FMO, don’t shirk your responsibilities to the ultimate beneficiaries of your projects — local communities.

  • Despite investing heavily in non-English speaking contexts, 0% of projects disclosed included translations of basic or technical project information;
  • 0% of projects disclosed technical documents, including environmental and social impact assessments (ESIAs), non-technical summaries, or stakeholder engagement plans; and
  • Only 24% of projects were disclosed with a summary of their potential impacts, and only 9% presented details on how harms could be prevented.

FMO has a responsibility to the communities who bear the impact of its investments.

While FMO’s statement attempts to shift this responsibility to its clients, as a financial institution with a development mandate, majority-owned by the Dutch government, and operating with public money, FMO has an obligation to ensure that its investments protect and fulfill the rights of communities. Such obligations cannot be transferred to private entities at the will of a public institution, generating a clear conflict of interest. As a bank operating with public resources, FMO’s disclosure policies and practices should be aligned with fulfilling the right to information, which acknowledges communities’ right to know about potential projects that will affect them — instead of falsely assuming that it is the bank’s prerogative to decide what information will be disclosed. Additionally, as a development bank, FMO should seek to fulfill communities’ human right to development which requires the meaningful participation — and leadership — of communities in the development process.

FMO should seek to lessen the already enormous barriers to access that communities face — not add to them.

FMO’s statement lists out the institution’s approach to disclosure of information, including its objectives for disclosure. Given the findings of our analysis, it is not surprising that not a single objective recognizes the goal of disclosure as ensuring communities are able to access information and meaningfully participate in the development process. FMO’s response exposes its lack of a people-centered approach. The work of IAP and our partners have repeatedly shown the immense barriers to access faced by communities — our experiences have also demonstrated that communities’ legitimacy and local expertise can better the design of potential projects, anticipating and mitigating adverse impacts, to build projects that result in positive development outcomes. In pursuing true development, FMO should be seeking to enable community access to information and participation as a fundamental goal. Implementing our collective recommendations, including creating an information request mechanism, will assist FMO in taking the first steps to achieve this goal of dismantling existing barriers to access. FMO’s efforts should be driven by recognition of the very real power imbalances faced by communities, and pursue both proactive and reactive channels of disclosure that are accessible to the communities impacted by the bank’s operations.

FMO should model international best practice.

As an influential investor, FMO’s disclosure practices matter. This visual analysis of FMO’s portfolio illustrates the global reach and scope of FMO’s investments. The institution should be modeling best practice on access to information — including disclosing environmental and social documents, publishing regular updates, and making translations available. FMO should not be relying upon its clients to fulfill communities’ right to information, but should instead be meeting the standards set internationally, setting the bar high, and become a global leader in transparency and access to information.

Explore FMO’s portfolio of investments, including risk category and sector, in our interactive visualization here.

If FMO is committed to following IFC’s lead on disclosure, it cannot apply IFC’s Performance Standards in isolation.

In its statement, FMO says it follows IFC’s Performance Standards in its approach to disclosure of information. However, IFC’s Performance Standards form one component of its core Sustainability Framework — they work in tandem with IFC’s Access to Information Policy, which governs the institution’s responsibilities for disclosure. Applying one without the other is incoherent. If FMO is truly committed to following IFC’s lead on disclosure, it should, at minimum, apply IFC’s Access to Information Policy which includes requirements for the Bank’s role in upholding transparency, including detailed ex-ante disclosure. Ideally, FMO should create its own Access to Information Policy based on the internationally endorsed principles on access to information.



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IAP is a human and environmental rights organization that works with communities, civil society and social movements to change how today’s development is done.