and exploitation andavoidance ofchildlabour. national legalrequirements. This includes protection from abuse workers’ rightsshouldbeprotected andremain consistent with Maintains that OS5 LabourConditions,Healthand Safety:Maintainsthat efficiently usingnaturalresources, especiallyenergyandwater. health and the environment; andsetsaframeworkfor related pollutantsthatcouldhaveadverseeffects onhuman and Resource Efficiency: Aims to manageandreduce project- OS4 PollutionPrevention andControl, Hazardous Materials biodiversity and ecosystemservices. should implementmeasures tominimiseimpactsand restore When direct andindirect impactsare unavoidable,they services. services. clients should avoid impacts on biodiversity and ecosystem clients shouldavoidimpactsonbiodiversityandecosystem Establishes that OS3 BiodiversityandEcosystemServices:Establishesthat project. their standard ofliving,andshare in thebenefitsof compensation orresettlement assistanceto improve avoided, peopleshouldbetreated fairly, receive when physicaloreconomic resettlement cannotbe OS2 impacts. minimising aproject’s environmental andsocial Establishes the importance of determining and Establishes the importance ofdetermining and OS1 Environmental andSocialAssessment: impacts. Guidelines cover the following: impacts. Guidelines cover thefollowing: assessments and minimising adverse community assessments andminimisingadverse community its clientsregarding socialandenvironmental Involuntary Resettlement: Aimstoensure that, The OSsetoutthe Bank’s expectationsfrom are expected to bereleased soon. and Social Impact Assessment (IESIA) Guidelines and SocialImpactAssessment(IESIA)Guidelines Procedures (ESAP)andIntegratedEnvironmental and newEnvironmental and Social Assessment includes a set ofOperationalSafeguards (OS), against harmfrom AfDBprojects. TheISS vulnerable groups andthe environment rules fortheprotection oflocalpopulations, Safeguards System(ISS),whichsets out In 2013,the AfDB released anewIntegrated Key AfDBrules United StatesofAmerica San Francisco,CA94108 Street,244 Kearny Floor6 Accountability Counsel – andtodemandremedies where rightsare violated–through theuseofnon-judicialaccountabilityoffices. projects. AccountabilityCounselhelpscommunitiestovoicetheircomplaintsaboutprojects thataffect them financeddevelopment environmental byinternationally andhumanrightswhentheyhavebeenharmed Accountability Counselisanon-profit legalorganisation thatsupportscommunitiestodefendtheir Counsel About Accountability The Netherlands 1018 GLAmsterdam Sarphatistraat 30 Centre forResearch onMultinationalCorporations Stichting OnderzoekMultinationaleOndernemingen SOMO go towww.grievancemechanisms.org. experience adverseimpactsontheirhumanrightsasaresult ofbusinessactivities.Formore information, improve theaccessibilityandeffectiveness ofnon-judicialgrievancemechanismsforstakeholderswho problems, exploitationandinequality. SOMO’s Rights,RemedyandAccountabilityProgramme aimsto fair globaleconomicdevelopmentandtheeliminationofstructuralcausespoverty, environmental SOMO isanindependent,non-profit research andnetworkorganisation thatpromotes sustainableand Affairs ortheAfricanDevelopmentBank. sole responsibility ofSOMOandAccountability Counselandcaninnowaybetakentoreflect theviewsofDutchMinistry ofForeign This publicationismade possiblewithfinancialassistancefrom theDutchMinistryofForeign Affairs. Thecontentofthispublicationisthe About SOMO grievance. Thisbrochure brieflyexplainshow. individuals whoarebyanAfDB-supportedproject harmed canusetheIRMprocess toaddress their and howtofileacomplaint.Civilsocietyorganisations, workers,communitiesandgroups of This brochure provides abriefoverviewoftheworkAfDB’s IndependentReviewMechanism brochure this About www.accountabilitycounsel.org [email protected] T +14152966761 www.somo.nl [email protected] T +31206391291
GRAPHIC DESIGN: JUSTAR.NL African Development Bank Mechanismofthe The IndependentReview
revised in2015. This brochure covers IRM policy, as infrastructure. hydropower, agriculture or sectors rangingfrom transportation, environmental impactsofprojects in Complaints mayrelate tothesocial and implementation of its projects. procedures duringthedesignand the AfDB follows itsownpoliciesand The IRMwasdesignedtomakesure that funded bytheAfDBGroup. or whoare likely tobeharmed,byaproject two or more peoplewhohavebeenharmed, address complaintsmade byanygroup of was establishedbytheAfDB in 2004to The Independent Review Mechanism(IRM) Ivory Coast. The Bank’s headquartersare locatedinAbidjan, progress ofits54Africanmembercountries. sustainable economicdevelopmentandsocial The bank’s mission is tocontribute to the established in 1964 aspart of the AfDB Group. The AfricanDevelopmentBank(AfDB)was Development Bank Mechanism oftheAfrican Independent Review About the
and exploitation andavoidance ofchildlabour. national legalrequirements. This includes protection from abuse workers’ rightsshouldbeprotected andremain consistent with Maintains that OS5 LabourConditions,Healthand Safety:Maintainsthat efficiently usingnaturalresources, especiallyenergyandwater. health and the environment; andsetsaframeworkfor related pollutantsthatcouldhaveadverseeffects onhuman and Resource Efficiency: Aims to manageandreduce project- OS4 PollutionPrevention andControl, Hazardous Materials biodiversity and ecosystemservices. should implementmeasures tominimiseimpactsand restore When direct andindirect impactsare unavoidable,they services. services. clients should avoid impacts on biodiversity and ecosystem clients shouldavoidimpactsonbiodiversityandecosystem Establishes that OS3 BiodiversityandEcosystemServices:Establishesthat project. their standard ofliving,andshare in thebenefitsof compensation orresettlement assistanceto improve avoided, peopleshouldbetreated fairly, receive when physicaloreconomic resettlement cannotbe OS2 impacts. minimising aproject’s environmental andsocial Establishes the importance of determining and Establishes the importance ofdetermining and OS1 Environmental andSocialAssessment: impacts. Guidelines cover the following: impacts. Guidelines cover thefollowing: assessments and minimising adverse community assessments andminimisingadverse community its clientsregarding socialandenvironmental Involuntary Resettlement: Aimstoensure that, The OSsetoutthe Bank’s expectationsfrom are expected to bereleased soon. and Social Impact Assessment (IESIA) Guidelines and SocialImpactAssessment(IESIA)Guidelines Procedures (ESAP)andIntegratedEnvironmental and newEnvironmental and Social Assessment includes a set ofOperationalSafeguards (OS), against harmfrom AfDBprojects. TheISS vulnerable groups andthe environment rules fortheprotection oflocalpopulations, Safeguards System(ISS),whichsets out In 2013,the AfDB released anewIntegrated Key AfDBrules Affairs ortheAfricanDevelopmentBank. sole responsibility ofSOMOandAccountability Counselandcaninnowaybetakentoreflect theviewsofDutchMinistry ofForeign This publicationismade possiblewithfinancialassistancefrom theDutchMinistryofForeign Affairs. Thecontentofthispublicationisthe United StatesofAmerica San Francisco,CA94108 Street,244 Kearny Floor6 Accountability Counsel – andtodemandremedies where rightsare violated–through theuseofnon-judicialaccountabilityoffices. projects. AccountabilityCounselhelpscommunitiestovoicetheircomplaintsaboutprojects thataffect them financeddevelopment environmental byinternationally andhumanrightswhentheyhavebeenharmed Accountability Counselisanon-profit legalorganisation thatsupportscommunitiestodefendtheir Counsel About Accountability The Netherlands 1018 GLAmsterdam Sarphatistraat 30 Centre forResearch onMultinationalCorporations Stichting OnderzoekMultinationaleOndernemingen SOMO go towww.grievancemechanisms.org. experience adverseimpactsontheirhumanrightsasaresult ofbusinessactivities.Formore information, improve theaccessibilityandeffectiveness ofnon-judicialgrievancemechanismsforstakeholderswho problems, exploitationandinequality. SOMO’s Rights,RemedyandAccountabilityProgramme aimsto fair globaleconomicdevelopmentandtheeliminationofstructuralcausespoverty, environmental SOMO isanindependent,non-profit research andnetworkorganisation thatpromotes sustainableand About SOMO grievance. Thisbrochure brieflyexplainshow. individuals whoarebyanAfDB-supportedproject harmed canusetheIRMprocess toaddress their and howtofileacomplaint.Civilsocietyorganisations, workers,communitiesandgroups of This brochure provides abriefoverviewoftheworkAfDB’s IndependentReviewMechanism brochure this About www.accountabilitycounsel.org [email protected] T +14152966761 www.somo.nl [email protected] T +31206391291
GRAPHIC DESIGN: JUSTAR.NL African Development Bank Mechanismofthe The IndependentReview
revised in2015. This brochure covers IRM policy, as infrastructure. hydropower, agriculture or sectors rangingfrom transportation, environmental impactsofprojects in Complaints mayrelate tothesocial and implementation of its projects. procedures duringthedesignand the AfDB follows itsownpoliciesand The IRMwasdesignedtomakesure that funded bytheAfDBGroup. or whoare likely tobeharmed,byaproject two or more peoplewhohavebeenharmed, address complaintsmade byanygroup of was establishedbytheAfDB in 2004to The Independent Review Mechanism(IRM) Ivory Coast. The Bank’s headquartersare locatedinAbidjan, progress ofits54Africanmembercountries. sustainable economicdevelopmentandsocial The bank’s mission is tocontribute to the established in 1964 aspart of the AfDB Group. The AfricanDevelopmentBank(AfDB)was Development Bank Mechanism oftheAfrican Independent Review About the
and exploitation andavoidance ofchildlabour. national legalrequirements. This includes protection from abuse workers’ rightsshouldbeprotected andremain consistent with Maintains that OS5 LabourConditions,Healthand Safety:Maintainsthat efficiently usingnaturalresources, especiallyenergyandwater. health and the environment; andsetsaframeworkfor related pollutantsthatcouldhaveadverseeffects onhuman and Resource Efficiency: Aims to manageandreduce project- OS4 PollutionPrevention andControl, Hazardous Materials biodiversity and ecosystemservices. should implementmeasures tominimiseimpactsand restore When direct andindirect impactsare unavoidable, they services. services. clients should avoid impacts on biodiversity and ecosystem clients shouldavoidimpactsonbiodiversityandecosystem Establishes that OS3 BiodiversityandEcosystemServices:Establishesthat project. their standard ofliving,andshare in thebenefitsof compensation orresettlement assistanceto improve avoided, peopleshouldbetreated fairly, receive when physicaloreconomic resettlement cannotbe OS2 impacts. minimising aproject’s environmental andsocial Establishes the importance of determining and Establishes the importance ofdetermining and OS1 Environmental andSocialAssessment: impacts. Guidelines cover the following: impacts. Guidelines cover thefollowing: assessments and minimising adverse community assessments andminimisingadverse community its clientsregarding socialandenvironmental Involuntary Resettlement: Aimstoensure that, The OSsetoutthe Bank’s expectationsfrom are expected to bereleased soon. and Social Impact Assessment (IESIA) Guidelines and SocialImpactAssessment(IESIA)Guidelines Procedures (ESAP)andIntegratedEnvironmental and newEnvironmental and Social Assessment includes a set ofOperationalSafeguards (OS), against harmfrom AfDBprojects. TheISS vulnerable groups andthe environment rules fortheprotection oflocalpopulations, Safeguards System(ISS),whichsets out In 2013,the AfDB released anewIntegrated Key AfDBrules The Netherlands 1018 GLAmsterdam Sarphatistraat 30 Centre forResearch onMultinationalCorporations Stichting OnderzoekMultinationaleOndernemingen SOMO go towww.grievancemechanisms.org. experience adverseimpactsontheirhumanrightsasaresult ofbusinessactivities.Formore information, improve theaccessibilityandeffectiveness ofnon-judicialgrievancemechanismsforstakeholderswho problems, exploitationandinequality. SOMO’s Rights,RemedyandAccountabilityProgramme aimsto fair globaleconomicdevelopmentandtheeliminationofstructuralcausespoverty, environmental SOMO isanindependent,non-profit research andnetworkorganisation