Independent Complaint Mechanism

Online consultation of the independent complaint mechanism’s policy, October – November 2021

The International Climate Initiative (IKI) is the most important instruments of the German Federal Ministry for the Environment, Nature Conservation and Nuclear Safety (BMU) for the international financing of climate change mitigation and biodiversity. IKI operates within the framework of the United Nations Framework Convention on Climate Change (UNFCCC) and the Convention on Biological Diversity (CBD), financing climate change mitigation and biodiversity conservation in developing, emerging and transition countries. The Secretariat of the International Climate Initiative supports the BMU in implementing the IKI. The IKI Secretariat is operated by the BMU-affiliated project management company Zukunft - Umwelt- Gesellschaft gGmbH (ZUG).

In 2020, BMU requested ZUG to explore options for a complaint mechanism for IKI and the necessary legal and practical means for its establishment. A draft policy for the mechanism has been released by BMU for consultation. The main objective of the consultation is enhancing the effectiveness of the future mechanism by strengthening the policy and the dialogue with its stakeholders.

The consultations run from 18.10. to 28.11.2021. During this time, the policy will be open for comments. A dedicated website will feature information about the mechanism and the consultation process as well as contributions from stakeholders released for publication.

The draft policy can be downloaded here:



Overview of the future mechanism

The Independent Complaint mechanism of IKI (IKI ICM) follows established international good practice of other accountability mechanisms associated in the Independent Accountability Mechanism Network. Its procedure is based on Germany’s human rights treaty obligations as well as standards such as the UN Guiding Principles on Business and Human Rights.

  • Everybody who – as a consequence of an IKI-supported project – either claims to have suffered negative consequences arising immediately from the implementation, or wants to report serious negative environmental impact resulting immediately from the implementation of an IKI-funded project, and/or wants to report misuse of funds or corruption.
  • For the protection of complainants and whistle-blowers, the anonymity of complainants can be ensured, among others through an anonymous mailbox, which allows communication back and forth.
  • IKI ICM addresses complaints regarding noncompliance with negative social and/or environmental impacts and/or misuse of funds and corruption. It does not consider complaints regarding rejection of funding proposals.
  • Complainants can choose between a mediation-based alternative dispute resolution procedure in which the IKI ICM facilitates a voluntary process between the parties to reach a mutually accepted solution to the issues raised in the complaint, and a compliance review, in which the IKI ICM assesses compliance of ZUG and implementing organisations with IKI safeguards and budgetary and funding law as well as their direct management by ZUG.
  • IKI ICM is located within ZUG, but structurally and financially independent. It consists of a panel of three independent experts (to be recruited) and a complaint office. It can be reached at: It will be fully operational by 2022.

Scope of the consultation

There is the possibility to participate with written contributions as well as to take part in online seminars (registration below). While all comments on the policy are highly welcome, we are particularly interested in comments regarding

  • the integration of both integrity/corruption issues as well as social and environmental complaints in one mechanism,
  • the inclusion of complaints regarding considerable and serious negative environmental impact without proving individual harm,
  • the structure and clarity of the procedure of the mechanism and its responsiveness to stakeholders,
  • the complementarity and cooperation between the IKI complaint mechanism and the complaint mechanisms of the organisations implementing IKI-funded projects,
  • provisions regarding transparency and data protection.

Written Submissions

Registration for online seminars and the newsletter of the independent complaint mechanism

Online seminars and the newsletter independent complaint mechanism


The office of the future complaints mechanism can be reached at IKI-complaints(at) Written feedback can also be sent to this address. Please indicate whether we can publish the contribution on our website.


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