Addressing Threats & Reprisals in CAO Cases: Accountability in Focus
CAO’s Head of Dispute Resolution, Nokukhanya Ntuli, explains the measures CAO takes to minimize and mitigate the threat of reprisals to complainants.
What sorts of reprisals are you seeing in CAO’s casework?
Reprisals can include compromising a person’s current standing in the workplace or their future employment prospects, their loss of reputation in the community, threats of physical violence, and even criminalization or incarceration. Understandably, people’s concerns for the safety and well-being of themselves or their family can prevent them from filing complaints to seek redress for impacts arising from projects. The changing nature of the investment landscape has seen a shift in the nature of threats and reprisals. For example, in recent years we’ve seen an escalation in complaints relating to labor issues. And as IFC increases its investment in microfinance, a new type of reprisal has emerged—the intimidation of defaulters on loans.
What’s the scale of the challenge?
The dangers of threats and reprisals are real and documented: in fiscal year 2026, 43 percent of cases handled by CAO included some concerns of threats and reprisals, 38 percent of which allegedly originated with the company involved, 38 percent with public authorities, and a further 14 percent with some combination of the two. In the remaining 10 percent, other community members, sometimes in combination with the company, were perceived as the source of the threat.
How does CAO address the issue?
We’ve developed a set of tools to mitigate the dangers of threats and reprisals to complainants. One critical measure is a regular and ongoing risk assessment that considers such risk factors as the environment for public participation and the types of risks typical in the country or regional context. Protecting the confidentiality of the complainants enables them—and future complainants—to feel entirely secure in the privacy and safety of the process. We also work to generate a supportive environment that addresses the power imbalances inherent in the process. Internally, we have developed a risk rating framework and escalation and response protocols, making our staff more proactive.
What happens when these measures fail?
Despite these measures, reprisals and other security incidents may recur. In such circumstances, CAO will discuss an appropriate course of action with the people concerned, and assess what steps are feasible within the limits of our mandate and capacity to physically protect complainants or safeguard people from possible consequences. We’re learning how to find the right balance between our responsibilities and our limitations, from our own practice and by engaging with other ideas, independent experts, and other stakeholders and actors like the other development finance institutions and civil society
How do you prepare IFC staff and communities to address concerns of threats and reprisals?
In 2018 we published our Approach in Responding to Concerns of Threats and Instances of Reprisals in CAO Operations, to provide guidance for staff and consultants. In 2024, after an independent review of this approach, we enhanced our website to improve access to information for complainants; provide opportunities for knowledge-sharing and learning; and improve how staff and consultants approach risk assessment and safety in the field.