thatpromotes sustainableand United StatesofAmerica San Francisco,CA94108 Street,244 Kearny Floor6 Accountability Counsel – andtodemandremedies where rightsare violated–through theuseofnon-judicialaccountabilityoffices. projects. AccountabilityCounselhelpscommunitiestovoicetheircomplaintsaboutprojects thataffect them financeddevelopment environmental byinternationally andhumanrightswhentheyhavebeenharmed Accountability Counselisanon-profit legalorganisation thatsupportscommunitiestodefendtheir Counsel About Accountability About SOMO grievance. Thisbrochure brieflyexplainshow. individuals whoarebyanAfDB-supportedproject harmed canusetheIRMprocess toaddress their and howtofileacomplaint.Civilsocietyorganisations, workers,communitiesandgroups of This brochure provides abriefoverviewoftheworkAfDB’s IndependentReviewMechanism brochure this About Affairs ortheAfricanDevelopmentBank. sole responsibility ofSOMOandAccountability Counselandcaninnowaybetakentoreflect theviewsofDutchMinistry ofForeign This publicationismade possiblewithfinancialassistancefrom theDutchMinistryofForeign Affairs. Thecontentofthispublicationisthe www.accountabilitycounsel.org [email protected] T +14152966761 www.somo.nl [email protected] T +31206391291
GRAPHIC DESIGN: JUSTAR.NL African Development Bank Mechanismofthe The IndependentReview
revised in2015. This brochure covers IRM policy, as infrastructure. hydropower, agriculture or sectors rangingfrom transportation, environmental impactsofprojects in Complaints mayrelate tothesocial and implementation of its projects. procedures duringthedesignand the AfDB follows itsownpoliciesand The IRMwasdesignedtomakesure that funded bytheAfDBGroup. or whoare likely tobeharmed,byaproject two or more peoplewhohavebeenharmed, address complaintsmade byanygroup of was establishedbytheAfDB in 2004to The Independent Review Mechanism(IRM) Ivory Coast. The Bank’s headquartersare locatedinAbidjan, progress ofits54Africanmembercountries. sustainable economicdevelopmentandsocial The bank’s mission is tocontribute to the established in 1964 aspart of the AfDB Group. The AfricanDevelopmentBank(AfDB)was Independent Review About the Mechanism oftheAfrican Development Bank
1 2 3 4 5
How to file Overall strategic considerations Community considerations prior to submitting a complaint Write the complaint File the complaint Follow up on your complaint a complaint Consider the benefits of a complaint, as well as Determine the scope of the community experiencing The complaint should include: You may submit the complaint in your local language, Once the complaint has been submitted, if limitations of the IRM, and set appropriate expectations. harm and assess whether those people fully understand The date, name and signatures of the affected people; whether they if you are not able to submit your complaint in English you do not hear from the CRMU within 14 The following step-by-step Consider whether another strategy might be more and support a complaint process. If they do not, consider wish their identities to remain confidential and if so why; and the name or French. Submit the complaint via email or mail to: days, check with them to ensure that the guide explains the process effective or efficient. Using the IRM is most effective whether it would be useful to conduct training for the of any representatives assisting the affected people, with a signed letter process is moving along. Compliance Review and Mediation Unit (CRMU) that affected groups and when combined with other strategies, including: affected group. confirming their authority to represent them. African Development Bank It is often helpful to speak to members of their representatives can engaging with the media; seeking campaign support If possible, any community divisions should be resolved A brief description of the project and, if possible, the policies and/or 01 P.O. Box 1387 -Abidjan 01, Cote d’Ivoire the Board, as they will ultimately decide 2nd Floor, CCIA Building, Abidjan Plateau follow to submit a complaint. from other organisations; government advocacy; or early on so that they do not undermine the process. procedures that have been violated. Avenue Jean-Paul II what to do with the CRMU’s report. The There are various tools other tactics. Problem-solving is most effective when the affected An explanation of the harm, or expected harm, resulting from the AfDB T +225 20 26 29 56 Board may ask the CRMU to monitor any available for assistance. The Understand the time and resources required to complete community speaks with one voice. project. Email: [email protected] changes to the project as a result of the IRM of the AfDB, as well as the IRM process, which might take several years. Decide who will speak on behalf of the affected An outline of the change you would like to see as a result of the CRMU If you are unable to submit a written complaint, compliance review. SOMO and Accountability Consider whether beginning an IRM complaint process community during the complaint process; how decisions process. contact the CRMU and they will assist you to submit If the compliance review concludes that the Counsel, can provide advice could place the affected group at risk of retribution during the process will be made; what the desired A description of any communication with Bank staff regarding the issue(s) the complaint in writing. The complaint may also Bank has violated its rules, ensure the Board and additional information or intimidation. Consider the need for confidentiality outcomes are; whether the dialogue could produce raised in the complaint. be submitted to your country’s field office. follows through with any commitments about submitting a and develop a strategy in advance about how to those outcomes and how; and which issues will take Supporting materials, such as correspondence with Bank staff and a Information on the location of the field offices can made to remedy the harm (or potential complaint. address risks. priority in the dialogue process. description of the location of the affected area. be found here: http://www.afdb.org/en/countries/. harm) of the project.
