PCM (EBRD)

→ Visit the PCM website

The Project Complaint Mechanism
of the European Bank for
Reconstruction and Development

On this page you will find:
– a brief history
– an overview of some key mandate and procedure points of the current version of the Project Complaint Mechanism:

1- The complaint
– Who can submit a complaint?
– How must complaints be submitted?
– What must complaints include and take into account?
2- Registration and Eligibility Assessment
– Registration criteria
– Procedure triggered by the Registration (Paras 18-23)
– Next phase: Eligibility Assessment
– Eligibility criteria
– Eligibility Assessment Report
– Effect of the registration and/or eligibility of a complaint on the project at issue
– Decision on the conduct of a problem-solving initiative (PSI)
3- The Problem-Solving Initiative (PSI) procedure
– Purpose
– Outcome
– Follow-up
4- The Compliance Review (CR) procedure
– Purpose
– Conduct of CR
– Outcome
– Monitoring

– direct links to the relevant EBRD website pages

 

« The Project Complaint Mechanism (« PCM ») provides an opportunity for an independent review of complaints from one or more individual(s) or Organisation(s) concerning a Project which allegedly has caused, or is likely to cause, harm. The goal is to enhance the EBRD’s accountability through the PCM’s two functions: • the Problem-solving function, which has the objective of restoring a dialogue between the Complainant and the Client to resolve the issue(s) underlying a Complaint without attributing blame or fault; and • the Compliance Review function, which seeks to determine whether or not the EBRD has complied with Relevant EBRD Policy in respect of an approved Project. » (*)

A brief history of EBRD’s grievance mechanism

The EBRD grievance mechanism was created in April 2003 as the « Independent Recourse Mechanism », whose mandate was « to assess and review complaints about EBRD-financed projects, to determine whether the Bank has acted properly in accordance with its policies and procedures, or to develop an effective process for resolving the problem raised in the complaint. » (1) It had from the start two functions, a problem-solving function and a compliance review function, under the responsibility of the Chief Compliance Officer. Between 2005 and 2008, the IRM received 5 requests; three were considered ineligible, one triggered a compliance review —Request 2007/01, Vlore Thermal Power Generation Project—, and one a problem-solving exercise —Request 2007/2, BTC Pipeline (Georgia-Atskuri). (2)
The IRM was revised in 2008-2009 and replaced by the Project Complaint Mechanism (PCM). (3) This major revision resulted in the creation of the PCM Officer, much clearer and comprehensive Rules of Procedure and a wider access to the EBRD’s grievance mechanism. The PCM Rules of Procedure were updated in May 2014. (4) This update does not result in significant procedural changes but intends to clarify a number of provisions of the Rules of Procedure.

The latest version to date: the 2014 Project Complaint Mechanism

The 2014 version of the PCM Rules of Procedure remains very close to the 2009 version. The PCM is headed by the PCM Officer, who is responsible for « outreach and training, maintenance of the PCM website and Register, Registration of Complaints, selection of PCM Experts to determine eligibility, conduct Compliance Reviews and/or Problem-solving Initiatives, monitoring and reporting on the implementation of follow up activities, reporting to the President and the Board on an annual basis and on such other occasions as may be necessary, and communications with the local communities, civil society organisations, and other accountability mechanisms. » (Para. 56) The PCM Officer is appointed by the Bank’s President, has a full-time position and is appointed for a 5-year renewable mandate. He/she cannot have worked for the EBRD for at least 2 years before being appointed and cannot work for the EBRD at least 3 years after the end of her/his mandate. (Para. 58)
The PCM Officer is assisted by Experts. They are appointed by the Board on the recommendation of the President and to the roster for a 3-year renewable term. They cannot have worked for the EBRD for at least 2 years before being appointed and cannot work for the EBRD at all after the term of their mandate. (Paras. 50 and 51) Experts serve as Eligibility Assessors, Compliance Review Experts, or Problem-solving Experts, and may be responsible, upon delegation by the PCM Officer, for any follow-up and reporting. (Para. 49) Note that under Para. 52, PCM Experts are required to attend training meetings organized by the PCM Officer for up to 5 days each year to enhance their knowledge of the Bank’s policies, procedures and operations and to discuss the functioning of the PCM. Ad hoc Experts can also be hired if no PCM Expert from the roster is available or has the particular specialization required to undertake or complete an assignment. (Para. 53)

The PCM can perform two functions, a Problem-Solving function and a Compliance Review function. Requesters can ask for one or the other or both.

