Independent Complaint Mechanism (IKI ICM)

As of: February 2026

Illustration: Two people sitting on the floor, three people discussing with each other and two people shaking hands.

The Independent Complaint Mechanism of the International Climate Initiative (IKI ICM) is intended to enable people who suffer (potential) 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 Zukunft-Umwelt Gesellschaft (ZUG) gGmbH, the Federeal Ministry for the Environment (BMUKN) and the Federal Foreign Office (AA),
support the appropriate use of public funds, and
comply with international good practice

The complaints mechanism is based at Zukunft - Umwelt - Gesellschaft (ZUG) gGmbH, the Federal Goverment's project management agency for the International Climate Initiative .

The basic responsibility for the complaints mechanism lies with the BMUKN, which also works closely with the Federal Foreign Office in this regard.

IKI ICM Policy (02/2022) (English, PDF, 345 KB, barrier-free)

The Independent Complaint mechanism of the International Climate Initiative 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.
The mechanism is open to anyone who claims to have suffered negative consequences directly from the implementation of an IKI project or who wishes to report serious negative environmental impacts directly caused by the project and/or 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 (currently being recruited) and a complaint office. It can be reached at: iki-complaints(at)z-u-g.org.
The expert panel of the independent complaint mechanism, which consists of 4 persons, is responsible for investigating and/or mediating complaints by project-affected persons and whistleblowers reporting negative social and/or environmental consequences from IKI projects, or the improper use of funds.

To the members of the expert panel …
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Andrea Kämpf

Andrea Kämpf, LL.M., is a lawyer and mediator and heads the office of the IKI Independent Complaint Mechanism. Andrea has over 20 years of experience in human rights, accountability, sustainability standards, participatory governance and stakeholder management – working with public, private and civil society sector organizations.

She led the process to the establishment of the IKI Independent Complaint Mechanism since January 2021 when she joined ZUG gGmbH.

Prior to this, as a Senior Policy Adviser at the German Institute for Human Rights (Germany’s NHRI), she advised and worked with the German government and development cooperation agencies GIZ and KfW, as well as the European Union on implementing a human rights based approach to development.

As an associate expert for the panel of the Independent Complaint Mechanism of DEG/FMO she laid the groundwork for the implementation of an alternative dispute resolution procedure.

Previously, she worked for international governmental and non-governmental organisations, as part-time professor and consultant for state and non-state development organizations.

Next to public sector complaint mechanism, she is interested in complaints practice of the private sector, and is co-author of a German legal commentary on the recently enacted German Supply Chain Due Diligence Act.

A German national, she speaks German, English, French and Spanish.
To the CV of Andrea Kämpf on LinkedIn
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.
Written submissions

Accountability Counsel (PDF, not barrier-free)

Urgewald (PDF, German, not barrier-free)

FIAN Deutschland e.V. (PDF, German, not barrier-free)

IKI BBL

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IKI Brown Bag Lunch: IKI Independent Complaint Mechanism (ICM)

Recording COP29 Event

At COP29 in Baku, the head of the complaints office of the IKI ICM, Andrea Kämpf, took part in the event ‘Why Accountability is Key to a Successful Just Transition’.

Watch the recording of the event

Contact

Office of the IKI Independent Complaint Mechanism (IKI ICM)

iki-complaints@z-u-g.org

File a complaint

Do you want to submit a complaint or are you looking for more information?

Notes on data protection

IKI ICM Notes on data protection (English, PDF, 162 KB, barrier-free)

Online seminar

To support the work of the IKI UBM, we offer an online seminar for implementing organisations, implementing partners, potentially affected individuals and interested non-governmental organisations.

IKI ICM presentation outreach (English, PDF, 755 KB, barrier-free)

Stay up to date with the IKI ICM newsletter!

Further information

The complaint mechanism is also handling complaints regarding the grants programme again maritime litter.

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