The Independent Review Mechanism process General information Once the CRMU receives a complaint, the Director conducts a review within 14 days to assess whether The about the IRM the complaint raises legitimate claims of harm stemming from a Bank-funded project. If this criterion is met, the Director then registers the complaint and asks AfDB Management to submit a response who, what, when, where, and why Benefits and limitations The IRM was created to provide communities with an effective tool through within 21 days. The Director then initiates either problem-solving or compliance review, based on the which they can request that the AfDB comply with its policies and procedures. complainants’ stated preference. If complainants request both functions, the problem-solving will be of filing a complaint of the mechanism The IRM handles complaints about both public and private sector operations, undertaken first. The Director then informs the President and the Boards of Directors of the decision. and is administered by the AfDB’s Compliance Review and Mediation Unit Who: Any two or more people who have been harmed by an AfDB-funded project may submit a Submitting a complaint to the CRMU could: (CRMU), which reports directly to the AfDB’s Boards of Directors. Problem-solving complaint. Local representatives acting on behalf of the affected people may submit a complaint as long help raise awareness about what is happening in In the problem-solving phase, the Director will first conduct an eligibility assessment, including as they provide the names of those they represent. Foreign representation is allowed only when local projects financed by the AfDB, both locally and The IRM has three functions: determining whether the parties agree to participate in a problem-solving process. If eligible, the representation cannot be found. The Boards of Directors can also refer a project to IRM to conduct a internationally; Compliance review focuses on non-compliance with the Bank’s operational Director will then initiate a process that could include mediation, fact-finding or dialogue facilitation, compliance review or spot check exercise. allow you to directly voice your concerns to the AfDB policies and procedures (the ISS) in the design, implementation or supervision of between the complainants and AfDB Management, the company and any other interested party. At about a project; a project. the end of the process, the Director reports to the President and the AfDB Boards on the results of the What: A complaint must relate to current or future serious harm caused by a project that is a result of allow a direct dialogue with the project company Problem-solving is used to resolve the issues raised in a complaint by encouraging problem solving, noting whether there are any issues that should be referred for compliance review. The the AfDB’s failure to follow its own policies and procedures in the design and/or implementation of a through a problem-solving process, if the company the parties involved (complainants, AfDB Management, project company or any President or Boards may either accept or reject the recommendations and a summary is made public. project. The IRM cannot accept complaints alleging human rights violations except those involving social agrees to participate in the process; other parties) to reach agreement on a solution. and economic rights in relation to an action or omission on the part of the Bank. lead to a formal investigation through a compliance Through its advisory functions, the IRM provides opinions on systemic issues related Compliance review review to determine whether or not there have been to the social and environmental impacts of Bank projects and performs spot check If the complaint presents evidence of a violation of Bank policy, the CRMU Director and the IRM Roster When: Affected persons or groups may submit a complaint up to 24 months after the final disbursement violations of AfDB policies; and reviews to assess the compliance of specific high-risk projects with AfDB policies. of Experts may recommend a compliance review, which must be approved by the President or Boards. of the loan or physical completion of the project. lead to action by AfDB leadership to bring the project into The Experts then conduct an investigation to determine whether any AfDB policies were violated during compliance with its policies. The CRMU is headed by a Director, who is chosen for a five-year term that can only the design, implementation or supervision of the project. The investigation may include a site visit and Where: The individuals submitting a complaint must live in the area affected by an AfDB-funded be renewed once. The Director cannot have worked for the AfDB Group for five years meetings with the affected community. The Experts will submit a compliance review report and any project. The complaint may be submitted to the CRMU, located at the AfDB’s headquarters in the Ivory Submitting a complaint to the CRMU cannot: before being appointed, and cannot work for the AfDB again after his or her term ends. recommendations for remedial action to the President or Boards and send a copy to complainants. Coast, or to any AfDB field office. guarantee that harm being caused by an AfDB-supported The Director is also assisted by support staff within the CRMU. project will be stopped or prevented; Bank Management then has 90 days to prepare a response and action plan to address the Why: Submitting a complaint may bring the problem you are facing to the attention of the Board of force a company to participate in a voluntary problem- The IRM is also supported by a Roster of Experts who conduct the compliance review recommendations. Thereafter, Bank Management and the CRMU jointly present the report, response Directors and the President of the AfDB. They have the power to instruct Management to redesign solving process; process. The Roster of Experts includes three independent members, appointed by the and action plan to the Boards or the President, who may either accept or reject the findings and projects to prevent harm, order compensation or remedy the harm inflicted, or cancel the project. attribute blame or lead to findings that a company or the AfDB Boards of Directors, who serve for a five year, non-renewable term. The CRMU may recommendations. The decision is shared with the parties and published on the AfDB’s website. The IRM Bringing a complaint may also create a record of the Bank’s violations, which may help the AfDB to AfDB is ‘guilty’; or also hire outside consultants to assist with investigations and fact-finding missions. will monitor the implementation of the approved action plan. prevent future policy violations and may be a useful tool in advocacy campaigns to address problems. guarantee that the CRMU will conduct an investigation. 1 2 3 4 5
How to file Overall strategic considerations Community considerations prior to submitting a complaint Write the complaint File the complaint Follow up on your complaint a complaint Consider the benefits of a complaint, as well as Determine the scope of the community experiencing The complaint should include: You may submit the complaint in your local language, Once the complaint has been submitted, if limitations of the IRM, and set appropriate expectations. harm and assess whether those people fully understand The date, name and signatures of the affected people; whether they if you are not able to submit your complaint in English you do not hear from the CRMU within 14 The following step-by-step Consider whether another strategy might be more and support a complaint process. If they do not, consider wish their identities to remain confidential and if so why; and the name or French. Submit the complaint via email or mail to: days, check with them to ensure that the guide explains the process effective or efficient. Using the IRM is most effective whether it would be useful to conduct training for the of any representatives assisting the affected people, with a signed letter process is moving along. Compliance Review and Mediation Unit (CRMU) that affected groups and when combined with other strategies, including: affected group. confirming their authority to represent them. African Development Bank It is often helpful to speak to members of their representatives can engaging with the media; seeking campaign support If possible, any community divisions should be resolved A brief description of the project and, if possible, the policies and/or 01 P.O. Box 1387 -Abidjan 01, Cote d’Ivoire the Board, as they will ultimately decide 2nd Floor, CCIA Building, Abidjan Plateau follow to submit a complaint. from other organisations; government advocacy; or early on so that they do not undermine the process. procedures that have been violated. Avenue Jean-Paul II what to do with the CRMU’s report. The There are various tools other tactics. Problem-solving is most effective when the affected An explanation of the harm, or expected harm, resulting from the AfDB T +225 20 26 29 56 Board may ask the CRMU to monitor any available for assistance. The Understand the time and resources required to complete community speaks with one voice. project. Email: [email protected] changes to the project as a result of the IRM of the AfDB, as well as the IRM process, which might take several years. Decide who will speak on behalf of the affected An outline of the change you would like to see as a result of the CRMU If you are unable to submit a written complaint, compliance review. SOMO and Accountability Consider whether beginning an IRM complaint process community during the complaint process; how decisions process. contact the CRMU and they will assist you to submit If the compliance review concludes that the Counsel, can provide advice could place the affected group at risk of retribution during the process will be made; what the desired A description of any communication with Bank staff regarding the issue(s) the complaint in writing. The complaint may also Bank has violated its rules, ensure the Board and additional information or intimidation. Consider the need for confidentiality outcomes are; whether the dialogue could produce raised in the complaint. be submitted to your country’s field office. follows through with any commitments about submitting a and develop a strategy in advance about how to those outcomes and how; and which issues will take Supporting materials, such as correspondence with Bank staff and a Information on the location of the field offices can made to remedy the harm (or potential complaint. address risks. priority in the dialogue process. description of the location of the affected area. be found here: http://www.afdb.org/en/countries/. harm) of the project.