1- The complaint

Who can submit a complaint?

If you seek a Problem-Solving Initiative
You can submit a complaint if you are « One or more individual(s) located in an Impacted Area, or who has or have an economic interest, including social and cultural interests, in an Impacted Area » (Para. 1) The text in italics was added to the 2009 version by the 2014 version.

If you seek a Compliance Review
You can submit a complaint if you are « One or more individual(s) or Organisation(s) » (Para. 2) Hence, as regards compliance review, complainants are not required to live in an impacted area or to have an economic, social or cultural interest in the impacted area.
Confidentiality: The Complaint must identify the individual(s) or Organisation(s) filing the Complaint. « A Complainant who is not an Organisation may ask that the identity of some or all of the individuals be kept confidential. The request for confidentiality, and the reasons for the request, must be submitted with the Complaint. » Para. 4 specifies that « If, however, the PCM Officer reasonably believes that maintaining confidentiality will prevent a review of the Complaint, then the PCM Officer will immediately notify the Complainant and will either agree with the Complainant on how to proceed, or, if agreement on how to proceed is not possible, will terminate the process. »
Authorised Representative: Complainants can submit their complaint with the assistance of an Authorised Representative (see below for details on proof of this authorisation). The Authorised Representative « will be the point of contact for all formal communications between the PCM and the Complainant. The PCM will communicate directly with the Complainant as necessary and appropriate, and shall keep the Authorized Representative and Complainant informed about the status of the Complaint. » (Para. 5)

• How must complaints be submitted?

The complaint must be submitted in writing and must identify the complainants (see above for confidentiality requests). (Para. 3) If complainants have an Authorised Representative, the Authorised Representative « must sign the Complaint and provide written proof (such as signed letter by the Complainant) of the Authorised Representative’s authority to represent and act on behalf of the Complainant in relation to the Complaint. » (Para. 5) The complaint may be submitted in English, Russian, German, French or in any of the official languages of a country in which the EBRD operates. (Para. 6)
A sample complaint form is available here, in Arabic, English and Russian, and you can submit your complaint online.
A PCM User Guide provides a summary of the PCM’s functions and further details the process for submitting a complaint.It is available in Arabic, Armenian, Bosnian, Bulgarian, Croatian, French, Georgian, Mongolian, Romanian, Russian, Serbian, Turkish and Ukrainian.

Complaints can be sent by postal mail to:
Project Complaint Mechanism
Attn: PCM Officer
European Bank for Reconstruction and Development
One Exchange Square
London EC2A 2JN
United Kingdom

or by fax to: +44 20 7338 7633

or by email to: pcm[at]ebrd[dot]com
In this case, the email must include
• an electronic scan of your signature; or,
• if emailed without a scan, you may send the PCM a signed version of the complaint through post, fax, or hand delivery at the same time as sending your email.

Complaints may also be delivered by post or hand, at any one of the EBRD’s Resident Offices, indicating that it is for transmission to the PCM.

• What must complaints include and take into account?

All complaints must specify:
– the identity of the Complainant;
– the identity of the Authorised Representative, if any, and provides proof of the authorisation;
– the contact information for the Complainant and the Authorised Representative, if any, (including residential and/or mailing address and, to the extent possible, telephone number, email address and fax number);
– the name or a description of the Project at issue and describe the harm, or potential harm which the Project has caused, or is likely to cause. (Para. 11)

It is not a required but, as this might help during the eligibility assessment of the complaint, the complainant can usefully give « an indication of which PCM function the Complainant expects the PCM to use to address the issues raised in the Complaint (in particular, whether the Complainant is seeking a Compliance Review, Problem-solving Initiative, or both) » and « an indication of the outcome(s) sought as a result of use of the PCM process » (Para. 25)

In addition:
When a Problem-Solving initiative is requested, the Complaint:
– must relate to a Project where the Bank has provided – and not withdrawn – a clear indication that it is interested in financing the Project (such indication would usually be provided if the Project has been approved by the body which has been delegated authority to give approval or has passed Final Review by the Bank’s Operations Committee); or must relate to a Project where the Bank maintains a financial interest in the Project in which case, the Complaint must be filed within 12 months following the last disbursement date of EBRD funds, or in the case of equity funding, where the Bank has not sold or exited from its investment;
– should describe the good faith efforts the Complainant has taken to address the issues in the Complaint, including with the Bank and/or the Client, and a description of the result of those efforts, or an explanation of why such efforts were not possible. The PCM Officer may waive the requirement that the Complainant make good faith efforts to resolve the issues in the Complaint with the Client if, in his/her view, such efforts would be harmful to the Complainant or futile. (Para. 12)

When a Compliance Review is requested, the Complaint « must relate to a Project that has either been approved for financing by the Board or by the body which has been delegated authority to give approval to the financing of such Project. » (Para. 13) In addition, at the latest the Complaint « must be filed within 24 months after the date on which the Bank ceased to participate in the Project. » (Para. 24b) A description of the EBRD policies that the complainants allege were violated is not required.

