Arne Hoel, World Bank


CAO exists to help ensure that people’s voices are heard, and responded to, when they have concerns regarding the environmental and social impact of IFC and MIGA projects. For this process to work, it is critically important that people can raise their voices in safety. CAO has experienced many cases in which people have reported that they do not feel safe to raise concerns. This may stop them from seeking help. Or it may mean that they feel threatened once they do.

An impacted individual’s ability to express concerns freely, and without fear, is essential for the effective functioning of accountability mechanisms like CAO, as well as for the development process in general.

CAO developed its Approach to Responding to Concerns of Threats and Instances of Reprisals in CAO Operations in response to concerns voiced by human rights organizations and to address operational challenges in CAO cases. The Approach focuses on CAO’s own operations and sets out guidance for CAO staff and consultants on how to handle situations involving threats and incidents of reprisals targeting individuals engaged, or seeking to engage, in a CAO process.

Links to the Approach in: English

CAO released the finalized Approach in April 2018 during the 2018 World Bank Group Spring Meetings after a period of consultation and external inputs which extended from April 2016 through to December 2017. CAO started operationalizing the Approach in advance of the launch, conducting internal training with an external expert and developing guidance materials for staff and consultants.

Far from being a static document, the Approach is a learning instrument and work in progress that can be improved over time and adjusted according to new insights and experience. CAO acknowledges the invaluable contribution that individuals and organizations with experience and expertise in the field can bring to the Approach, and will seek ongoing feedback and guidance from all stakeholders, including community members, NGOs, government and company representatives.

CAO started to develop the Approach following the release of Human Rights Watch’s “At Your Own
Risk” Report, which raised the issue of the ineffectiveness of the World Bank Group’s approach to retaliation against people who speak up against World Bank Group projects, or participate in complaints processes. The challenges set out in the report resonated with CAO, which had encountered the issue of threats and reprisals as a challenge in its operations.


CAO released a draft Approach during the WBG/IMF 2016 Spring Meetings, and actively sought inputs through its network. CAO also posted the Approach and a call for inputs on the Business and Human Rights Resource Center website, and solicited feedback through the site’s newsletter. During the public consultation process, CAO received inputs and feedback from about 20 NGOs focused in the field of human rights defenders and international accountability, as well as from representatives of UN human rights bodies and expert academics. These include Accountability Counsel, the Center for International Environmental Law (CIEL), Front Line Defenders, the Office of the United Nations High Commissioner for Human Rights (OHCHR), and Themis Research.   CAO also discussed the Approach with IFC management, and shared it with the World Bank Group President before releasing the finalized Approach.

The Approach benefited greatly from the substantial inputs received during the consultation phase.  A summary of consultation and expert inputs, and how CAO addressed them in the Approach, is available here.  CAO formally released the finalized Approach at a stakeholder roundtable during the World Bank Group Spring Meetings in April 2018, with special guest Zeid Ra’ad Al Hussein, UN High Commissioner for Human Rights.

In the Approach, CAO has committed to report information about threats and reprisals in its operations in aggregate annually. In FY2019, complainants in 36 percent of cases shared concerns with CAO about reprisal risks, up from 23 percent in FY2018. These reports were most prevalent in cases from East Asia and the Pacific, where complainants in 50 percent of cases from the region raised reprisals concerns, followed by Sub-Saharan Africa, and Europe and Central Asia (both 42 percent). Threats were also reported in cases in Latin America and North Africa. In over 55 percent of reprisal risk cases, complainants reported that threats emanated from government authorities. In 44 percent of cases, complainants reported threats from the company, while in a few cases the source was unknown.

Different types of threats and reprisals have been reported to CAO. People have said they experienced warnings, demotion, damage to personal property, and physical assault. Others report being questioned at the workplace about the content of meetings with CAO. One person has reported being followed and receiving anonymous phone calls. Retaliation risks have also been reported to CAO in the context of outreach activities. Here, concerns were raised mostly by international civil society groups regarding the safety of potential complainants and safeguarding their confidentiality.

Guide for Independent Accountability Mechanisms on Measures to Address the Risk of Reprisals in Complaint Management: A Practical Toolkit
This report from the network of Independent Accountability Mechanisms (IAMnet) provides guidance and tools for mechanisms when they encounter situations of risks or incidents of threat and reprisal in their work.