The Independent Review Mechanism process General information Once the CRMU receives a complaint, the Director conducts a review within 14 days to assess whether The about the IRM the complaint raises legitimate claims of harm stemming from a Bank-funded project. If this criterion is met, the Director then registers the complaint and asks AfDB Management to submit a response who, what, when, where, and why Benefits and limitations The IRM was created to provide communities with an effective tool through within 21 days. The Director then initiates either problem-solving or compliance review, based on the which they can request that the AfDB comply with its policies and procedures. complainants’ stated preference. If complainants request both functions, the problem-solving will be of filing a complaint of the mechanism The IRM handles complaints about both public and private sector operations, undertaken first. The Director then informs the President and the Boards of Directors of the decision. and is administered by the AfDB’s Compliance Review and Mediation Unit Who: Any two or more people who have been harmed by an AfDB-funded project may submit a Submitting a complaint to the CRMU could: (CRMU), which reports directly to the AfDB’s Boards of Directors. Problem-solving complaint. Local representatives acting on behalf of the affected people may submit a complaint as long help raise awareness about what is happening in In the problem-solving phase, the Director will first conduct an eligibility assessment, including as they provide the names of those they represent. Foreign representation is allowed only when local projects financed by the AfDB, both locally and The IRM has three functions: determining whether the parties agree to participate in a problem-solving process. If eligible, the representation cannot be found. The Boards of Directors can also refer a project to IRM to conduct a internationally; Compliance review focuses on non-compliance with the Bank’s operational Director will then initiate a process that could include mediation, fact-finding or dialogue facilitation, compliance review or spot check exercise. allow you to directly voice your concerns to the AfDB policies and procedures (the ISS) in the design, implementation or supervision of between the complainants and AfDB Management, the company and any other interested party. At about a project; a project. the end of the process, the Director reports to the President and the AfDB Boards on the results of the What: A complaint must relate to current or future serious harm caused by a project that is a result of allow a direct dialogue with the project company Problem-solving is used to resolve the issues raised in a complaint by encouraging problem solving, noting whether there are any issues that should be referred for compliance review. The the AfDB’s failure to follow its own policies and procedures in the design and/or implementation of a through a problem-solving process, if the company the parties involved (complainants, AfDB Management, project company or any President or Boards may either accept or reject the recommendations and a summary is made public. project. The IRM cannot accept complaints alleging human rights violations except those involving social agrees to participate in the process; other parties) to reach agreement on a solution. and economic rights in relation to an action or omission on the part of the Bank. lead to a formal investigation through a compliance Through its advisory functions, the IRM provides opinions on systemic issues related Compliance review review to determine whether or not there have been to the social and environmental impacts of Bank projects and performs spot check If the complaint presents evidence of a violation of Bank policy, the CRMU Director and the IRM Roster When: Affected persons or groups may submit a complaint up to 24 months after the final disbursement violations of AfDB policies; and reviews to assess the compliance of specific high-risk projects with AfDB policies. of Experts may recommend a compliance review, which must be approved by the President or Boards. of the loan or physical completion of the project. lead to action by AfDB leadership to bring the project into The Experts then conduct an investigation to determine whether any AfDB policies were violated during compliance with its policies. The CRMU is headed by a Director, who is chosen for a five-year term that can only the design, implementation or supervision of the project. The investigation may include a site visit and Where: The individuals submitting a complaint must live in the area affected by an AfDB-funded be renewed once. The Director cannot have worked for the AfDB Group for five years meetings with the affected community. The Experts will submit a compliance review report and any project. The complaint may be submitted to the CRMU, located at the AfDB’s headquarters in the Ivory Submitting a complaint to the CRMU cannot: before being appointed, and cannot work for the AfDB again after his or her term ends. recommendations for remedial action to the President or Boards and send a copy to complainants. Coast, or to any AfDB field office. guarantee that harm being caused by an AfDB-supported The Director is also assisted by support staff within the CRMU. project will be stopped or prevented; Bank Management then has 90 days to prepare a response and action plan to address the Why: Submitting a complaint may bring the problem you are facing to the attention of the Board of force a company to participate in a voluntary problem- The IRM is also supported by a Roster of Experts who conduct the compliance review recommendations. Thereafter, Bank Management and the CRMU jointly present the report, response Directors and the President of the AfDB. They have the power to instruct Management to redesign solving process; process. The Roster of Experts includes three independent members, appointed by the and action plan to the Boards or the President, who may either accept or reject the findings and projects to prevent harm, order compensation or remedy the harm inflicted, or cancel the project. attribute blame or lead to findings that a company or the AfDB Boards of Directors, who serve for a five year, non-renewable term. The CRMU may recommendations. The decision is shared with the parties and published on the AfDB’s website. The IRM Bringing a complaint may also create a record of the Bank’s violations, which may help the AfDB to AfDB is ‘guilty’; or also hire outside consultants to assist with investigations and fact-finding missions. will monitor the implementation of the approved action plan. prevent future policy violations and may be a useful tool in advocacy campaigns to address problems. guarantee that the CRMU will conduct an investigation. 1 2 3 4 5
How to file Overall strategic considerations Community considerations prior to submitting a complaint Write the complaint File the complaint Follow up on your complaint a complaint Consider the benefits of a complaint, as well as Determine the scope of the community experiencing The complaint should include: You may submit the complaint in your local language, Once the complaint has been submitted, if limitations of the IRM, and set appropriate expectations. harm and assess whether those people fully understand The date, name and signatures of the affected people; whether they if you are not able to submit your complaint in English you do not hear from the CRMU within 14 The following step-by-step Consider whether another strategy might be more and support a complaint process. If they do not, consider wish their identities to remain confidential and if so why; and the name or French. Submit the complaint via email or mail to: days, check with them to ensure that the guide explains the process effective or efficient. Using the IRM is most effective whether it would be useful to conduct training for the of any representatives assisting the affected people, with a signed letter process is moving along. Compliance Review and Mediation Unit (CRMU) that affected groups and when combined with other strategies, including: affected group. confirming their authority to represent them. African Development Bank It is often helpful to speak to members of their representatives can engaging with the media; seeking campaign support If possible, any community divisions should be resolved A brief description of the project and, if possible, the policies and/or 01 P.O. Box 1387 -Abidjan 01, Cote d’Ivoire the Board, as they will ultimately decide 2nd Floor, CCIA Building, Abidjan Plateau follow to submit a complaint. from other organisations; government advocacy; or early on so that they do not undermine the process. procedures that have been violated. Avenue Jean-Paul II what to do with the CRMU’s report. The There are various tools other tactics. Problem-solving is most effective when the affected An explanation of the harm, or expected harm, resulting from the AfDB T +225 20 26 29 56 Board may ask the CRMU to monitor any available for assistance. The Understand the time and resources required to complete community speaks with one voice. project. Email: [email protected] changes to the project as a result of the IRM of the AfDB, as well as the IRM process, which might take several years. Decide who will speak on behalf of the affected An outline of the change you would like to see as a result of the CRMU If you are unable to submit a written complaint, compliance review. SOMO and Accountability Consider whether beginning an IRM complaint process community during the complaint process; how decisions process. contact the CRMU and they will assist you to submit If the compliance review concludes that the Counsel, can provide advice could place the affected group at risk of retribution during the process will be made; what the desired A description of any communication with Bank staff regarding the issue(s) the complaint in writing. The complaint may also Bank has violated its rules, ensure the Board and additional information or intimidation. Consider the need for confidentiality outcomes are; whether the dialogue could produce raised in the complaint. be submitted to your country’s field office. follows through with any commitments about submitting a and develop a strategy in advance about how to those outcomes and how; and which issues will take Supporting materials, such as correspondence with Bank staff and a Information on the location of the field offices can made to remedy the harm (or potential complaint. address risks. priority in the dialogue process. description of the location of the affected area. be found here: http://www.afdb.org/en/countries/. harm) of the project.
