Integrated Fisheries and Water Resources Management Project (LEAF II)” (GEF Grant USD 4,510,000). (ID5674...Multinational_-_Lakes_Edward__Albert_Integrated_Fisheries__Water_Resourc___.pdf)

Agency: AfDB

Date complaint submitted by stakeholder: September 13, 2021

Allegations (Safeguards related): Alleged accusations of human rights violations of the indigenous peoples impacted by the project. Lack of stakeholder consultations, gender inequalities and undue force and violence to monitor and enforce the project, causing harm upon the surrounding communities during project implementation. Non-compliance of several Safeguards.

Date case put under formal review: November 17, 2021

Update reported to Council: May 29, 2024; December 20, 2023; October 26, 2022

Investigation Findings: The IRM investigation has been completed and the Compliance Review Report (approved by the Board of Directors on March 27, 2024) is linked here: https://irm.afdb.org/sites/default/files/project-file/EN_LEAF%20II%20Project%20-%20Compliance%20Review%20Report%20Final%20no%20annexes.pdf. The findings of the investigation include the following:

1. Meaningful Consultation and Stakeholder Engagement. IRM finds the Bank in non-compliance with AfDB’s OS1, OS2, and the DAI Policy as the Bank did not ensure that the minimum requirements related to consultations and stakeholder engagements were implemented and the relevant E&S information disclosed.
2. Assessment of Impacts on the Livelihoods of Fisherfolk and Mitigation Measures. The Bank did not comply with OS1 because it did not ensure that the Project had an adequate assessment of the impacts on the [Project Affected Persons] PAPs’ livelihoods, as the project’s environmental and social documents did not sufficiently: reflect the number of people affected; identify the type of impacts; design a dedicated budget for mitigation measures or livelihood alternatives; and determine specific prevention and/or mitigation measures designed in consultation with the beneficiaries and implemented. Particularly, the Bank did not ensure that the Project had a baseline study to assess the current socio-economic status of the fishing villages covered by the LEAF Project, nor was this included as one of the socioeconomic requirements of the Project. AfDB prepared and implemented LEAF II without a final ESMP and/or RAP containing mitigation measures to address the economic displacement resulting from the LEAF II-supported enforcement of fishing restrictions. AfDB failed to ensure that the economic displacement was assessed, mitigated, and addressed in sufficient detail. AfDB also failed to identify during supervision that the livelihood impacts of the reported confiscation and destruction of productive assets were adequately addressed. AfDB also failed to identify that the grievance management system was not functioning as it should.
3. Consideration of Gender Aspects within the Project. The Bank did not ensure that the ESMP adequately identified and assessed the gender-specific risks and potential negative impacts to women, including threats of SEAH/GBV related to the enforcement of the new fisheries regulations. The Bank did not identify that the Project lacked environmental and social management plans addressing the risks and impacts of the Project on women and determining measures to address them, particularly regarding their access to livelihoods. On the contrary, the Project focused on positive impacts on women. This also lead to a poor supervision on gender aspects, which included the absence, on the side of the Bank, of implementing specific actions and the inclusion of relevant gender expertise to identify whether the Project was generating any impacts on women during the implementation stages of the Project. The Bank also did not identify that:
4. a) the Project did not deliver on AfDB’s and LEAF II’s women empowerment objectives;
5. b) women benefited less from the Project; and
6. c) female fishmongers often faced the expropriation of their fish stock without due process and/or compensation. Additionally, the IRM finds that there is sufficient evidence to conclude that sexual harassment and exploitation committed by personnel related to the Project occurred. Sexual exploitation was frequently related to enforcement activities. Yet the Bank did not ensure that the Project have an expert on the GBV/SEAH, and a GRM appropriate to receive and handle survivors’/whistleblowers’ complaints. Additionally, the Bank did not include any GBV-/SEAH-related supervision activities, nor did it include any expert in this field in the Bank’s supervision team. Therefore, IRM finds the Bank in non-compliance with OS1 and OS2 on identifying and assessing the environmental and social impacts and risks related to gender and vulnerability.

Use of Excessive Force and Risks of Retaliation Against Those Who Raise Concerns. The Bank failed to ensure that the Project identify and assess the risks and potential impacts of UPDFFPU using AfDB-funded boats and operational funds to conduct law enforcement and/or to satisfy itself that the SOP has been used at all times and that the affected people were provided with access to grievance redress. The Bank also failed to effectively supervise and ensure an adequate reporting system was in place as a way to determine whether the Project was generating serious risks to the personal integrity, security, and lives of the PAPs throughout the implementation of the Project. Additionally, during the completion phase of the Project, the Bank did not assess the social sustainability of the project results; thus, the Bank is found in non-compliance with OS1. IRM also finds that the Project was implemented in contravention of OS1’s requirements related to grievance management as the PAPs by the actions of the UPDF-FPU were unable to register their grievances and/or obtain review and redress; they were also exposed and made to face retaliation and/or threats of retaliation by doing so. 

Management Action: The final Management Action Plan in response to the investigation findings, approved by the Board of Directors of the AfDB on May 14, 2024, is attached and linked here: https://irm.afdb.org/sites/default/files/project-file/Final%20approved%20-%20Management%20Response%20-%20IRM%20Compliance%20Review%20Report%20-%20LEAF%20II%20Project%20002.pdf. It includes the Management Response and Action Record to each of the IRM Issues, as it refers to the IRM investigation report, as set out in detail in the attached.

