“Complaints are a force for good”
The Independent Complaint Mechanism for the IKI (IKI ICM) – a milestone for the IKI – was launched in autumn 2022. We talked to the Head of the Complaint Office, Andrea Kämpf, about an eventful first year.
Why does the IKI need a complaints mechanism?

Mistakes can occur in any organisation, including the IKI. Measures from IKI projects can adversely impact people, cause social consequences or lead to negative environmental outcomes for communities. Of course, there is always the danger that IKI funds will be used inappropriately. The IKI ICM is the designated point of contact for such cases. Together with the IKI Safeguards, the ICM ensures that the IKI fulfils its duty of care in terms of project selection and implementation.
How can people contact the IKI ICM?
The complaints form can be submitted to the IKI ICM by post or email. People can also call us or send voice or video messages. Complaints can be lodged in English or the national language of the respective country. For all the details, please visit the IKI ICM section on the IKI website.
When was the IKI ICM established?
The rules of procedure came into force in January 2022. These rules are the result of a broad-based consultation process with employees at the IKI project management agency Zukunft – Umwelt – Gesellschaft (ZUG) as well as federal ministries, domain experts, international civil society and IKI implementing organisations. The independent expert panel was then appointed last autumn.
What role does the expert panel play?
The experts on the panel investigate the complaints reported. We’ve managed to acquire a truly international and highly qualified body of experts for the IKI ICM, consisting of Lalanath de Silva, the former Head of the Independent Redress Mechanism of the Green Climate Fund, Sârra-Tilila Bounfour, a lawyer with investigative experience gained at the World Bank, World Food Programme and at international law offices, and Philipp König, a mediation and compliance expert with experience gained at the European Investment Bank, African Development Bank and KfW in Germany.
What actual complaints might be made?
One of the most famous cases in recent years – although not involving the IKI – was the abuse of local populations by park rangers working for conservation authorities that received funding for nature reserves from the German government. This was the subject of both media attention and debate in the Bundestag.
The IKI was not involved there. Has the IKI ICM already received and processed complaints?
In November 2022, one case was reported that the IKI ICM has since been investigating. It concerns an accusation of misappropriated budget funds. The IKI ICM is also investigating allegations that complainants are suffering reprisals after reporting problems – a situation that is unfortunately growing increasingly common worldwide and is also part of the complaint mentioned above.
Where can information be obtained about ongoing cases?
The IKI ICM publishes procedural documents in its section on the IKI website. Some documents will be anonymised in terms of the project country, the name of the implementing organisation and the identity of the complainant.
What are your hopes for the IKI ICM over the next few months – no new complaints?
Unfortunately, it’s not that simple. Interpreting the absence of complaints as the absence of problems would assume that all those affected were able to submit a complaint without any problems. However, we have to consider obstacles such as remote regions, language barriers, lack of internet access, or personal threats. These challenges will remain for a long time to come.
A comment made by a US senator comes to mind here: “The more complaints we receive, the better the protection afforded to human rights in this country.”
So in fact, I’d like to see the IKI ICM receiving more complaints.
Complaints are a positive indicator – they show that affected parties know about the mechanism and have confidence that it will process their complaints and achieve a satisfactory outcome. In international terms, the mechanisms receiving the most complaints are those considered to be the most effective. So we should want the IKI ICM to receive many complaints, although the IKI of course makes every effort to ensure that projects result in no negative consequences or impacts.
Interview partner

Andrea Kämpf, LL.M., is a lawyer and mediator and heads the Complaints Office of the IKI Independent Complaint Mechanism.
IKI ICM at a glance
Innovations made by the IKI ICM compared with previous mechanisms
- Integration of complaints involving safeguards and misuse of funds within a single mechanism
- Acceptance of anonymous complaints in light of more serious threats against complainants
- For serious environmental damage, complainants do not have to prove they are personally affected
- Reprisals are an independent reason for a complaint
IKI Annual Report 2022
This article is part of the IKI Annual Report 2022. Learn more about the IKI Year 2022 ...
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