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

A joint submission by Accountability Counsel, the Center for International Environmental Law, and Friends of the Earth to the U.S. Secretary of State, urging caution regarding the endorsement of project-level grievance mechanisms (PLGMs) and providing a framework for their effective implementation within the U.S. National Action Plan on Responsible Business Conduct.

• The authors identify several fundamental flaws in project-level grievance mechanisms (PLGMs), noting they are often managed by the same actors who may have caused the harm. These flaws include a lack of expertise to handle serious human rights abuses, a lack of independence and trust due to conflicts of interest, an absence of third-party oversight, and the creation of barriers to other judicial or non-judicial remedies.
• PLGMs often fail to protect users from reprisals and lack meaningful community participation in their design and monitoring, which can lead to a lack of local trust and a failure to account for cultural or project-specific factors.
• To be effective, the authors argue that PLGMs must be legitimate and independent of the influence of project management. They suggest housing these mechanisms in external entities like NGOs or community institutions and requiring the creation of grievance redress funds or insurance to guarantee compensation.
• Accessibility requirements for PLGMs should include providing informational materials in all primary local languages, conducting verbal outreach for illiterate populations, and ensuring that the use of a PLGM does not impede or require prior use before seeking other judicial or non-judicial remedies.
• The submission emphasizes the need for equitability and transparency, recommending that users have access to independent legal counsel and that companies maintain a publicly available case register. The authors specifically urge the U.S. government to prohibit 'blanket confidentiality' requirements that prevent public monitoring of the mechanism's effectiveness.
• The authors recommend that the U.S. government implement a comprehensive inter-agency policy on PLGMs. Specifically, they suggest that the U.S. Department of the Treasury only approve IFI policies meeting these criteria, federal export promotion and development agencies only rely on compliant PLGMs, and the U.S. National Contact Point for the OECD Guidelines evaluate PLGMs based on these standards.

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} }