The Independent Review Mechanism process General information Once the CRMU receives a complaint, the Director conducts a review within 14 days to assess whether The about the IRM the complaint raises legitimate claims of harm stemming from a Bank-funded project. If this criterion is met, the Director then registers the complaint and asks AfDB Management to submit a response who, what, when, where, and why Benefits and limitations The IRM was created to provide communities with an effective tool through within 21 days. The Director then initiates either problem-solving or compliance review, based on the which they can request that the AfDB comply with its policies and procedures. complainants’ stated preference. If complainants request both functions, the problem-solving will be of filing a complaint of the mechanism The IRM handles complaints about both public and private sector operations, undertaken first. The Director then informs the President and the Boards of Directors of the decision. and is administered by the AfDB’s Compliance Review and Mediation Unit Who: Any two or more people who have been harmed by an AfDB-funded project may submit a Submitting a complaint to the CRMU could: (CRMU), which reports directly to the AfDB’s Boards of Directors. Problem-solving complaint. Local representatives acting on behalf of the affected people may submit a complaint as long help raise awareness about what is happening in In the problem-solving phase, the Director will first conduct an eligibility assessment, including as they provide the names of those they represent. Foreign representation is allowed only when local projects financed by the AfDB, both locally and The IRM has three functions: determining whether the parties agree to participate in a problem-solving process. If eligible, the representation cannot be found. The Boards of Directors can also refer a project to IRM to conduct a internationally; Compliance review focuses on non-compliance with the Bank’s operational Director will then initiate a process that could include mediation, fact-finding or dialogue facilitation, compliance review or spot check exercise. allow you to directly voice your concerns to the AfDB policies and procedures (the ISS) in the design, implementation or supervision of between the complainants and AfDB Management, the company and any other interested party. At about a project; a project. the end of the process, the Director reports to the President and the AfDB Boards on the results of the What: A complaint must relate to current or future serious harm caused by a project that is a result of allow a direct dialogue with the project company Problem-solving is used to resolve the issues raised in a complaint by encouraging problem solving, noting whether there are any issues that should be referred for compliance review. The the AfDB’s failure to follow its own policies and procedures in the design and/or implementation of a through a problem-solving process, if the company the parties involved (complainants, AfDB Management, project company or any President or Boards may either accept or reject the recommendations and a summary is made public. project. The IRM cannot accept complaints alleging human rights violations except those involving social agrees to participate in the process; other parties) to reach agreement on a solution. and economic rights in relation to an action or omission on the part of the Bank. lead to a formal investigation through a compliance Through its advisory functions, the IRM provides opinions on systemic issues related Compliance review review to determine whether or not there have been to the social and environmental impacts of Bank projects and performs spot check If the complaint presents evidence of a violation of Bank policy, the CRMU Director and the IRM Roster When: Affected persons or groups may submit a complaint up to 24 months after the final disbursement violations of AfDB policies; and reviews to assess the compliance of specific high-risk projects with AfDB policies. of Experts may recommend a compliance review, which must be approved by the President or Boards. of the loan or physical completion of the project. lead to action by AfDB leadership to bring the project into The Experts then conduct an investigation to determine whether any AfDB policies were violated during compliance with its policies. The CRMU is headed by a Director, who is chosen for a five-year term that can only the design, implementation or supervision of the project. The investigation may include a site visit and Where: The individuals submitting a complaint must live in the area affected by an AfDB-funded be renewed once. The Director cannot have worked for the AfDB Group for five years meetings with the affected community. The Experts will submit a compliance review report and any project. The complaint may be submitted to the CRMU, located at the AfDB’s headquarters in the Ivory Submitting a complaint to the CRMU cannot: before being appointed, and cannot work for the AfDB again after his or her term ends. recommendations for remedial action to the President or Boards and send a copy to complainants. Coast, or to any AfDB field office. guarantee that harm being caused by an AfDB-supported The Director is also assisted by support staff within the CRMU. project will be stopped or prevented; Bank Management then has 90 days to prepare a response and action plan to address the Why: Submitting a complaint may bring the problem you are facing to the attention of the Board of force a company to participate in a voluntary problem- The IRM is also supported by a Roster of Experts who conduct the compliance review recommendations. Thereafter, Bank Management and the CRMU jointly present the report, response Directors and the President of the AfDB. They have the power to instruct Management to redesign solving process; process. The Roster of Experts includes three independent members, appointed by the and action plan to the Boards or the President, who may either accept or reject the findings and projects to prevent harm, order compensation or remedy the harm inflicted, or cancel the project. attribute blame or lead to findings that a company or the AfDB Boards of Directors, who serve for a five year, non-renewable term. The CRMU may recommendations. The decision is shared with the parties and published on the AfDB’s website. The IRM Bringing a complaint may also create a record of the Bank’s violations, which may help the AfDB to AfDB is ‘guilty’; or also hire outside consultants to assist with investigations and fact-finding missions. will monitor the implementation of the approved action plan. prevent future policy violations and may be a useful tool in advocacy campaigns to address problems. guarantee that the CRMU will conduct an investigation. 1 2 3 4 5