Status: On-going. See above.

Project: “Strengthening Resilience of Water Supply in Honiara” (GEF Grant USD 4,587,156).

Agency: ADB

Date complaint submitted by stakeholder: July 2022 – March 2023

Allegations:

1. The first was raised during vegetation clearance for the Kongulai WTP. Some of the trees that were felled at the western end of the construction site, landed over the boundary and damaged seven betel nut trees belonging to 2 community members. This required the contractor to compensate the owners based on rates that SW provided to REAN, who met with the owners. They accepted the payment and considered the issue resolved. This event which took place on 3rd March 2023 was witnessed by other residents and customary owners of Kongulai.
2. The second was received by Pacific Engineering Projects Limited (PEP), a contractor, and was resolved immediately. The grievance was raised by a shop owner regarding a boundary location. The Ministry of Infrastructure and Development (MID) was able to clarify to the shop owner that the area in question is within the road reserve and therefore, gave the clearance for the pipeline route to be installed in that location. The shop owner was also happy with the explanation. This grievance is under the baseline UWSSSP project but is not financed by GEF/LCDF.

Date case put under formal review: No formal complaint filed to ADB; it went through the Project Implementation Unit’s Grievance Redress Monitoring (GRM)[1] process.

Update reported to Council: January 9, 2024

Investigation Findings: The Ministry of Infrastructure and Development (MID) advised that the area in question is within the road reserve and was therefore justified in granting clearance for the location to be used for the pipeline installation.

Management Action: no formal investigation was required; it was resolved through coordination with the MPA stakeholders through the Grievance Redress Monitoring process

Status: Investigation complete – case closed

Date of case closure: March 2, 2023

[1] The GRM is a three-stage process which allows for appeals at each stage: complaints are forwarded to the Project Manager who tries to solve the complaint. If a solution cannot be reached the complaint is referred upwards first to the Chief Executive Officer of SW and then, if no resolution is found, to a Grievance Tribunal of three people: (i) a member of the Board of SW; (ii) the Permanent Secretary (or designate) of the Ministry of Mines, Energy and Rural Electrification; (iii) an independent member jointly selected by Chief Executive Officer of SW and Board Chairman. Within five working days of the Tribunal meeting a formal response is issued to the aggrieved party outlining the Tribunal’s decision on the grievance.

(SW- Solomon Islands Water Authority trading as Solomon Water)

Project: “CTI: Coral Reef Rehabilitation and Management Program-Coral Triangle Initiative, Phase III (COREMAP-CTI III)” (GEF Grant USD 8,000,000).

Agency: ADB

Date complaint submitted by stakeholder: July 2022 – June 2023

Allegations: The complaints (9) are related to issues of small infrastructure development, hand-over of assets, permission to operate speedboat in an MPA which had not been released, and a permit for operational mooring buoy in Gili Balu.

Date case put under formal review: No formal complaint filed to ADB; it went through the Project Implementation Unit’s Grievance Redress Monitoring (GRM)[1]process

Update reported to Council: January 9, 2024

Investigation Findings: no formal investigation was required; it was resolved through coordination with the MPA stakeholders through the Grievance Redress Monitoring process

Management Action: They were all resolved by the sub-contractors, the Project Implementation Unit with coordination with the MPA stakeholders.

Status: Investigation complete – case closed

Date of case closure: 31 December 2022

[1] The complaint was recorded through the GRM form and hotline mechanism, it has been recorded to and resolved in accordance with the GRM procedures.

Project: “BIOREACH: Biodiversity Conservation and Agroecological Land Restoration in Productive Landscapes of Trinidad and Tobago” (GEF Grant USD 3,752,162). BIOREACH: Biodiversity Conservation and Agroecological Land Restoration in Productive Landscapes of Trinidad and Tobago | GEF

Agency: FAO

Date complaint submitted by stakeholder: February 15, 2023

Allegations: In February 2023, the project received a complaint from Tableland Pineapple Farmers Association (TFPA), about the non-inclusion at a Farmer’s Sub-Committee Meeting and reports of environmental damage observed at the Victoria Forest Reserve

Update reported to Council: June 2023

Investigation Findings: BIOREACH informed via email on February 16, 2023, that the project has involved TPFA in workshops that supported the project’s formulation. With regards to the environmental damage report, the technical officer informed the complainant that the project cannot enforce against or investigate any possible breaches. 

Management Action: Resolution letter February 28, 2023 - TPFA was assured that they would be included and consulted in future meetings, especially when activities focused on farmer training and development, exploring the development of a green value chain and agrotourism opportunities for Pineapple farmers. The matter was resolved by the parties. Regarding the second complaint, the PMU notifies the responsible agencies in writing and report TFPA when the letters are sent.

Status: case closed, March 2023

Project: “Integrated Transboundary Ridges-to-Reef Management of the Mesoamerican Reef (MAR2R)” (GEF Grant USD 9,018,349). (See GEF project page and WWF GEF project page for endorsed project description)

Agency: WWF-US

Date complaint submitted by stakeholder: April 2023

Allegations: Among all the sub-projects within the MAR2R, the "Comprehensive Water Resource Management with an R2R Approach in the Tulum Watershed" sub-project in Mexico received a grievance. A beneficiary raised a complaint because the composting latrine, which was part of the pilot project, had not been fully completed, with pending issues related to the door and paint. The grievance was submitted in writing and placed in a community complaint box.

