Two fishermen in Kribi, Cameroon prepare their net on the beach, June 2019 (Rodrigue Mbock/CAO).

Annual Report


A Year in Review

Solutions, Accountability & Learning

This year, we tackled challenges to complainant safety through the roll out of our Approach to Threats and Reprisals, and enhanced knowledge of our work through global outreach. We concluded our work in Mongolia following a dispute resolution settlement related to the Oyu Tolgoi mine, in addition to concluding settlements in Albania, Uganda, Chad, and Cameroon. We issued new compliance investigations of projects in Albania and Kenya, and closed three investigations of IFC after monitoring, including the Dinant case in Honduras. We also provided advice to IFC to inform their guidance on involuntary resettlement, and collated findings from our monitoring and evaluation work to assess our effectiveness.

As we approach our 20th year of operations, we are embarking on a Board-led independent review of IFC and MIGA’s accountability framework, including CAO’s role and effectiveness. This will be an opportunity to reflect on CAO’s evolution, and to further strengthen accountability at the World Bank Group and ensure communities are at the heart of its development agenda.

Our Mission

CAO’s mission is to serve as a fair, trusted, and effective independent accountability mechanism and to improve the environmental and social performance of IFC and MIGA, members of the World Bank Group.

Community members from Tiddas, Morocco meet with CAO’s local mediator before the official signing of an agreement with an IFC-supported poultry producer, August 2017 (CAO). CAO is now monitoring implementation of the agreement.
CAO Vice President, Osvaldo L. Gratacós (second from left), and CAO staff visit with herders living near the Oyu Tolgoi mine site, Mongolia, June 2015 (CAO).

Introduction from the Compliance Advisor Ombudsman (CAO)

This year represents my fifth as the CAO Vice President. When I was appointed to the position in 2014, CAO's reputation as a respected and uniquely holistic independent accountability office preceded it. The vision, dedication, and hard work of Dame Meg Taylor, the first CAO, and the level of professionalism and expertise of the CAO team, made the office the standard in accountability amongst multilateral development institutions. I sincerely hope that in my time at CAO we have honored and upheld this reputation.

As I conclude my original appointment term as CAO, and reflect on these five years, I am now only more convinced that independent accountability offices are crucial to international development and to the mandate that development institutions have of doing no harm. Without them, vulnerable communities adversely impacted by development projects may not have an impartial, independent, and safe space to bring their concerns, and their voices may be silenced or ignored. The World Bank Group’s twin goals of eliminating extreme poverty and boosting shared prosperity by 2030 need the unhindered voice of communities to achieve their intended results. In the end, development is about people and respecting their human dignity.

During my tenure at CAO, I have seen first-hand the change in the level of IFC and MIGA’s engagement with our work. I have also witnessed the increasing interest from companies, banks, government and other stakeholders as they seek guidance on environmental and social accountability. I believe this speaks to growing recognition of accountability as a core component of sustainable and responsible development. I am also personally supportive of the recent structural changes announced by IFC’s CEO, Philippe Le Houérou, which recognize the importance of institutional accountability, while promoting proactive and consistent actions by management.

For CAO, this past year has been a pivotal one — one that saw substantial case outcomes and continued efforts to advance solutions, accountability, and learning from CAO’s work. Our diverse caseload spanned 35 countries and all major sectors. About half of our cases in active assessment, dispute resolution, and compliance processess, and half are in monitoring. Monitoring extends the timeframe of our cases but enhances outcomes by ensuring that settlements are implemented and compliance findings addressed.

Further, given the importance of institutional accountability — a responsibility that rests primarily with the management of the institution, and not just with the independent accountability mechanisms — the foundation was laid for an external review of IFC and MIGA’s environmental and social accountability framework, including CAO’s role and effectiveness. This will be a focus for the Board, IFC, MIGA, and CAO in the coming year. The review presents an opportunity to strengthen accountability in a way that supports IFC and MIGA’s development goals while ensuring that communities are at the heart of the process.