In any case, complainants should also provide any available additional information or documentation about the issues raised in their complaint (such as copies of correspondence with the EBRD or project sponsor, maps or reports). This information might prove quite helpful during the eligibility assessment phase but is not a requirement. (Para. 25)

2- Registration and Eligibility Assessment

• Registration criteria

Within 10 days after the receipt of the complaint, the PCM Officer decides on the registration of the request. Requests are registered if they include all necessary information described above in the « What must complaints include? » paragraph and respect the requirements on the stage of its life-cycle the project at issue is, also described above. (project already approved or not, deadlines: Paras. 12-13)
If required elements are missing, the PCM Officer can suspend the registration of the complaint to give time to the complainant to correct the failure. (Paras 15-16) If the Complainant « did not make good faith efforts to address the issues with the Bank and/or the Client and did not provide an explanation of why such efforts were not possible as per Paragraph 12(c), the PCM Officer will, in consultation with the Complainant, forward the Complaint to the relevant department in the Bank to address the issues raised without registering the Complaint at that stage. When good faith efforts have subsequently been made, suspension may be lifted if such efforts, in the opinion of the PCM Officer, have not yielded positive results. » (Para. 17)
In addition, Para. 14 states that a Request will not be registered if:
« a. it raises allegations of fraud [for this, go to the Office of the Chief Compliance Officer page] or relates to procurement matters [for this, go to the Project Procurement Complaints page] (…);
b. it relates to Article 1 of the Agreement Establishing the Bank, the Portfolio Ratio Policy or any other specified policy as may be identified by the Board from time to time;
c. it relates to the adequacy or suitability of EBRD policies;
d. it relates to matters in regards to which a Complaint has already been processed by the PCM or its predecessor IRM, unless there is new evidence or circumstances not known at the time of the previous complaint. »

• Procedure triggered by the Registration (Paras 18-23)

Upon registration, the PCM Officer notifies the parties and « may, in the course of notification, verify with the Complainant or its Authorised Representative, if any, whether the Complainant is seeking a Problem-solving Initiative, a Compliance Review, or both. » The complaint is entered in the PCM Register and a copy is posted on the PCM website.
Registration +5 days: The PCM Officers appoints a PCM Expert « to work jointly with the PCM Officer to conduct an Eligibility Assessment of the Complaint. »
Registration +21 days: The Bank Management must provide its written response to the complaint.
Cooperation with other institutions: « Once the PCM Officer registers a Complaint, if the Project at issue in the Complaint is subject to co-financing by other institutions, the PCM Officer may notify the accountability mechanism(s) of the co-financing institution(s) of the Registration of the Complaint and may communicate and cooperate with the accountability mechanisms of such institution(s) so as to avoid duplication of efforts and/or disruption or disturbance to common parties. Where appropriate, the PCM will consider establishing a written cooperation agreement with the accountability mechanism of co-financing institution(s) addressing such issues as confidentiality and sharing of information. »

• Next phase: Eligibility Assessment

Para. 24 specifies that « An Eligibility Assessment is a preliminary process that must be satisfied before a Complaint is deemed eligible for further processing under the PCM. Based on an evaluation of the eligibility criteria set out below, the Eligibility Assessors determine whether the Complaint is eligible for a Problem-solving Initiative, a Compliance Review, for both, or for neither. At any time during the Eligibility Assessment, the Bank may decide to agree that certain criteria are satisfied in order to expedite the determination of eligibility. The Eligibility Assessors do not judge the merits of the allegations in the Complaint and do not make a judgment regarding the truthfulness or correctness of the Complaint. In making their determination, the Eligibility Assessors take into account the PCM function requested by the Complainant. »
The Eligibility Assessment must be performed no later than 40 days after the submission of the Bank management response to the complaint. (Para. 30)

