1. Project Complaint Mechanism PCM Anoush Begoyan PCM Officer

2. What is PCM ? Accountability mechanism – to enhance accountability and transparency of the Bank; Provides opportunity to individuals, groups and organisations to raise a complaint concerning EBRD-funded project (including TC funds); Replaces Independent Recourse Mechanism (IRM) which was in force since July 2004

3. Brief history of PCM 2008 - January 2009 - Review of IRM, Public Consultation on the First Draft of the Revised PCM Rules of Procedure 6 May 2009 – approval of PCM Rules of Procedures 16 March 2010 – PCM is operational (with appointment of PCM Officer and four PCM Experts)

4. Functions of PCM Problem–solving function – objective is to restore dialogue between the Complainant and the Client to resolve the issue; The Compliance Review function – to determine whether or not, in approving or monitoring a project, EBRD has complied with Relevant EBRD Policy

5. Public Information Policy (PIP); Environmental Policies. ! PCM covers not only the current Environmental and Social Policy 2008, but also previous Environmental policies. Which policies?

6. For Problem-solving initiative – a person or a group located in a project area or having economic interest in the area. For Compliance Review – any person, group or civil society organisation/NGO. Who may submit a complaint?

7. For Problem-solving initiative – after EBRD has clearly expressed interest in funding the project and no later than 12 months after the last disbursement of funds. For Compliance Review – only after the Bank approved the financing of the project (no end date). ! PSDs contain reference to the last date to file a complaint. When a complaint may be submitted?

8. Commitments € billion It is filed fraudulently or for frivolous or malicious purpose; Its purpose is to seek competitive advantage; It raises allegations of fraud or relates to procurement matters (will be forwarded to the appropriate office within the Bank); PCM will not deal with a complaint if:

9. It relates to Article 1 of the Agreement Establishing the Bank, the Portfolio Ration Policy or any other policy identified by the Board; It relates to adequacy or suitability of EBRD policies; or It relates to a complaint which has already been processed by IRM, PCM or accountability mechanism of a co-funding institution (only for Problem-solving).

10. What happens when a complaint is received? Registration Eligibility assessment (if registered) Problem-solving or Compliance Review or both (if eligible)

11. Problem – solving No: Decision is posted on PCM website with Eligibility Assessment Sent to the President for approval (10 business days) Yes: PCM Officer appoints PSI Expert, PSI starts PSI completion: report sent to relevant parties and publicly released Monitoring of the reached agreement, PCM Officer reports annually to the President, the Board and the public

12. Compliance Review Complaint is closed, results published on the website Non-compliance: CR Report with findings and recommendations PCM Officer appoints CR Expert, review process Management Action Plan to PCM (within 30 business days) Compliance Compliance Review Report, monitoring of the Action Plan, publication of results

13. Contact details for EBRD PCM European Bank for Reconstruction and Development One Exchange Square London EC2A 2JN United Kingdom Fax: +44 20 7338 7633 Email: pcm@ebrd.com or Begoyana@ebrd.com List of EBRD Resident Offices is available at: http://www.ebrd.com/pages/about/contacts/r egional.shtml