As we embark on this next phase, I want to thank all those we work with—community members, civil society organizations, IFC and MIGA clients and staff, government and other partners—for placing your trust in CAO and helping us support better project outcomes.

Osvaldo L. Gratacós
Vice President
October 2019

FY2019 Snapshot

We handled 60 cases in 35 countries this year, including 12 new eligible complaints and 48 cases where we continued to assess, mediate, investigate, and monitor issues and outcomes. Since our caseload includes many multi-year, complex engagements, CAO continues to work hard to develop local mediation capacity, enhance our responsiveness, deliver timely reports, and provide effective redress for communities within the constraints of our resources and team.


Concerns Of Threats And Reprisals
Concerns of Threats and Reprisals
More information on CAO’s Approach to Reprisals is available on our website. The Approach is available in English, Spanish, French, Arabic, and Ukrainian, with more translations forthcoming.

Complainants in


of cases shared concerns about reprisal risks

These concerns were most prevalent in cases in

East Asia and the Pacific

Over half of reprisal cases cite

government authorities

as the source of threat

FY2019 Update

When a person is affected by an IFC or MIGA project, it is essential that they are able to raise their concerns freely and without fear.  Since threats and reprisals impact our accessibility and ability to respond to concerns, addressing this issue in CAO’s operations is at the forefront of our work.  This year, we expanded implementation of CAO’s Approach to Threats and Reprisals, which was released in April 2018.  This included rolling out new risk assessment procedures, updated implementation guidelines, and internal support tools on outreach and secure communications. CAO’s approach is now available in English, Spanish, French, Arabic, and Ukrainian, with more translations forthcoming.  We have also been engaging IFC as it operationalizes its Position Statement on Retaliation, which was released in October 2018. The statement commits IFC to take seriously allegations of reprisals and not tolerate any action by an IFC client that amounts to retaliation.

This is the second year we are reporting out data on threats and reprisals in CAO’s operations. 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.  More information on how we are addressing these issues is available on our website.


Exploring Options Together
Understanding the Issues ASSESSMENT
CAO’s mediation team meets with community members during the assessment of a new case in Ukraine, October 2018 (Roman Koval/CAO).

After finding a complaint eligible, we conduct an assessment. This is a crucial step which empowers the parties to decide how best to address their concerns through a CAO process. During the assessment we are in listening and capacity building mode. Our focus is to better understand the issues and different perspectives of the parties, and explain options offered by CAO. Ultimately, the parties can decide to engage in a voluntary dispute resolution process or initiate a compliance review to address the complaint.

Cases in Assessment, FY2019

We completed 10 assessments this year, referring 3 cases to dispute resolution and 7 to compliance. Nine cases were still in assessment at the end of the fiscal year.

Cases in Assessment, FY19 9 ongoing assessments 7 assessments referred to compliance 3 assessments referred to dispute resolution 19 TOTAL CASES HANDLED IN ASSESSMENT FY2019 15 Countries
Note: Chart status as of June 30, 2019

FY2019 Snapshot


We completed the assessment of a case regarding the IFC and MIGA-supported Shuakhevi hydropower plant in Georgia. The plant operator and impacted villagers agreed to address the issues through dispute resolution. The dialogue process is now underway.


We are assessing a case filed by local community members in May 2019 regarding IFC’s investment in Salala Rubber operations in Liberia. This is our first case from Liberia, and raises concerns about land and livelihood loss.


In March 2019, we referred a case related to IFC’s investment in the Condor Gold exploration project in Nicaragua to compliance for appraisal, as the parties did not reach consensus to engage in dialogue.


Parties have agreed to engage in dispute resolution to address resettlement and labor concerns in our second case from Togo regarding the Lomé Container Terminal project, which is supported by IFC.

ASSESSMENT Kenya/Bridge Assessment

Kenya: CAO Assesses Case Regarding IFC Support to Low-Cost Private Schools

Bridge International Academies is Africa’s largest chain of low-cost private schools. Founded in 2007, the company aims to provide affordable, quality education to children from families earning less than US$2 per person per day.

Kenya/Bridge Assessment
The CAO team visits a Bridge school in Kenya during the assessment trip for the case, September 2018 (CAO).