• Eligibility criteria

In order to be eligible to a Problem-solving Initiative, the complaint must:
« i. be filed by an individual or individuals as referred to in Paragraph 1;
ii. raise issues covered by a Relevant EBRD Policy. » (Para. 24a)
Note that para. 24 a) ii) was added by the 2014 update and that it does not entail that the complaint has to be related to a compliance issue related to a relevant EBRD Policy, but merely that the object of the complaint must be related to the kind of issues covered by the relevant EBRD policies which are the Public Information Policy and the Environmental and Social Policies.
The Eligibility Assessors also consider « whether a Problem-solving Initiative may assist in resolving the dispute, or is likely to have a positive result, in particular:
a. whether the Complainant has raised the issues in the Complaint with the Client’s dispute resolution or grievance mechanism, or with the complaint or accountability mechanism of a co-financing institution, or before a court, arbitration tribunal or other dispute resolution mechanism and, if so, the Eligibility Assessors will also consider the status of those efforts; and
b. whether the Problem-solving Initiative may duplicate, or interfere with, or may be impeded by, any other process brought by the same Complainant (or where the Complainant is a group of individuals, by some members of the group) regarding the same Project and/or issues. » (Para. 26)

In order to be eligible to a Compliance Review, the complaint must « be filed within 24 months after the date on which the Bank ceased to participate in the Project and must relate to a Relevant EBRD Policy. » (Para. 24b; the deadline of 24 months after the end of the Bank’s involvement was added by the 2014 update)
The Eligibility assessors also « consider whether the Complaint relates to:
a. actions or inactions that are the responsibility of the Bank;
b. more than a minor technical violation of a Relevant EBRD Policy unless such technical violation is alleged to have caused harm; and
c. a failure of the Bank to monitor Client commitments pursuant to a Relevant EBRD Policy. » (Para. 27)

Exclusions of eligibility (Para. 28): The complaint will be considered as ineligible if:
« a. it was filed fraudulently or for a frivolous or malicious purpose;
b. its primary purpose is to seek competitive advantage through the disclosure of information or through delaying the Project;
c. or, in the case of a request for a Problem-solving Initiative, the subject matter of the Complaint has been dealt with by the accountability mechanism of any co-financing institution and the PCM Officer is satisfied that the complaint was adequately considered by such accountability mechanism, unless there is new evidence or circumstances not known at the time of the previous complaint. In the event that a Complaint is seeking a Compliance Review, a review by another accountability mechanism will not disqualify the Complaint from being processed under these rules;
d. it relates to the obligations of a third party, such as an environmental authority and the adequacy of their implementation of national requirements, or relating to the obligations of the country under international law or treaty, rather than to issues that are under the control of the Client or the Bank. »

Other criteria and information used in the assessment: Under Para. 29, the Eligibility Assessors take into account « the Bank management response to the Complaint and the Client’s response to the Complaint (if applicable) ». They also « examine key documents and consult with the Relevant Parties. The Eligibility Assessors may also carry out a site visit and employ such other methods as they may deem appropriate. »

• Eligibility Assessment Report

No later than 40 days after the submission of the Bank Management response, the Eligibility Assessors issue an Eligibility Assessment Report which includes:
 » a description of the steps taken in the Eligibility Assessment;
b. a summary of the facts and positions of the Relevant Parties; and
c. a determination of whether the Complaint is eligible for a Problem-solving Initiative, Compliance Review, both (with a decision regarding the order in which they should be conducted), or neither. »

If the Eligibility Assessors conclude that the complaint is ineligible, the Eligibility Assessment Report is submitted to the Board (for Projects already approved by the Board) or to the President (for Projects that do not require Board approval or which have not yet been Board approved) to approve their recommendation that the complaint be closed. If the recommendation is approved, the PCM Officer closes the complaint; if the recommendation is not approved, the Board or President sends the complaint back to the Eligibility Assessors for further consideration. Once the recommendation is approved, the Eligibility Assessment Report and the decision are sent for information to the parties and are publicly released and posted on the PCM website. (Para. 31)
If the Eligibility Assessors find the complaint eligible, the Eligibility Assessment Report must also include the terms of reference for either a Compliance Review, Problem-solving Initiative, or both. Where possible, the Eligibility Assessors consult with parties in the drafting of the terms of reference.
« a. The terms of reference for a Problem-solving Initiative will set out the methods to be used and the time frame for the initiative and will identify the type of expertise required;
b. The terms of reference for a Compliance Review will identify the type of expertise required to carry out the review, as well as the scope and time frame for the review. » (para. 32)