How to file Overall strategic considerations Community considerations prior to submitting a complaint Write the complaint File the complaint Follow up on your complaint a complaint Consider the benefits of a complaint, as well as Determine the scope of the community experiencing The complaint should include: You may submit the complaint in your local language, Once the complaint has been submitted, if limitations of the IRM, and set appropriate expectations. harm and assess whether those people fully understand The date, name and signatures of the affected people; whether they if you are not able to submit your complaint in English you do not hear from the CRMU within 14 The following step-by-step Consider whether another strategy might be more and support a complaint process. If they do not, consider wish their identities to remain confidential and if so why; and the name or French. Submit the complaint via email or mail to: days, check with them to ensure that the guide explains the process effective or efficient. Using the IRM is most effective whether it would be useful to conduct training for the of any representatives assisting the affected people, with a signed letter process is moving along. Compliance Review and Mediation Unit (CRMU) that affected groups and when combined with other strategies, including: affected group. confirming their authority to represent them. African Development Bank It is often helpful to speak to members of their representatives can engaging with the media; seeking campaign support If possible, any community divisions should be resolved A brief description of the project and, if possible, the policies and/or 01 P.O. Box 1387 -Abidjan 01, Cote d’Ivoire the Board, as they will ultimately decide 2nd Floor, CCIA Building, Abidjan Plateau follow to submit a complaint. from other organisations; government advocacy; or early on so that they do not undermine the process. procedures that have been violated. Avenue Jean-Paul II what to do with the CRMU’s report. The There are various tools other tactics. Problem-solving is most effective when the affected An explanation of the harm, or expected harm, resulting from the AfDB T +225 20 26 29 56 Board may ask the CRMU to monitor any available for assistance. The Understand the time and resources required to complete community speaks with one voice. project. Email: [email protected] changes to the project as a result of the IRM of the AfDB, as well as the IRM process, which might take several years. Decide who will speak on behalf of the affected An outline of the change you would like to see as a result of the CRMU If you are unable to submit a written complaint, compliance review. SOMO and Accountability Consider whether beginning an IRM complaint process community during the complaint process; how decisions process. contact the CRMU and they will assist you to submit If the compliance review concludes that the Counsel, can provide advice could place the affected group at risk of retribution during the process will be made; what the desired A description of any communication with Bank staff regarding the issue(s) the complaint in writing. The complaint may also Bank has violated its rules, ensure the Board and additional information or intimidation. Consider the need for confidentiality outcomes are; whether the dialogue could produce raised in the complaint. be submitted to your country’s field office. follows through with any commitments about submitting a and develop a strategy in advance about how to those outcomes and how; and which issues will take Supporting materials, such as correspondence with Bank staff and a Information on the location of the field offices can made to remedy the harm (or potential complaint. address risks. priority in the dialogue process. description of the location of the affected area. be found here: http://www.afdb.org/en/countries/. harm) of the project.
The Independent Review Mechanism process General information Once the CRMU receives a complaint, the Director conducts a review within 14 days to assess whether The about the IRM the complaint raises legitimate claims of harm stemming from a Bank-funded project. If this criterion is met, the Director then registers the complaint and asks AfDB Management to submit a response who, what, when, where, and why Benefits and limitations The IRM was created to provide communities with an effective tool through within 21 days. The Director then initiates either problem-solving or compliance review, based on the which they can request that the AfDB comply with its policies and procedures. complainants’ stated preference. If complainants request both functions, the problem-solving will be of filing a complaint of the mechanism The IRM handles complaints about both public and private sector operations, undertaken first. The Director then informs the President and the Boards of Directors of the decision. and is administered by the AfDB’s Compliance Review and Mediation Unit Who: Any two or more people who have been harmed by an AfDB-funded project may submit a Submitting a complaint to the CRMU could: (CRMU), which reports directly to the AfDB’s Boards of Directors. Problem-solving complaint. Local representatives acting on behalf of the affected people may submit a complaint as long help raise awareness about what is happening in In the problem-solving phase, the Director will first conduct an eligibility assessment, including as they provide the names of those they represent. Foreign representation is allowed only when local projects financed by the AfDB, both locally and The IRM has three functions: determining whether the parties agree to participate in a problem-solving process. If eligible, the representation cannot be found. The Boards of Directors can also refer a project to IRM to conduct a internationally; Compliance review focuses on non-compliance with the Bank’s operational Director will then initiate a process that could include mediation, fact-finding or dialogue facilitation, compliance review or spot check exercise. allow you to directly voice your concerns to the AfDB policies and procedures (the ISS) in the design, implementation or supervision of between the complainants and AfDB Management, the company and any other interested party. At about a project; a project. the end of the process, the Director reports to the President and the AfDB Boards on the results of the What: A complaint must relate to current or future serious harm caused by a project that is a result of allow a direct dialogue with the project company Problem-solving is used to resolve the issues raised in a complaint by encouraging problem solving, noting whether there are any issues that should be referred for compliance review. The the AfDB’s failure to follow its own policies and procedures in the design and/or implementation of a through a problem-solving process, if the company the parties involved (complainants, AfDB Management, project company or any President or Boards may either accept or reject the recommendations and a summary is made public. project. The IRM cannot accept complaints alleging human rights violations except those involving social agrees to participate in the process; other parties) to reach agreement on a solution. and economic rights in relation to an action or omission on the part of the Bank. lead to a formal investigation through a compliance Through its advisory functions, the IRM provides opinions on systemic issues related Compliance review review to determine whether or not there have been to the social and environmental impacts of Bank projects and performs spot check If the complaint presents evidence of a violation of Bank policy, the CRMU Director and the IRM Roster When: Affected persons or groups may submit a complaint up to 24 months after the final disbursement violations of AfDB policies; and reviews to assess the compliance of specific high-risk projects with AfDB policies. of Experts may recommend a compliance review, which must be approved by the President or Boards. of the loan or physical completion