Kenya: CAO Assesses Case Regarding IFC Support to Low-Cost Private Schools

Bridge International Academies is Africa’s largest chain of low-cost private schools. Founded in 2007, the company aims to provide affordable, quality education to children from families earning less than US$2 per person per day.

Since Bridge opened its first school in Nairobi, Kenya in 2009, operations have grown to hundreds of schools across the country, as well as a chain of schools in India, Liberia, Nigeria, and Uganda. In April 2018, CAO received a complaint from the East Africa Centre for Human Rights, a Kenyan NGO, on behalf of 10 current and former parents and teachers at Bridge. The complaint expresses concerns about Bridge’s compliance with international and Kenyan laws, and IFC’s policies, as well as concerns about economic discrimination, parental inclusion, and transparency regarding the operation of the schools.

A CAO team traveled to Kenya in September 2018 to meet with the complainants and Bridge management. CAO visited six Bridge schools located in Nairobi, Homa Bay, Kisumu and Mombasa. With the support of the local CAO mediators and translators, CAO gathered information about the main concerns, which ranged from teachers’ employment conditions to regulatory issues such as lack of registration of schools, use of unqualified teachers, and use of a non-Kenyan curriculum.

While Bridge the company expressed openness to dialogue, there was no consensus to pursue this option among the complainants. As a result, the case was transferred to compliance for an appraisal of IFC’s performance.

Finding Solutions
Through Dialogue
CAO observes a community-company roundtable as part of its exit from the case related to the Patos Marinza oilfield project, Albania, September 2018 (Felix Davey/CAO).

Through dispute resolution, we provide an independent forum for communities and companies to address concerns together and seek joint solutions. This voluntary process is facilitated by our dispute resolution specialists with the support of local mediators, who vest ownership in the process and outcomes with the parties. We document good practice and learning from our work resolving development disputes to benefit practitioners, IFC and MIGA, private sector, and broader development community.

Cases in Dispute Resolution, FY2019

In dispute resolution, 70 percent of our current cases are in full or partial settlement. This includes new settlements reached this year, and cases where we are monitoring implementation of agreements.

FY2019 Snapshot 8 cases being monitored 7 cases in mediation 4 cases closed cases 1 transfered to compliance 20 TOTAL CASES HANDLED IN DISPUTE RESOLUTION FY2019 16 Countries
Note: Chart status as of June 30, 2019

FY2019 Snapshot


We settled a dispute related to the Patos Marinza oilfield project, operated by Bankers Petroleum. Dialogue led to the establishment of community-company working groups to address earthquake damage, environmental concerns, and social investment.

Chad & Cameroon

We are concluding our work on the Chad-Cameroon Pipeline Project after facilitating successful mediations between Exxon subsidiaries and communities living in the oil field development zone.


We are conducting our first dispute resolution process in Myanmar between IFC client, Myanma Awba Group and a local community to address the impacts of a new agro-chemical plant. The parties have agreed to ground rules for the dialogue.


We are facilitating a dialogue process in Uzbekistan to address concerns of forced labor in the cotton sector related to two IFC clients. As part of the process, CAO has also facilitated informational meetings involving IFC with their clients and the complainants.


CAO Launches Dispute Resolution Reflections from Practice Series

To advance dispute resolution practice and contribute to consistency in approach, we’ve launched a series of good practice publications this year based on CAO’s 20 years of experience in this field.

Learn more and explore CAO’s ‘Reflections from Practice’ series at


CAO Launches Dispute Resolution Reflections from Practice Series

To advance dispute resolution practice and contribute to consistency in approach, we’ve launched a series of good practice publications this year based on CAO’s 20 years of experience in this field.

As the first mechanism of our kind among multilateral development banks to offer dispute resolution, our team is at the forefront of using professional mediation skills and innovative techniques to problem-solve and address conflicts between communities and IFC/MIGA project sponsors. The series, ‘Reflections from Practice’, is designed to benefit staff, mediators, and practitioners, as well as meet the growing external demand for CAO’s dispute resolution knowledge. 