Date case put under formal review: May 11, 2023

Update reported to Council: January 10, 2024

Investigation Findings: Centinelas del Agua A.C. (local NGO leading execution of the subproject in Mexico) and the PMU (Project Management Unit) received and addressed the grievance. They resolved it by installing the missing door and making the necessary adjustments to ensure satisfactory delivery to the beneficiary. Although there was no damage to the community, the slow provision of the promised construction slowed their ability to have a benefit from the project. Thus, despite the minimal health, safety and security risks, the project still addressed the complaint.

Management Action: The grievance was left in box #004 in May: although it was dated April 25, it did not appear on the community box until May 11. It was retrieved by the safeguards staff on May 16, once they had secured the key to open the box. Upon deeming the grievance eligible, a field visit was conducted to the site in order to conduct a visual inspection. At that time, it was verified that the construction was 90% done and that an aluminum door had been installed. It was explained to the beneficiary that the delay in construction was because he had not been part of the first 15 beneficiaries selected. As such, the timeline for construction of his latrine was delayed from the original timeline. It was explained that his latrine was part of the second round of construction.

Status: Investigation complete – case closed, May 16, 2023.

Project: “Securing the Future of Peru's Natural Protected Areas (GEF6-PdP)” (GEF Grant USD 810,677). (See GEF project page and WWF GEF project page for endorsed project description) 

Agency: WWF-US

Date complaint submitted by stakeholder: December 21, 2022

Allegations: An operations staff in Reserva Comunal Machiguenga (RCM, by its acronym in Spanish) complained that Profonanpe (Fund for the Promotion of Peruvian Natural Protected Areas) had failed to make a payment of 960.00 soles that was pending since September 2021. At that time, the RCM and SERNANP (Peru’s National Service of Natural Protected Areas) staff sent official letters to Profonanpe attaching all the necessary documents for the Fund to make said payment to a provider of foodstuff that had been ordered for a demarcation activity. Upon further review, in January of 2022, the RCM team realized that Profonanpe had, in fact, paid that amount of 960.00 soles but to another provider. In December of 2022, the provider still had not been paid and communicated his unease to the operations staff filing this complaint.

Date case put under formal review: December 21, 2022

Update reported to Council: October 17, 2023

Investigation Findings: Upon further review, in January of 2022, the RCM team realized that Profonanpe had, in fact, paid that amount of 960.00 soles but to another provider. In December of 2022, the provider still had not been paid and communicated his unease to the operations staff filing this complaint.

Management Action: Payment was made to the correct vendor.

Status: This complaint was addressed within two days of its receipt and is now closed.

Date of case closure: December 23, 2022

Project: Strengthening capacity of institutions in The Gambia to meet transparency requirements of the Paris Agreement (GEF Grant USD 1,100,000)

Agency: Conservation International (CI)

Date complaint submitted by stakeholder: November 2022

Allegations: The Gambia Ministry of Environment, Climate Change and Natural Resources (“MECCNAR”) submitted a complaint to Conservation International’s Global Environment Facility Agency (the “CI-GEF Agency”). The complaint raised concerns about the procedural approach, project design transparency, and role and consultations between partners and stakeholders. After considering the complaint, Conservation International (CI)’s Global Grievance Committee (the “Grievance Committee”) concluded that the complaint was eligible for consideration by the Grievance Committee, as provided under its Accountability and Grievance Mechanism.

Date case put under formal review: n/a

Update reported to Council: August 14, 2023

Investigation findings: A series of consultations were facilitated by CI and MECCNAR to address and mutually resolve the concerns raised in an amicable and positive manner. These included measures and commitments to ensure the budget and activities outlined in the ProDoc will be revised in consultation with MECCNAR and that CI will seek written approval from MECCNAR before submission of the revised ProDoc, and that CI will ensure written approvals from its implementing partners before submission of final Project documentation.

Management Action: Based on these consultations and the related resolutions and commitments, MECCNAR positively received and confirmed its acceptance of the developed action plan in February 2023.

Status: Case completed.

Project: “Supporting the Implementation of Integrated Ecosystem Management Approach for Landscape Restoration and Biodiversity Conservation in Tanzania”. (GEF Grant USD 1,008,528)

Agency: UNEP

Date complaint received:  July 2023

Allegations:  UNEP was requested to undertake a Management Review of the project raised by US-based NGO regarding allegations of evictions, human rights abuses, and cattle seizure allegations occurring in specific areas in Tanzania.

Date case put under formal review: 8 August 2023. UNEP initiated a Management Review which concluded that the TRI Project in question is not implicated in the concerns. It confirmed that the project’s intervention followed the standard procedures and the operational policies. There was no evidence to suggest harm derived from the GEF financed activities, nor any geographical linkage to the allegations. Further, the NGO confirmed that the allegations raised were not exclusive to the GEF-financed project.

