CAO Cases

Arne Hoel, The World Bank

East Asia & the Pacific

Philippines / Rizal Commercial Banking Corporation (RCBC)-01

Local community members (the complainants) supported by PMCJ, IDI and BIC (NGOs)
Date Filed
October 11, 2017
Climate change, inadequate compensation, health harms, loss of livelihoods, environmental and social management system
Case Status
Open - Compliance


Project Overview

Rizal Commercial Banking Corporation (RCBC or “the client”) is a large universal bank in the Philippines, providing a wide range of banking and other financial products and services, including commercial and retail banking, credit cards, asset management, and treasury and investment banking products and services. IFC has made multiple equity and loan investments to support RCBC. IFC states that its investments aim at supporting RCBC’s growth in the areas of microfinance, small and medium-sized enterprises, and retail banking, as part of IFC’s strategy to support the Philippine financial markets through investments in local financial institutions that play a key role in providing access to finance to underserved sectors.



In October 2017, the national NGO Philippine Movement for Climate Justice (PMCJ), in collaboration with Inclusive Development International (IDI) and Bank Information Center Europe (BIC Europe), submitted a complaint on behalf of several communities living in the proximity of 19 active or proposed coal-fired power plants, located in different parts of the country. The complaint alleges that RCBC has provided financial support to the plants, either directly or through companies that own or operate them. The complaint raises several concerns related to the development and operation of the plants, in the form of localized environmental and social issues, such as impacts on biodiversity, health harms caused by air pollution, inadequate compensation for physical displacement, loss of livelihoods, and violation of indigenous peoples’ rights. Further, the complaint raises issues about climate change impacts on the Philippines and its residents, including the complaint signatories, as well as issues related to RCBC’s environmental and social risk management system, lack of consultation and information about the projects and their impacts, and absence of grievance mechanisms for the affected communities. Finally, the complaint raises issues about IFC, asserting that there is a lack of transparency regarding IFC’s financial intermediary portfolio, and IFC’s monitoring and supervision of RCBC’s environmental and social performance.


CAO Action

CAO determined the complaint eligible in relation to RCBC’s support to 11 coal-fired power plants. Between November 2017 and April 2019, CAO conducted an assessment of the complaint to further understand the issues raised, the client’s response, and whether there was interest between the parties for a CAO-facilitated dispute resolution process. None of the complainant groups reached agreement to engage in a dispute resolution process with the owners of the respective affected coal-fired power plants. Therefore, in accordance with CAO’s Operational Guidelines, the complaint was transferred to CAO’s compliance function.


CAO completed a compliance appraisal of the complaint in October 2019. Following a review of IFC’s documentation, CAO has questions related to application of IFC’s E&S standards to this investment, in particular: (a) whether IFC’s pre-investment E&S review of the client was commensurate to risk and established a realistic expectation that the client would meet IFC’s E&S requirements within agreed timeframes; (b) whether IFC’s supervision of the client, including IFC’s processing of additional investments, included adequate consideration of client implementation of IFC’s E&S requirements and the developing E&S risk profile of the client’s lending; (c) whether IFC responded adequately to project-level E&S concerns raised in the complaint to CAO; and, (d) whether IFC’s approach to its investment was consistent with Sustainability Policy commitments to work with the private sector to address climate change.


Accordingly, CAO has decided to conduct a compliance investigation in response to this complaint.  The scope of the investigation is further defined in terms of reference, which are available at the link below.



CAO will conduct a compliance investigation in response to this complaint.  Terms of reference for the investigation are available at the link below.


Updated as of November 19, 2019

Project information

Project Name & Number
Rizal Commercial Banking Corporation (RCBC) 30235, 32853, 34115, 37489
Financial Markets
Rizal Commercial Banking Corporation (RCBC)
East Asia & the Pacific
Environmental Category
$30m C loan; $149m equity; $75m bond

Case Tracker


  • Eligible: Completed
  • Assessment Period: Completed


  • Under Appraisal: Completed
  • Under Audit: In Process