The first two publications in this series are ‘Getting Started with Dispute Resolution’ and ‘Representation’.  ‘Getting Started with Dispute Resolution’, provides an overview of the principles that guide the early phase of a CAO Dispute Resolution process, challenges that may arise, and strategies and tools that we employ during this early convening phase.  This phase is important as communities and companies may not have come together in this way before, on the same level, at the same table, and in a context that is collaborative rather than adversarial.  Equally, in our experience, conveners like CAO may need to address issues such as power imbalances, lack of trust, need for negotiation training and determining who represents the parties at the dialogue table, among others.

The second publication, ‘Representation’,  focuses specifically on representation and provides guidance on how to achieve clarity and consensus about who will participate and who will have decision-making power in a dispute resolution process.  CAO cases often involve dozens, and in some cases even thousands, of stakeholders. It is not feasible to regularly convene such large numbers for meetings.  Establishing representation is critical to ensure the legitimacy of the process and that any agreements reached are meaningful and honored.

A third publication in the series, ‘Joint Fact-Finding’ will be released in September 2019.  Learn more and explore the series at

Finding Solutions
Accountability for
Environmental and
Social Performance
Villages east of the port, Lomé, Togo, April 2016 (CAO). CAO released a second monitoring report related to this case in April 2019.

Through compliance, CAO investigates cases that raise substantial concerns about a project’s environmental and social outcomes. Compliance investigations help IFC and MIGA address gaps in the implementation of their environmental and social standards, respond to negative project impacts on local communities, and make systemic improvements to improve performance.

Cases in Compliance, FY2019

In FY2019, our compliance caseload comprised 32 cases in 22 countries. We issued 3 appraisals, 2 new investigation reports, and 7 monitoring reports regarding IFC projects in the agribusiness, mining, financial intermediary, infrastructure, and manufacturing sectors.

Cases in Compliance, FY19 12 cases being monitored 8 cases being investigated 7 cases being appraised 5 cases closed 32 TOTAL COMPLIANCE CASES 22 Countries
Note: Chart status as of June 30, 2019

FY2019 Snapshot


We appraised two labor complaints from Egypt regarding Titan Group cement operations. CAO initiated an investigation of IFC’s performance related to its review and supervision of issues related to retrenchment, occupational health and safety, and forced early retirement.


We published a compliance investigation regarding IFC’s investment in Bidco Africa Ltd., which addresses a complaint from workers. IFC’s response contains a project-level action plan and commits to review Bidco’s labor practices.


We published a second monitoring report related to IFC’s investment in the Lomé Container Terminal. IFC has taken positive steps to address compliance findings related to coastal erosion, including commissioning an environmental audit.


In March 2019, we published a monitoring report regarding IFC/MIGA’s Bujagali Energy Project. The report follows up on two CAO compliance investigations issued in 2017 and 2018 regarding labor and land issues. While IFC has made commitments, CAO noted delays in implementation.


Enhancing Outcomes

To enhance outcomes following a compliance investigation, CAO encourages IFC and MIGA to develop action plans that include both project and systemic level responses to non-compliance findings. CAO also encourages management to consult with project-affected communities, including CAO complainants when developing a response.

CAO conducts a site visit to Bidco manufacturing facilities in Kenya as part of the investigation of IFC’s investment in the project, May 2017 (CAO).


Enhancing Outcomes

To enhance outcomes following a compliance investigation, CAO encourages IFC and MIGA to develop action plans that include both project and systemic level responses to non-compliance findings.

This year, a new procedure was put in place whereby the President of the World Bank Group provides the Board with an opportunity to consider a CAO compliance investigation and IFC or MIGA response prior to their clearance for publication. Following this procedure IFC’s response to CAO’s Enso investigation in Albania included a commitment to work with the client to support implementation of a management plan for the National Park where the IFC supported hydropower project is located, and also to work with local tourism operators to allow rafting on the river at agreed times. IFC’s response to CAO’s Bidco investigation in Kenya included a commitment to enhance supervision of the client’s labor practices. CAO will report back on the effectiveness of these actions in addressing its compliance findings as part of its compliance monitoring function.