Para. 34 also specifies that if the Eligibility Assessors find the complaint is « ineligible because it fails to meet one or more of the eligibility criteria, and the failure may be remedied, the Eligibility Assessors may suspend issuing their Eligibility Assessment Report and afford the Complainant (…) 10 Business Days to remedy the failure. »

• Effect of the registration and/or eligibility of a complaint on the project at issue

Though by principle the registration/and or the eligibility of a complaint cannot result in the suspension of the Bank’s participation in the project at issue, « if at any time during the processing of a Complaint, the PCM Officer believes that serious, irreparable harm will be caused by the Bank’s continued processing of the Project or disbursements in respect of the Project, the PCM Officer may make an interim recommendation to suspend further Bank processing of the Project, or, if possible, disbursements in respect of the Project. The decision on the recommendation will be made by the body vested with the power to make such a decision and only if the Bank has the right to suspend or cancel its interest in the Project. The PCM Officer’s recommendation and the decision thereon will be noted on the PCM Register » (Para. 35, emphasis added)

• Decision on the conduct of a problem-solving initiative (PSI)

Where a complaint has been held eligible for a PSI, the Eligibility Assessors submit the Eligibility Assessment Report to the President with a recommendation that the PCM undertake a Problem-solving Initiative and the reasons supporting their recommendation. The President decides, within 10 business days whether or not to accept it. If the President approves the recommendation, the Problem-solving Expert begins the PSI as soon as practicable following the President’s decision. (Para. 36)
Note that the Rules of Procedure do not mention any approval requirement regarding compliance review.

3- The Problem-Solving Initiative (PSI) procedure

• Purpose

PSIs « ha[ve] the objective of restoring a dialogue between the Complainant and the Client to resolve the issue(s) underlying a Complaint without attributing blame or fault » (Introduction and purpose, emphasis added)

• Outcome

PSIs are conducted until relevant parties reach an agreement or when the Problem-solving Expert believes no further progress towards resolution of the dispute is possible. The Problem-solving Completion Report describes the issues raised in the Complaint, the methods used in the PSI and the results, including any issues that remain outstanding. (Para. 37)
The PCM Officer circulates the Problem-solving Completion Report for information to all Relevant Parties, as well as to the President and the Board. Within 5 business days of circulation, and if the Relevant Parties so agree, the Problem-solving Completion Report is publicly released and posted on the PCM website. If the Relevant Parties do not agree to the release of the Report due to confidentiality concerns, a summary of the Report is publicly released and posted on the PCM website. (Para. 38)

• Follow-up

The Problem-solving Completion Report identifies the need for any follow-up monitoring and reporting by the PCM Officer. (Para. 37) The PCM Officer is responsible for the monitoring of the implementation of any agreements reached during a PSI. She/he submits draft Problem-solving Initiative Monitoring Reports to the parties, who are given reasonable opportunity to comment on these. If the PCM Officer receives comments from the parties,she/he has 5 business days from the day the last comments are received to finalize the Report and sends the final Report to the President and to the Board. Within 5 business days thereafter, the Problem-solving Initiative Monitoring Report is publicly released and posted on the PCM website.
The PCM Officer issues Problem-solving Initiative Monitoring Reports at least biannually or until she/he determines that monitoring is no longer needed. (Para. 39)

4- The Compliance Review (CR) procedure

• Purpose

Compliance review « seeks to determine whether or not the EBRD has complied with Relevant EBRD Policy in respect of an approved Project » (Introduction and purpose, emphasis added. EBRD policies and procedures are available here)
« The objective of the Compliance Review will be to establish if (and if so, how and why), any EBRD action, or failure to act, in respect of an approved Project has resulted in non-compliance with a Relevant EBRD Policy and, in the affirmative, to recommend remedial changes in accordance with Paragraph 44 of these rules. The Compliance Review may not recommend the award of compensation to the Complainant beyond that which may be expressly provided for in the Relevant EBRD Policy. » (Para. 41)

• Conduct of a CR

Where a Complaint has been held eligible for a Compliance Review, the PCM Officer appoints a PCM Expert, who cannot be the same person as the Eligibility Assessor, to act as the Compliance Review Expert and to conduct the Compliance Review. (Para. 40)
The Compliance Review Expert examines key documents and consults the Relevant Parties. She/he can carry out a site visit and use any other method she/he deems appropriate.
The Compliance Review Expert prepares a « Draft Compliance Review Report, allow the Relevant Parties opportunity to comment, and consider these comments when finalising the Report. » (Para. 42)