of the project. lead to action by AfDB leadership to bring the project into The Experts then conduct an investigation to determine whether any AfDB policies were violated during compliance with its policies. The CRMU is headed by a Director, who is chosen for a five-year term that can only the design, implementation or supervision of the project. The investigation may include a site visit and Where: The individuals submitting a complaint must live in the area affected by an AfDB-funded be renewed once. The Director cannot have worked for the AfDB Group for five years meetings with the affected community. The Experts will submit a compliance review report and any project. The complaint may be submitted to the CRMU, located at the AfDB’s headquarters in the Ivory Submitting a complaint to the CRMU cannot: before being appointed, and cannot work for the AfDB again after his or her term ends. recommendations for remedial action to the President or Boards and send a copy to complainants. Coast, or to any AfDB field office. guarantee that harm being caused by an AfDB-supported The Director is also assisted by support staff within the CRMU. project will be stopped or prevented; Bank Management then has 90 days to prepare a response and action plan to address the Why: Submitting a complaint may bring the problem you are facing to the attention of the Board of force a company to participate in a voluntary problem- The IRM is also supported by a Roster of Experts who conduct the compliance review recommendations. Thereafter, Bank Management and the CRMU jointly present the report, response Directors and the President of the AfDB. They have the power to instruct Management to redesign solving process; process. The Roster of Experts includes three independent members, appointed by the and action plan to the Boards or the President, who may either accept or reject the findings and projects to prevent harm, order compensation or remedy the harm inflicted, or cancel the project. attribute blame or lead to findings that a company or the AfDB Boards of Directors, who serve for a five year, non-renewable term. The CRMU may recommendations. The decision is shared with the parties and published on the AfDB’s website. The IRM Bringing a complaint may also create a record of the Bank’s violations, which may help the AfDB to AfDB is ‘guilty’; or also hire outside consultants to assist with investigations and fact-finding missions. will monitor the implementation of the approved action plan. prevent future policy violations and may be a useful tool in advocacy campaigns to address problems. guarantee that the CRMU will conduct an investigation. and exploitation andavoidance ofchildlabour. national legalrequirements. This includes protection from abuse workers’ rightsshouldbeprotected andremain consistent with Maintains that OS5 LabourConditions,Healthand Safety:Maintainsthat efficiently usingnaturalresources, especiallyenergyandwater. health and the environment; andsetsaframeworkfor related pollutantsthatcouldhaveadverseeffects onhuman and Resource Efficiency: Aims to manageandreduce project- OS4 PollutionPrevention andControl, Hazardous Materials biodiversity and ecosystemservices. should implementmeasures tominimiseimpactsand restore When direct andindirect impactsare unavoidable, they services. services. clients should avoid impacts on biodiversity and ecosystem clients shouldavoidimpactsonbiodiversityandecosystem Establishes that OS3 BiodiversityandEcosystemServices:Establishesthat project. their standard ofliving,andshare in thebenefitsof compensation orresettlement assistanceto improve avoided, peopleshouldbetreated fairly, receive when physicaloreconomic resettlement cannotbe OS2 impacts. minimising aproject’s environmental andsocial Establishes the importance of determining and Establishes the importance ofdetermining and OS1 Environmental andSocialAssessment: impacts. Guidelines cover the following: impacts. Guidelines cover thefollowing: assessments and minimising adverse community assessments andminimisingadverse community its clientsregarding socialandenvironmental Involuntary Resettlement: Aimstoensure that, The OSsetoutthe Bank’s expectationsfrom are expected to bereleased soon. and Social Impact Assessment (IESIA) Guidelines and SocialImpactAssessment(IESIA)Guidelines Procedures (ESAP)andIntegratedEnvironmental and newEnvironmental and Social Assessment includes a set ofOperationalSafeguards (OS), against harmfrom AfDBprojects. TheISS vulnerable groups andthe environment rules fortheprotection oflocalpopulations, Safeguards System(ISS),whichsets out In 2013,the AfDB released anewIntegrated Key AfDBrules United StatesofAmerica San Francisco,CA94108 Street,244 Kearny Floor6 Accountability Counsel – andtodemandremedies where rightsare violated–through theuseofnon-judicialaccountabilityoffices. projects. AccountabilityCounselhelpscommunitiestovoicetheircomplaintsaboutprojects thataffect them financeddevelopment environmental byinternationally andhumanrightswhentheyhavebeenharmed Accountability Counselisanon-profit legalorganisation thatsupportscommunitiestodefendtheir Counsel About Accountability The Netherlands 1018 GLAmsterdam Sarphatistraat 30 Centre forResearch onMultinationalCorporations Stichting OnderzoekMultinationaleOndernemingen SOMO go towww.grievancemechanisms.org. experience adverseimpactsontheirhumanrightsasaresult ofbusinessactivities.Formore information, improve theaccessibilityandeffectiveness ofnon-judicialgrievancemechanismsforstakeholderswho problems, exploitationandinequality. SOMO’s Rights,RemedyandAccountabilityProgramme aimsto fair globaleconomicdevelopmentandtheeliminationofstructuralcausespoverty, environmental SOMO isanindependent,non-profit research andnetworkorganisation thatpromotes sustainableand About SOMO grievance. Thisbrochure brieflyexplainshow. individuals whoarebyanAfDB-supportedproject harmed canusetheIRMprocess toaddress their and howtofileacomplaint.Civilsocietyorganisations, workers,communitiesandgroups of This brochure provides abriefoverviewoftheworkAfDB’s IndependentReviewMechanism brochure this About Affairs ortheAfricanDevelopmentBank. sole responsibility ofSOMOandAccountability Counselandcaninnowaybetakentoreflect theviewsofDutchMinistry ofForeign This publicationismade possiblewithfinancialassistancefrom theDutchMinistryofForeign Affairs. Thecontentofthispublicationisthe www.accountabilitycounsel.org [email protected] T +14152966761 www.somo.nl [email protected] T +31206391291
GRAPHIC DESIGN: JUSTAR.NL African Development Bank Mechanismofthe The IndependentReview
revised in2015. This brochure covers IRM policy, as infrastructure. hydropower, agriculture or sectors rangingfrom transportation, environmental impactsofprojects in Complaints mayrelate tothesocial and implementation of its projects. procedures duringthedesignand the AfDB follows itsownpoliciesand The IRMwasdesignedtomakesure that funded bytheAfDBGroup. or whoare likely tobeharmed,byaproject two or more peoplewhohavebeenharmed, address complaintsmade byanygroup of was establishedbytheAfDB in 2004to The Independent Review Mechanism(IRM) Ivory Coast. The Bank’s headquartersare locatedinAbidjan, progress ofits54Africanmembercountries. sustainable economicdevelopmentandsocial The bank’s mission is tocontribute to the established in 1964 aspart of the AfDB Group. The AfricanDevelopmentBank(AfDB)was Mechanism oftheAfrican Independent Review About the Development Bank