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.

Links to the Approach in: English

The Approach in its current form reflects consultation inputs received until September 2017.  While already applying many of the good practices set out in the Approach, CAO plans to fully operationalize it by the end of December 2017. CAO will consider comments received during the next two months, which may lead to further improvements in the Approach. 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.

To comment on this Approach, please send your feedback to CAO will report back in aggregate on any comments received before end December 2017 and, if relevant, any resulting changes to the Approach, before it is fully operationalized.

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 sharing this revised version in October 2017.

The Approach benefited greatly from the substantial inputs received during the consultation phase, and CAO is welcoming additional comments on this Approach, including from perspectives or stakeholders who did not provide inputs before. A summary of consultation and expert inputs, and how CAO addressed them in the Approach, is available here.