Investigation Findings:  UNEP initiated a management review encompassing a desk analysis of all pertinent project documentation, spatial analysis, a field visit by the Senior Safeguards Advisor, and a series of consultations with project teams and wider stakeholders including local/national authorities and community representatives.

Management actions: UNEP reports that the case is now closed, and the complainant and all stakeholders were informed of the outcome of the Review.

Status: Case completed.

Project: “Sustainable Landscapes in Chiapas and Oaxaca” (GEF Grant USD 7,219,450)

Agency: Conservation International

Date complaint submitted by stakeholder: June 6, 2024

Allegations: The implementation of safeguards, specifically Free, Prior and Informed Consent (FPIC), was deficient.

Date case put under formal review: July 1, 2024; responded to aggrieved party on June 7, 2024

Update reported to Council: Not yet

Investigation Findings: Aggrieved party did not respond to requests for additional information. Confirmation of safeguards implementation with the project team. Additional evidentiary confirmation will be obtained, whereafter the grievance will be closed.

Management actions: Case cannot be further processed due to insufficient information from the complainant.

Project: “Standards and Labels for Promoting Energy Efficiency in Russia”

(GEF Grant USD 7,810,000)

Agency: UNDP

Date complaint was received: May 10, 2017

Allegations: A special annex to the terminal evaluation report of this project alleged, inter alia, procurement fraud and embezzlement. There were also claims of retaliation against persons involved in project review and in reporting alleged misconduct.

Date case put under formal review: May 10, 2017

Investigation Findings: Investigation by UNDP Office of Audit and Investigation (OAI) is closed. OAI investigated the allegations and found the claims of procurement fraud and embezzlement could not be substantiated and closed the case in May 2018. However, OAI did detect a number of irregularities linked to conflicts of interest in the Project Steering Committee that did not amount to misconduct of UNDP staff but did need to be addressed in order for the same mistakes not be repeated in the future.

Management actions: At the request of several member states, UNDP initiated an external review to determine if UNDP’s management of the S&L project was appropriate and existing oversight and accountability policies effectively implemented. The results of the external review, the UNDP management response, and related documentation are here:

Final Draft Report

UNDP Cover Letter

UNDP Ethics Office Response

UNDP Management Response

UNDP Office of Audit and Investigations Response

Final Report

Note: UNDP also has initiated a broader system-wide audit of UNDP’s management of the GEF portfolio. The results of this audit, the UNDP management response, and related documentation are here:

Final Report

Action Plan and tracking of implementation of the Action Plan

Cover Letter

UNDP OAI undertook a follow up Audit of UNDP’s management of the GEF portfolio in April/May 2021. See final report. Additional information on allegations of retaliation available at UN Dispute Tribunal.

Status: Investigation Completed

Project: Strengthening climate services and early warning systems in the Gambia for climate resilient development and adaptation to climate change – 2nd Phase of the GOTG/GEF/UNEP LDCF NAPA Early Warning Project (GEF ID 5071), implemented by UNDP.

Date complaint received: February 15, 2018

Summary of allegations:  UNDP Resident Representative reported allegations of procurement fraud against former UNDP staff member

Date case put under formal review: February 16, 2018

Status and findings: OAI opened 14 investigation cases. 3 cases closed in May 2022 and 5 additional cases were closed between February and August 2023. Another 6 cases remain opened and investigations are on-going. Financial losses likely but total amount has not been finalized.

Management actions: Project closure expected in December 2022.

Project: “Market Transformation and Removal of Barriers for Effective Implementation of State Level CC Action Plans” (GEF Grant USD 3,744,438)

Agency: UNDP

Date complaint received: May 9, 2018

Summary of allegations: Procurement fraud

Date case put under formal review: May 22, 2018

Investigations Findings: OAI investigation closed on February 10, 2022. Case unsubstantiated.

Management actions: Project financially closed in Aug 2022. 

Status: Case completed.

Project: “Building adaptive capacity and resilience to climate change in Afghanistan” (LDCF Grant USD 5,390,000)

Agency: UNEP

Date complaint was received: See below.

Allegations (and nature of the claim): UNEP management identified irregularities in financial reporting, delayed submission, and issues relating to expenditure eligibility. This led to an internal audit, with concerns referred to the Office of Internal Oversight Services (OIOS).

Date case put under formal review: The OIOS audit was conducted between Nov 2018 and Feb 2019 with the final report released in May 2019.

Investigation Findings: Financial handling practices did not align with best practices, and there was a lack of clear records for expenditures tied to their respective projects.

Management actions: Management suspended all disbursements as an interim measure pending the OIOS internal audit. The audit and financial analysis determined that $323,920 were ineligible costs charged to the LDCF project, which were then retrieved. Management implemented restructuring measures to strengthen accountability mechanisms within the concerned Branch. The Country Program Manager for the Afghanistan Office was replaced. Following a Steering Committee Meeting to discuss these events, a decision was made to transfer the project execution to NEPA. However, the project was later cancelled due to the emerging challenging political situation. UNEP reports that the case was closed. 

Status: Case completed.

Project: “GEF Small Grants Programme in Mauritius” (Part of GEF SGP 7th Operational Phase – Core (Part 1) - GEF Grant USD 61,538,462) 

Agency: UNDP

Date complaint was received: March 31, 2019 

Allegations: The Environmental Protection and Conservation Organization (EPCO), a former SGP grantee in Mauritius, alleged improper grant management by the SGP National Coordinator, including termination of their grant, favoritism, and conflict of interest by a National Steering Committee member.

