Independent Complaint Mechanism

The mechanism is intended to enable people who suffer (potentially) negative social and/or environmental consequences from IKI projects, or who wish to report the improper use of funds, to voice their complaints and seek redress. In doing so, it should also contribute to

  • monitor and improve the environmental and social outcomes of projects,
  • avoid unintended negative impacts of projects that go unnoticed by ZUG and BMU,
  • support the appropriate use of public funds, and
  • comply with international good practice

The complaints mechanism is based at Zukunft - Umwelt - Gesellschaft (ZUG) gGmbH, BMU's project management agency for the IKI funding programme.

Consultations October-November 2021

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 was consulted between 18.10. to 28.11.2021. In three online seminars and in the form of written comments, more than 20 participants from all regions of the world provided ZUG and BMU with valuable suggestions.

The draft policy (as of October 2021) can be downloaded here:




Written submissions

  1. Accountability Counsel
  2. Urgewald
  3. FIAN Deutschland e.V. 

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.

Registration for the newsletter of the independent complaint mechanism

Newsletter independent complaint mechanism


The office of the future complaints mechanism can be reached at IKI-complaints(at)


Privacy Policy Statement