• Outcome

If the Compliance Review Reports finds there wasn’t any breach of EBRD policies by the Bank, the Compliance Review Expert submits the Report to all parties and the President or the Board (depending on whether the project requires the Board approval). The complaint is then closed. (Para. 43)

If the Compliance Review Report finds relevant EBRD policies were breached by the Bank, the Compliance Review Report makes recommendations to:
« a. address the findings of non-compliance at the level of EBRD systems or procedures in relation to a Relevant EBRD Policy, to avoid a recurrence of such or similar occurrences; and/or
b. address the findings of non-compliance in the scope or implementation of the Project taking account of prior commitments by the Bank or the Client in relation to the Project; and
c. monitor and report on the implementation of any recommended changes. » (Para. 44)

Regarding the way the Management and the PCM interact at this stage, the Compliance Review Expert communicates the Compliance Review Report to the Management, who elaborates a Management Action Plan which addresses whether the recommendations contained in the draft Compliance Review Report are appropriate and includes a timetable and estimate of the human and financial resources required to implement those recommendations considered appropriate. (Para. 45 a) The Management can also make a response to the CR findings. (Para. 45 b) The Management Action Plan and the Management response to findings must be submitted to the Compliance Review Expert within 30 business days following the receipt of the Report. (Para. 45 c)
The PCM Officer then sends the Compliance Review Report and the Management Action Plan to the Complainant for comments within 20 business days.
Taking account of the Management Action Plan and Complainant’s comments, the Compliance Review Expert can adjust his or her recommendations (but not findings) and issues the final Compliance Review Report to the PCM Officer no later than 15 business days following receipt of the Complainant’s comments. (Para. 45 d)

The PCM Officer then:
« a. submit[s] the Compliance Review Report, the management response to findings, if any, to the Board (if the relevant Project has been approved by the Board at the time the report is submitted), or to the President, to take note thereof;
b. submit[s] the Management Action Plan and the Complainant’s comments on the Management Action Plan to the Board of Directors or the President, as the case may be, who may decide to accept the Management Action Plan or to reject it in whole or in part. In case of rejection, in whole or in part, the Management Action Plan will be returned to Management for appropriate amendments. If the Management Action Plan is sent to the President for approval, it will be simultaneously circulated to the Board for information.
The Compliance Review Report, the approved Management Action Plan and the Complainant’s Comments will be circulated to the Relevant Parties and publicly released and posted on the PCM website. » (Para. 46)

• Monitoring

The PCM Officer is responsible for the monitoring of the implementation of the Management Action Plan. She/he issues Compliance Review Monitoring Reports at least biannually or until she/he determines that monitoring is no longer needed. In the preparation of each report, the PCM Officer consults with the Relevant Parties as appropriate. Compliance Review Monitoring Reports are submitted to the President and to the Board for information and, within 5 business days, are publicly released and posted on the PCM website. (Para. 47)

Links to relevant EBRD PCM website pages

EBRD Policies
Main page of the Project Complaint Mechanism
PCM Register


Notes

 (*) Project Complaint Mechanism, Rules of Procedure 2014, Introduction and purpose, <http://www.ebrd.com/downloads/integrity/pcmrules2014.pdf>

  (1) Decision of the Board of 29 April 2003. The IRM Rules of procedure were adopted on 4 April 2004. See: EBRD, Independent Recourse Mechanism. A guide to making a complaint against an EBRD-financed project, July 2004, <http://www.ebrd.com/downloads/research/policies/irm.pdf>

 (2) IRM register, <http://www.ebrd.com/pages/project/pcm/irmregister.shtml‎>

 (3) EBRD, Project Complaint Mechanism: Rules of Procedure, May 2009, <http://www.ebrd.com/downloads/integrity/pcmrules09.pdf>

 (4) Project Complaint Mechanism, Rules of Procedure 2014, op. cit. On the update see inter alia Project Complaint Mechanism (PCM) Rules of Procedures. Report on the invitation to the public to comment, <http://www.ebrd.com/downloads/integrity/pcm_comments.pdf>; Comments on the European Bank for Reconstruction and Development's Draft Revised Project Complaint Mechanism Rules of Procedure 2014, 6 March 2014, <http://www.accountabilitycounsel.org/wp-content/uploads/2013/05/EBRD-PCM-civil-society-comments-2014.pdf>; CEE Bankwatch Network comments on Project Complaint Mechanism Draft Rules of Procedure 2014, March 2014, <http://bankwatch.org/sites/default/files/comments-EBRD-PCM-06Mar2014.pdf>.