Date case was put under formal review: April 16, 2019 by UNOPS

Investigations Findings: The Internal Audit and Investigation Group (IAIG) of UNOPS found no evidence of fraud but that: (i) the NSC member had a conflict of interest or at least perception of such; (ii) several grantees used the technical assistance of an NGO owned by the NSC member, and his organization materially benefitted. The report recommended several steps to improve the implementation of the SGP Operational Guidelines and Standard Operation Practices.

Management actions: UNOPS worked with the SGP Country Programme Team to fully implement all recommendations of the Action Plan. Implementation was finalized and verified by the UNOPS Internal Audit and Investigation Group (IAIG) during the first quarter of 2021. The recommendations were linked to:

1) removal of an NSC member due to identified conflict of interest;

2) reinforcement of the practices and expectations related to the terms of reference (TOR) for National Steering Committee (NSC) members and ensure full compliance with the Conflict of Interest regulation/form; and

3) assessment of audited grants as to whether any funds should be recovered.

As such, the NSC member has been replaced and NSC member rotation duly documented and shared with IAIG. Furthermore, SGP Mauritius has reviewed the composition and tenure of all National Steering Committee members, and two members have ended their participation in NSC. SGP Mauritius has also adopted the new NSC meeting minutes template developed jointly by CPMT and UNOPS with a view to streamline information required from the NSC meetings and ensure that information recorded in NSC meeting minutes is improved in terms of quality, completeness, and in regard to conflict of interest. In early 2020, all members signed the conflict-of-interest statement at the NSC meeting. Beyond that, SGP staff in Mauritius completed a course on ethical conduct and related UNOPS training on ethics and integrity. One project was terminated, and funds recovered by SGP have been reallocated to COVID-19 response projects. The SGP Mauritius team also documented proof-of-completion of all projects. UNOPS reviewed and verified all relevant financial reports for these projects. 

Status of the case: Case completed.

Project:  “Transboundary Cooperation for Snow Leopard and Ecosystem Conservation” (GEF Grant USD 1,000,000) (project document)

Agency: UNDP

Date complaint submitted by stakeholder: July 10, 2019

Allegations: UNDP staff member reported allegations of procurement fraud.

Date case put under formal review: July 29, 2019

Update reported to Council: July 10, 2019

Investigation Findings: OAI investigation was closed on 22 October 2021. UNDP has reported a finding of financial loss of US$2,874.90.

Management Action: UNDP reimbursed the financial loss amount of $2,874.90 to the GEF Trustee on 20 May 2024 with payment reference no. 1449702, and informed GEF Secretariat on 21 May 2024. Project financially closed in January 2021 and reported to donor in May 2021.

Status: Investigation complete – case closed, October 14, 2021

Projects: (1) “Nationally Appropriate Mitigation Actions for Low-carbon Urban Development” (GEF Grant USD 1,000,000); and (2) “Promotion of energy efficient lighting in Kazakhstan” (GEF Grant USD 3,400,000)

Agency: UNDP

Allegations: Procurement fraud.

Date case put under formal review: October 9, 2019

Investigation Findings: OAI investigation closed on April 6, 2022. Case substantiated with no quantifiable financial loss identified.

Management actions: Project GEF ID 4166 financially closed in April 2018. Project GEF ID 5059 under implementation with enhanced oversight, and Terminal Evaluation planned for February 2024.

Status: Completed

Project: “Strengthening Management Effectiveness and Generating Multiples Environmental Benefits within and around Protected Areas in Zambia” (GEF Grant USD 13,148,864)

Agency: UNDP.

Date complaint received: November 6, 2019

Allegations: UNDP Resident Representative informed OAI regarding allegations relating to a legal case and dispute by vendor that UNDP has not honored a payment related to the supply of scout uniforms and equipment (patrol kits). Investigation indicates possible misappropriation by a former employee of the vendor.

Date case put under formal review: November 7, 2019

Investigation Findings:  OAI investigation closed on August 11, 2021. Financial loss of US$68,562.00 confirmed through investigation, from an apparent misappropriation of funds for patrol kits by a former employee of a vendor in the project.

Level of Financial Damage subject to the Complaint: n/a

Management actions: Project implementation completed, and the project financially closed in March 2021. UNDP reports that the offender is an external person not under the jurisdiction of OAI, and that OAI has recommended the case against this person be referred to national authorities. UNDP also reports that it is taking the necessary steps to reimburse the GEF TF for the loss, working with the Trustee.

Status: Case completed

Project: “Climate risk finance for sustainable and climate resilient rainfed farming and pastoral systems” (GEF Grant USD 5,700,000)

Agency: UNDP

Date complaint received: November 6, 2019

Allegations:  Related to procurement fraud

Investigation Findings: OAI has determined that the allegations made in relation to this project were unsubstantiated and they have closed the case. 

Management actions: Project implementation completed, and financially closed in November 2022

Status: Case completed.

Project concerned: “Umbrella Global Project on the Updating of National Implementation Plans for POPs” (Global Project with Libyan allocation of $169,132)

Agency: UNEP.