Promoting Change
Change and
Prevention of Harm
Through Learning
A dispute resolution process in Myanmar between an IFC-supported fertilizer company and representatives of a local community, June 2018 (CAO). Insights from this case also informed Advisory's guidance on IFC's draft resettlement handbook this year.

Through our advisory function, we gather insights from our dispute resolution and compliance cases to catalyze learning and help enhance IFC and MIGA performance in relation to key environmental and social issues. This work is done with the end goal of improving project outcomes and preventing future harm.

Environmental & Social Issues FY2019

Environmental and social policy compliance continues to be the leading concern raised by complainants in 60 percent of our cases. Community health, displacement, and stakeholder engagement also feature in over 50 percent of all cases.

Complaints typically include multiple environmental and social (E&S) issues. Percentages therefore denote the frequency that each issue was raised in the FY2019 caseload.

  • 60% Policy Compliance
  • 53% Community Health
  • 52%Economic Displacement
  • 52%Stakeholder Engagement
  • 49%Biodiversity & Natural Resources Impact
  • 47%Compensation
  • 45%Pollution
  • 44%Risk Assessment
  • 40%Project Benefits to Community
  • 39% Community Safety & Security
  • 36%Labor
  • 36% Vulnerable Groups
  • 33% E&S Management
  • 32%Asset Damage / Loss
  • 28%Resettlement
  • 24%Social Fabric
Improving Access
Outreach & Knowledge Sharing
CAO facilitates a multi-stakeholder discussion in Tirana, Albania, September 2018 (Felix Davey/CAO).

In keeping with CAO’s mandate of ensuring access to recourse for communities affected by IFC and MIGA projects, our outreach program aims to proactively meet with communities and civil society groups to inform them about our work. We also engage the private sector, government, and other stakeholders with the goal of promoting environmental and social accountability and good practice in relation to grievance redress. In all, we met with over 300 organizations from 50 countries during FY2019.


CAO operations are funded by an administrative budget, which is approved by the President and provided by IFC and MIGA on a cost-sharing basis. CAO also has available a non-conditional supplemental budget allocation and a Mediation/Conflict Resolution Contingency Fund. CAO manages its budget independently. In FY2019, a new procedure was introduced whereby the President will share CAO’s budget request for review, advice and direction with the IFC and MIGA Boards of Executive Directors.


Looking Forward

The next year is a significant one for CAO as we celebrate our 20th anniversary and will be assessing the impact of our work through a retrospective analysis. In addition, we will be engaging in the external review of IFC and MIGA’s environmental and social accountability framework, including CAO’s role and effectiveness. The review, which will be conducted by independent experts reporting to the Board, provides a structured process through which informed decisions can be made to strengthen grievance response and accountability around IFC and MIGA projects. We hope the outcome of the review will be a stronger CAO and institutions that are better prepared to respond to community concerns, with more effective remedy, local impact, and systematic learning resulting from the accountability process.

Over the last 20 years, CAO has consistently sought input from external experts on how we can be a more effective mechanism, and enacted valuable recommendations through updates to our Operational Guidelines in consultation with stakeholders. We welcome proposals to enhance our work and evolve our practice so we can continue to deliver solutions, accountability and learning that benefits communities, IFC and MIGA clients, staff, and other stakeholders—and supports the Bank Group’s strategic goals.

Finding Solutions
A herder near the Oyu Tolgoi mine site in Mongolia, May 2015 (Felix Davey/CAO). The parties to the Oyu Tolgoi case, the Tripartite Council, will continue to collaborate on implementation of agreements after CAO’s exit.

About CAO

The Office of the Compliance Advisor Ombudsman (CAO) is the independent accountability mechanism for the International Finance Corporation (IFC) and the Multilateral Investment Guarantee Agency (MIGA), members of the World Bank Group. CAO’s mandate is to address complaints from people affected by IFC and MIGA projects and to enhance environmental and social project outcomes. CAO reports to the President of the World Bank Group.

Learn more at