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Independent Accountability Mechanism

Preliminary review

The IAM will acknowledge receipt of all complaints. This will trigger a preliminary review of the complaint against eligibility criteria and exclusions identified in the Policy and Procedures to determine whether the complaint is eligible for further processing.

  • If a complaint is deemed eligible:

It will be registered, relevant parties will be notified, and FinDev Canada management will provide a response. All reasonable efforts will be made to resolve the complaint which may include dispute resolution or compliance review.

  • If a complaint is deemed ineligible:

Relevant parties will be notified and the complaint will be closed.

Dispute resolution

The purpose of the IAM dispute resolution function is to help resolve a complaint through a neutral and collaborative approach, and to contribute to improved outcomes at a community level.

The methods or approaches that may be applied by the IAM when conducting dispute resolution include:

  •      Consultative dialogue;
  •      Information sharing between the parties;
  •      Joint fact-finding; and
  •      Conciliation or mediation by a neutral third party appointed by the IAM.

The outcome of a successful dispute resolution will be reflected in a written agreement or a series of written agreements as appropriate between relevant parties.

The IAM will conduct annual monitoring of any commitments made within the agreements until implemented.

Compliance review

The purpose of the IAM compliance review process is to resolve a complaint by carrying out an assessment of FinDev Canada’s compliance with its policies, including assessing whether any actual or potential harm has occurred or could result from non-compliance with such policies. Remedial actions will be recommended where appropriate. Policies pertinent to the IAM include the Environmental and Social (“E&S”) Policy and the Transparency & Disclosure Policy.

A compliance review assessment will be completed to determine the eligibility of the complaint for a compliance review. If a review is recommended, it may include the following:

  •      Document review;
  •      Meetings;
  •      Discussions;
  •      Site visits;
  •      Evidence gathering; and
  •      Obtaining expert opinions, as appropriate.


A compliance review process will conclude with a final report, recommendations and a management action plan if applicable.

The IAM will conduct annual monitoring of any agreed-upon management action plans following a compliance review.

Who can submit a complaint

A complainant(s) directly


A representative, authorized by the complainant(s) to act in that capacity


A complaint can be submitted to the IAM through several means:


A complaint may be submitted in any language the complainant(s) choses and may be written or recorded. All complaints will be translated into English and French if not submitted in those languages. Persons or entities seeking advice on how to prepare and submit a complaint may contact the IAM directly.

What to include in a complaint

Complaints at a minimum should include the following information:

  • The complainant’s name(s), address(s), and other contact information;
  • If a representative is acting on behalf of a complainant(s), they should identify on whose behalf the complaint is made. The representative should also present evidence that they have been requested and authorized to present the complaint on behalf of the complainant(s);
  • Whether the complainant(s) requests that the IAM keep their identity or any information communicated as part of the complaint confidential;
  • The identity and nature of the related FinDev Canada transaction;
  • A detailed description of the alleged harm, whether actual or potential, caused to the complainant(s) and how, in their opinion, FinDev Canada is responsible for that harm; and
  • A description of: 

                     - Any good faith efforts the complainant(s) has made with Management and/or the client(s) to address

                       the issues raised in the complaint and a description of the results of those efforts; or

                     - An explanation why such efforts were not undertaken.

  • Confirmation that the complaint is not frivolous, fraudulent or malicious, nor is the complaint arising out of or connected to a conflict of interest motivated by an intention to gain competitive advantage.



Where possible, it is also helpful to include:

  • A description of the outcomes the complainant(s) is looking to achieve through the use of the IAM process; and
  • Whether the complainant(s) has an interest in exploring dispute resolution or compliance review to address the issues raised in the complaint.


Complainants may use the Complaints Form to file a complaint online, or the PDF Complaints Form to file a complaint by mail (see address in "Who can submit a complaint" paragraph above).