Date complaint was received: November 13, 2019

Allegations: A senior GEF Secretariat staff member reported to the UNEP GEF Coordinator that she met the Libyan GEF Operational Focal Point (OFP) during an Extended Constituency Workshop of MENA Countries, and he reported to her that: “some of the funds transferred to the executing agency in Libya have disappeared.”

Investigation Findings: The complex political situation in Libya disrupted the standard reporting procedures between UNEP and the Libyan Executing Agency, the Environmental General Authority (EGA). This disruption was compounded as the EGA, along with other segments of the Libyan Government, experienced fragmentation. Notably, the Stockholm Convention Focal Point was located in the EGA branch in Tripoli, while the GEF Operational Focal Point resided in a competing EGA faction in Elbaida. The primary concern arose from funds that were transferred to the government of Libya and were not adequately accounted for during the turmoil in the country.

Management actions: In response to the challenging political situation, operations and further disbursements for the Libyan component were suspended. Efforts to address the unaccounted funds totaling $38,312 involved communication through various channels, such as the Permanent Mission of Libya to the UN Offices in Geneva, the UN Resident Coordinator, the Stockholm Convention Focal Point, and the GEF Operational Focal Point.

In July 2020, with the appointment of a new GEF Operational and Political Focal Point within the Government of National Accord in Tripoli, UNEP successfully re-established communication with the appointee and requested a formal review of the outstanding balance.

Subsequently, the Environmental General Authority conducted internal inquiries, reaching out to former staff and examining project archives. In March 2021, UNEP received an official correspondence and an endorsed expenditure report from the GEF Political and Operational Focal Point. After reviewing and accepting the reported expenditures, UNEP was able to account for the balance. In January 2023, UNEP communicated to the GEF OFP in Libya its decision to cancel the Libyan component of the project and proceeded accordingly. UNEP reports that the case was closed. 

Status: Case completed.

Project concerned: “Development of Minamata Initial Assessment in South Africa” (GEF Grant USD 1,000,000)

Agency: UNEP

Date complaint was received: November 26, 2019

Allegations: Following a Project Steering Committee meeting held in Pretoria, South Africa in November 2017, the project beneficiary wrote to UNEP (as implementing agency) and the executing agency, raising concerns over a large sole source procurement valued at $115,000. In 2018-2019, UNEP conducted an informal review into the procurement and agreed that there were valid issues linked to the procurement related to inappropriate identification, selection and payment to a supplier outside the scope of the project procurement plan and procurement policies of UNEP as set out in the legal instrument with the executing agency.

Date case put under formal review: The case was referred to OIOS in November 2019 and was included in their 2020 workplan for formal investigation.

Investigation Findings: OIOS transmitted its investigation report to the UNEP Executive Director on 27 May 2021. The report identified an unaccounted sum of $36,000, which seems unlikely to be recovered, and recommended that UNEP take appropriate action. The Office of Legal Affairs (OLA)-NY was also involved to consider potential referral of the case to national judicial authorities.

Management actions: In response, and following consultations with the Executing Agency and Project Beneficiary, the responsible staff member from the Executing Agency was removed from all UNEP/GEF projects. UNEP’s procurement section reviewed the agency's processes and assisted in developing a procurement manual aligning with international standards. The Executing Agency cancelled the procurement contract and recovered funds exceeding the value of services provided. Internal investigations at the Executing Agency led to the decision not to renew the contract of the staff member involved.

Projects under the Executing Agency now benefit from enhanced supervision and comply with financial rules, as verified by financial audits. The UNEP-developed procurement manual is being utilized by the executing agency. The project is currently in its closure phase, with UNEP reconciling the financials. As previously reported, UNEP will coordinate with the Trustee to return the lost amount of $36,000 to the GEF Trust Fund. UNEP reports that the case has now been closed.

Status: Case completed

Project: “Development and Commercialization of Bioenergy Technologies in the Municipal Sector in Ukraine” (GEF Grant USD 4,7000,000). (project document)

Agency: UNDP

Date complaint submitted by stakeholder:  November 18, 2019

Allegations: An anonymous source made allegations of procurement fraud in the award of a training contract and in the award of a contract for the provision of boilers. In addition, the complainant alleged that grants to five NGOs and four individual contracts were unduly awarded to people/entities linked to a member of the Project Board.

Date case put under formal review: November 18, 2019

Update reported to Council: January 16, 2024; February 22, 2022; April 21, 2021; April 10, 2020

Investigation Findings: The OAI investigation was comprised of six sub cases. Two sub-cases

were substantiated and vendors have been included on the UNDP Vendor Sanctions list. The

final four sub-cases were unsubstantiated. Cases connected to this project are now closed.

Management Action: This Bioenergy Project (GEF ID 4377) completed implementation and was reported as financially closed to GEF Trustee in May 2021. In March 2020, out of an

abundance of caution, UNDP suspended a separate project in the Ukraine the Energy Efficiency in Public Buildings Project (GEF ID 5357) and initiated a full management review of the project. The management review has been completed and the Energy Efficiency project suspension was

lifted, with GEF CEO concurrence, on 4 March 2021. Project implementation is on-going with closure expected by June 2024.

