Submission for U.S. National Action Plan on Responsible Business Conduct regarding Project-Level Grievance Mechanisms

The submission argues that project-level grievance mechanisms (PLGMs) are often fundamentally flawed due to a lack of independence and oversight, and urges the U.S. government to exercise caution before endorsing them. The authors recommend that any supported PLGMs must adhere to the UN Guiding Principles' effectiveness criteria, including legitimacy, accessibility, predictability, equitability, transparency, rights compatibility, continuous learning, and engagement.

• Project-level grievance mechanisms (PLGMs) are often fundamentally flawed because they are designed and operated by the same project management that may have perpetrated the harm, leading to a lack of independence and trust.
• PLGMs are considered inappropriate for addressing serious human rights abuses, including torture, rape, and extrajudicial killings, as they lack the necessary expertise and authority.
• The use of PLGMs can create barriers to other forms of remedy through the use of confidentiality clauses and legal waivers, which limit a victim's ability to escalate claims or raise awareness.
• To ensure legitimacy, PLGMs should function independently of project management, potentially by being housed in NGOs, think-tanks, or community institutions, and should be backed by grievance redress funds or insurance.
• Accessibility requires that PLGMs provide informational materials and outreach in all primary languages spoken by affected people, including verbal outreach for illiterate populations.
• To maintain transparency and public confidence, the U.S. government should prohibit blanket confidentiality requirements and require the maintenance of a publicly available case register.
• Effective monitoring of PLGMs requires independent third-party auditors who conduct unannounced site visits and interview affected people without company or agency representatives present.

APA

Center for International Environmental Law (2015). Submission for U.S. National Action Plan on Responsible Business Conduct regarding Project-Level Grievance Mechanisms. https://www.ciel.org/wp-content/uploads/2015/08/4.24.2015-NAP-submission_AC-CIEL-FoE.pdf

Chicago

Center for International Environmental Law. Submission for U.S. National Action Plan on Responsible Business Conduct regarding Project-Level Grievance Mechanisms. 2015. https://www.ciel.org/wp-content/uploads/2015/08/4.24.2015-NAP-submission_AC-CIEL-FoE.pdf.

Wikipedia

{{cite press release |author=Center for International Environmental Law |title=Submission for U.S. National Action Plan on Responsible Business Conduct regarding Project-Level Grievance Mechanisms |date=24 April 2015 |url=https://www.ciel.org/wp-content/uploads/2015/08/4.24.2015-NAP-submission_AC-CIEL-FoE.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centerforinternationalenvironmentallaw2015submission, author = {{Center for International Environmental Law}}, title = {{Submission for U.S. National Action Plan on Responsible Business Conduct regarding Project-Level Grievance Mechanisms}}, publisher = {Center for International Environmental Law}, year = {2015}, month = apr, url = {https://www.ciel.org/wp-content/uploads/2015/08/4.24.2015-NAP-submission_AC-CIEL-FoE.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }