What are the key differences between IFC’s enhanced Action Plan and the Action Plan disclosed by IFC on January 3?
IFC has enhanced the Action Plan which was posted in January 2014 in response to the CAO Audit of IFC's investment in Corporación Dinant. This enhanced Action Plan incorporates feedback from IFC’s Board and other stakeholders and will serve as the basis for consultation with affected communities over the coming months. It includes a more detailed approach to ensuring that Dinant’s security protocols meet international best practice, including vetting and training of in-house and third party security personnel, establishing a grievance mechanism, and more formalized and defined roles for Dinant’s security personnel vis a vis public security forces.
The enhanced Action Plan also includes an assessment and verification of these protocols and the development of an internal investigative process to address future security incidents or allegations against Dinant’s security personnel. An independent expert will be hired to develop these protocols..
In accordance with IFC’s Performance Standards, Dinant will also engage a reputable third party to conduct an investigation of credible past incidents involving its security forces to identify any non-compliance or wrongdoing. If this is found, corrective actions will be taken, including disciplinary measure and compensation, as warranted.
With regard to community engagement, the enhanced Action Plan includes plans for community consultations to be facilitated by a reputable third party with IFC participation. Communities will be given prior notice and relevant, culturally appropriate information. A draft grievance mechanism will be shared as part of the consultations. IFC will also hire its own conflict mediation consultants to support the community engagement process. The enhanced Action Plan may be revised based on feedback received.
What are the next steps for consultation on the enhanced Action Plan? How can interested parties provide feedback?
The enhanced Action Plan includes references to several independent, third party experts who will assist Dinant and IFC on various aspects related to security and community engagement. There is also a need for a specialized external expert to conduct an investigation into credible allegations related to Dinant’s past security incidents. The next steps are to identify and hire these experts with experience working in conflict zones and to develop terms of reference (ToRs), acceptable to IFC, to carry out the actions described.
Interested parties can provide feedback by contacting IFC directly at email@example.com. They can also participate in consultations to be held this year in Honduras. More information, including dates and locations, will be posted on IFC’s website.
When and where will the community engagement process begin, what is the objective of this engagement?
Dinant will identify a reputable third party consultant to develop and implement the community engagement strategy and the grievance mechanism. IFC will also engage its own consultant to support the consultations, undertake conflict mapping, and - if needed - recommend further enhancements to the grievance mechanism considering the context of the Aguan Valley.
Consultations will be conducted this year in four regions in Honduras where Dinant has operations, including the Aguan Valley. Locations and dates will be posted on IFC’s website once they are determined.
How will Dinant’s Corporate Security Management System help address violence and inappropriate use of force against communities in the Aguan Valley?
Dinant’s Corporate Security Management System will help develop a protocol that includes vetting for in-house and third party contractors and training. It will also create a process for addressing any future incidents involving Dinant’s security forces. Dinant will report any information related to unlawful or abusive acts to the appropriate authorities in charge of criminal investigations.
What types of issues will the grievance mechanism address? Will IFC monitor this mechanism?
The grievance mechanism will cover any concerns or complaints raised by communities affected by Dinant’s operations, including security-related issues. This will be an important part of the community engagement process as it will create opportunities for the company and the community to identify problems and propose solutions together. IFC will review the draft grievance mechanism and provide any necessary recommendations to ensure that it meets the requirements of our Performance Standards. A draft of the grievance mechanism will be discussed with communities as part of the engagement process and will be revised as needed based on community feedback.
Through its supervision of Dinant, IFC will also monitor how well the company is implementing their grievance mechanism and provide feedback if changes are needed to improve its effectiveness. Dinant will provide information on the grievance mechanism as part of its Annual Monitoring Report, including a summary of how grievances have been handled. IFC Specialists will review the grievance mechanism and meet with communities during supervision activities to understand the issues and resolutions raised.
What is the process for investigating allegations against Dinant’s security forces, what incidents will be investigated?
Dinant will engage a reputable third party and develop a terms of reference acceptable to IFC. The specific terms of reference have not been developed at this point, but IFC will be engaging external advisors with expertise in private security and human rights to support this process. The terms of reference will be in line with the requirements of IFC’s Performance Standards and accompanying Guidance Notes. Dinant will report any information related to unlawful acts to the appropriate authorities in charge of criminal investigations.
How is IFC addressing some of the internal issues raised by the CAO report, including adequate consideration of project context, improving application of existing policies and procedures, and better assessing and managing environmental and social risks in fragile and conflict affected areas?
As mentioned in its January 3 response to the CAO, IFC committed to review and strengthen its approach to the management of environmental and social risks in fragile and conflict-affected situations. Work has already begun to develop and provide guidance and training to staff on client use of security forces and human rights due diligence in high risk contexts. IFC will retain expert consultants in these areas to support project appraisal and supervision. IFC will also further strengthen its overall environmental and social supervision program to focus more resources on high risk operations.
In addition, IFC will review its procedures related to the processing and documentation of waivers and conditions of disbursement, and continue process improvements related to integrity due diligence. IFC will also engage with its Board of Directors more systematically on emerging risks related to challenging projects and provide more analysis of risks in the broader operating context, including on the possible limitations of IFC’s leverage and the resulting residual risks.