Status: Investigation complete – case closed, April 4, 2023

Project: “Market Transformation for Sustainable Rural Housing in Uzbekistan”

(GEF Grant USD 6,000,000)

Agency: UNDP

Date complaint received: March 12, 2020

Allegations: Failure to comply with UNDP obligations.

Date case put under formal review: March 17, 2020

Investigation Findings: Case unsubstantiated based on OAI investigation.

Status: Investigation Completed.

Date of Case Closure: February 16, 2022. 

Project concerned: “GEF Small Grants Programme (SGP) in Sri Lanka” (Part of the Sixth Operational Phase of the GEF SGP in Sri Lanka - GEF Grant USD 2,497,078)

Agency: UNDP

Date complaint received: June 30, 2020

Allegations: Sri Lanka Nature Forum (SLNF) - a network of registered environmental organizations in Sri Lanka – submitted allegations of wrongdoing, irregularities, discrimination, fraud, and injustice.

Date case put under formal review: July 31, 2020 by UNOPS

Investigation Findings: The Internal Audit and Investigation Group (IAIG) of UNOPS conducted a remote forensic audit of the program. It found no credible evidence of fraud or conflict of interest but rather gaps and irregularities in required documentation and management of the Country Programme and a lack of guidance on a small number of key issues, including conflict-of-interest documentation and involvement of civil servants in proposal design and implementation. The report recommended that UNOPS issue more comprehensive guidance in a number of areas to the NC/NSC, to improve the implementation of the SGP Operational Guidelines and Standard Operating Procedures.

Management actions: Following the results of the audit, UNOPS in coordination with UNDP, agreed on an implementation plan to address the recommendations with management actions, including guidance on key issues, that will not only strengthen management of the Sri Lanka SGP Country Programme but also that of SGP Country Programmes worldwide. UNOPS, in coordination with UNDP, will actively engage with the SGP Country Programme Teams to improve their capacities to more effectively and transparently perform programme operations, including financial and grant management, in compliance with the SGP Operational Guidelines and SGP UNOPS Standard Operating Procedures. This will include sharing of best practices based on audit findings. The lessons learned from the audit findings will be used to strengthen execution of SGP Sri Lanka Programme management, while informing its new Operational Phase (OP7). 

Status: Case completed.

Project: “Removing Barriers to increase investment in Energy Efficiency in Public Buildings in Ukraine through the ESCO modality in Small and Medium Sized Cities” (GEF Grant USD 5,480,000)

Agency: UNDP

Date complaint received: June 2, 2021

Allegations: Failure to comply with obligations.

Date case put under formal review: June 22, 2021

Investigation Findings: Case unsubstantiated per OAI investigation which closed on March 25, 2022.

Management Actions: Implementation is on-going with closure expected by June 2025.

Status: Investigation completed.

Date of Case Closure: March 25, 2022

Project: “Hanoi Urban Transport Development Project in Vietnam (effective November 22, 2007”; closed December 31, 2016) (GEF Grant USD 9,800,000)

Agency: World Bank.

Allegations: The project aimed to increase urban mobility in targeted areas in Hanoi, by increasing use of public transport in selected corridors and reducing travel times, and to promote more environmentally sustainable transport modes and urban development plans for Hanoi. The project was partially supported by GEF funding. On November 11, 2013, an individual was hired under Contract IS02c2: An International Individual Consultant to Support the BRT Component on Traffic Signal System (“Contract IS02c2”). Contract IS02c2 was financed by the Global Environment Facility (GEF) Grant and the Japan Policy and Human Resources Development Fund (PHRD). On November 1, 2014, the individual signed a subcontract to be the Team Leader for a consultancy joint venture which had been awarded two consultancy contracts under the Danang Sustainable City Development Project. The consultancy contracts were fully financed with IBRD loans.

Investigation Findings: An investigation by the World Bank Integrity Vice Presidency (INT) found that the individual improperly influenced the tender processes under the two projects, solicited bribes, and failed to disclose his business relationship with a bidder. These are collusive, corrupt, and fraudulent practices, respectively. (See also below, Management actions)

Management actions: The World Bank imposed sanctions including debarment of an individual in connection with the collusive, corrupt, and fraudulent practices. Additional information is here. The World Bank also issued a press release announcing the debarment of Spain-based Grupo Mecánica del Vuelo Sistemas, S.A.U., in connection with collusive, corrupt, and fraudulent practices, as defined by the World Bank’s Sanctions Procedures, relating to two projects in Viet Nam, including the Hanoi Urban Transport Development Project (GEF ID 2368) that was partially funded by a grant from the GEF. This project closed on December 31, 2016. The press release is publicly accessible on the World Bank’s external website.

Status: Case completed.

Project: “Global Sustainable Supply Chains for Marine Commodities” (GEF Grant US$5,500,000)

Agency: UNDP

Date complaint received: November 6, 2021

Allegations: Failure to comply with UNDP obligations.

Date case put under formal review: November 11, 2021

Investigation Findings: Case unsubstantiated based on OAI investigation which closed on June 27, 2022.

Management action: Project implementation completed. Financial closure expected in March 2024.

Status: Investigation completed.

Date of case closure: June 27, 2022.

Project 1: “Strengthening Multi-sectoral Management of Critical Landscapes”

(GEF Grant USD 4,736,363)

Agency: UNDP

Allegations: misconduct, unauthorized payments, and fraudulent activities

Investigation Findings: Case substantiated with financial loss with amount of US$154,043.16

Management Actions: Refund to GEF processed on February 14, 2022 with amount of US$154,043.16. Project implementation completed and was reported as financially closed to GEF Trustee in June 2022.

Status: Investigation Complete

Project 2: “LDCF-financed Enhancing the resilience of tourism-reliant communities to climate change risks” (GEF ID 4585; total GEF Grant USD 1,950,000)

Agency: UNDP

Allegations: same as above

Investigation Findings: Case substantiated with financial loss with amount of US$139,624.86

Management Actions: Refund to GEF was processed on February 14, 2022 with amount of US$139,624.86. Project implementation was completed and reported as financially closed to GEF Trustee in April 2020.

Status: Investigation Complete

Project 3: “LDCF-financed Economy-wide integration of climate change adaptation and disaster risk management to reduce climate vulnerability of communities in Samoa “

(GEF Grant USD 12,322,936),

Agency: UNDP

Implementation Findings: Case substantiated with financial loss. Refund due to financial loss has been processed on February 14, 2022 with amount of US$7,899.80.

Management Actions: Project implementation completed in August 2022, and financial closure expected in December 2023.

Status: Investigation Complete

Project 4: “GEF-financed ABS Global Capacity Program Nagoya Protocol - Strengthening human resources, legal frameworks and institutional capacities to implement the Nagoya Protocol”

(GEF Grant USD 12,000,000),

Agency: UNDP.

Investigation Findings: Case on Samoa substantiated with financial loss. Refund due to financial loss has been processed on February 14, 2022 with amount of US$103,088.58.

Management action: Project implementation completed and was reported as financially closed to GEF Trustee in June 2022.

Status: Investigation Complete

Project: – “Energy efficient standards, certification, and labeling for appliances and equipment in Kazakhstan - EE S&L project in Kazakhstan under Global UNEP Platform” (GEF Grant USD 3,500,000). Link to Project Document

Agency: UNDP

Date complaint submitted by stakeholder: August 11, 2020

Allegations: Related to procurement fraud against project personnel.

Date case put under formal review: August 11, 2020

Update reported to Council: April 16, 2024; March 26, 2024; January 18,2023

Investigation Findings: The UNDP Office of Audit and Investigation (OAI) substantiated the allegations in this case related to procurement fraud and misrepresentation, forgery, and false certification. At that time, UNDP reported that no financial loss could be quantified. UNDP corrected this and has returned a financial loss of US$13,047 to the GEF on 22 August 2024. UNDP OAI referred the case to the UNDP Vendor Sanctions Committee to consider sanctions against individuals/companies. UNDP reports that the sanctions list now includes Kazakhstan individual/companies who are barred from working with UNDP.

Management Action: Investigation has completed.

Status: Investigation completed – case closed. UNDP is withdrawing the request to the lift the suspension of the project. The project will remain suspended pending completion of this new OAI investigation. 

Date of case closure: Two of the three cases were closed on 7 December 2022, one closed on 11 November 2022

Project: “Strengthening Management of the PA System to Better Conserve Endangered Species and their Habitats” (GEF Grant USD 5,525,114). Link to Project Document

Agency: UNDP

Date complaint submitted by stakeholder: September 14, 2020

Allegations: Related to theft and embezzlement.

Date case put under formal review: September 14, 2020

Update reported to Council: 10 January 2023

Investigation Findings: UNDP reports that the OAI investigation is completed and found that the case is unsubstantiated.

Management Action: The project was financially closed on 22 January 2024 and is expected to

Status: Investigation complete – case closed

Date of case closure: December 15, 2022

Project: “Promoting production and utilization of biomethane from agro-waste in South-Eastern Botswana” (GEF Grant USD 2,632,300),

Agency: UNDP

Allegations: Related to procurement fraud against a UNDP personnel.

Investigation Findings: The OAI investigation is completed in July 2023 and found that the case unsubstantiated. 

Management action: The project implementation completed, and financial closure expected in July 2024.

Status: Case completed

Project: “Pakistan Snow Leopard and Ecosystem Protection Program” (GEF Grant USD 4,644,521)

Agency: UNDP

Allegations: Related to misuse of official resources against an NGO reported by the UNDP Resident Representative

Investigation Findings: The OAI investigation is completed in April 2023 and found the case substantiated with an estimated financial loss of US$80,556.03 as a result of the use of funds for unauthorized purposes by a third party (NGO) within the project. The case has been referred to the Vendor Sanctions Committee after which UNDP will begin a process to attempt to recover these funds.

Management Actions: The project was suspended when the OAI case was opened and remains suspended until December 31, 2023.

Status: Investigation completed.

Project: “Sound Mexico GEFID 5179 Management of POPs Containing Waste” (GEF Grant USD5,720,000). (project document)

Agency: UNDP

Date complaint submitted by stakeholder: January 7,2022

Allegations: Related to procurement fraud.

Date case put under formal review: January 7, 2022

Investigation Findings: UNDP reports that the OAI investigation is completed and found that the case is unsubstantiated.

Management Action: Project implementation completed and financially closed in November 2023.

Status: Investigation complete – case closed.

Date of case closure: September 5, 2023