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CAO in Numbers

Methodological Attachment

CAO is expanding the way in which data from cases is captured, mined, and structured, to support analysis that will enhance
transparency and improve the performance and outcomes of our work. To that end, CAO in Numbers aims to consolidate historical CAO data while considering changes in CAO’s practice. This methodological attachment provides more information on the data made available and used throughout the piece and clarifies some of the key methodological decisions made along the way.

For any further information, please contact CAO at CAO@worldbankgroup.org

Key Concepts & Definitions

  • Project: Refers to the MIGA guarantee or IFC investment or advisory services product as the unit of measure, identified through a unique project ID. Project information is disclosed on the following websites:

    IFC — https://disclosures.ifc.org/
    MIGA — https://www.miga.org/projects
  • Complaint: CAO receives complaints from any individual, group, or community (who are, at times, supported by NGOs and
    CSOs). When a complaint meets the relevant criteria, it is deemed to be eligible. In some instances, CAO receives multiple
    complaints on a single project, and in others, a single complaint may raise concerns about more than one IFC/MIGA project.

    Complaint is the primary unit of measure reported in this piece. However, it should be noted that the number of complaints alone is a challenging data point when seeking to understand trends about the institutions’ underlying portfolio. For example, a significant concentration of complaints in one region or sector can all relate to just one project. (1)
  • Case: A CAO case is a complaint that is handled by CAO or a compliance process initiated/triggered by CAO/WBG. Some
    complaints on the same IFC/MIGA project are merged by CAO during case-handling, particularly for Compliance review. (2)
  • Fiscal Year: The WBG defines its fiscal year as running from July 1 of a given calendar year to June 30 of the following year. For example, FY21 relates to the time period from July 1, 2020 to June 30, 2021. All of the date ranges and references to years in this publication refer to WBG fiscal year.
  • Triggered complaints: These are complaints that are initiated by the CAO or WBG leadership. As related in the CAO Policy, CAO may initiate a compliance appraisal in response to an internal request from the CAO Director General, the WBG President, Boards, or Management.
  • Received vs. handled: Received means that the text refers to the complaints that have come in during a given year, while
    handled refers to the active caseload in that year, which would include those received that year as well as those received in
    previous years that are still being addressed.
1. For example, this was the case with the Baku Tbilisi-Ceyhan Pipeline (#11251) in the Mining, Oil, Gas & Chemicals sector. CAO received 27 eligible complaints on this one project alone and, as a result, complaints in the Europe & Central Asia region accounted for over 40 percent of CAO’s cases between 2004 and 2011.
2. One example is the Chile: Alto Maipo -01 and -02 case, where two separate complaints were received by CAO—the first in January 2017 and the
second in July 2017. These were handled individually up until the Assessment phase, but once transferred to Compliance, they were merged in
Appraisal and have been handled as a single case through the entirety of the Compliance process—meaning a single Appraisal report and single
Investigation report have been published for both complaints.

How CAO Policy and Practice Impacts Data

As CAO has evolved, changes in its policy and practice impact its data. This means that CAO’s data is not always easily comparable over time. For example, the 2007 edition of Operational Guidelines marked a significant shift in CAO’s complaint-handling process towards a more distinct Assessment, Dispute Resolution, and Compliance case handling structure. The most recent review of CAO’s policy by the Board has led to another significant change in the movement from Operational Guidelines to the CAO Policy, applicable since 1 July 2021. The following table outlines the key policy and practice changes thought CAO’s history.

Data Sources & Interpretation

After a significant shift in CAO’s operational process in 2007 (see Table 1), CAO’s process has remained relatively consistent. This
consistency enables us to present data from 2008 onwards when showing how we handle complaints (How We Handle Complaints, Dispute Resolution, Compliance sections). We can use the full set of data from CAO’s inception in 2000 when reporting information about the complaints we received (Complaints to CAO, Complainants, Outreach, Threats and Reprisals sections

  • CAO Caseload Process Tracking (2001 – 2021): Captures key process indicators, ranging from the complainant type to the start and completion date of each CAO process phase. These are reported at the complaint level and are used as the source of all internal and external CAO reporting.
  • CAO Caseload E&S Issues (2001 – 2021): Tracks the frequency of environmental and social issues reported as they align thematically with the requirements of the Performance Standards (2012 edition). The issues are captured based on the language included in the complaint received (if publicly disclosed) or the text included on the relevant CAO case page (when the original complaint is not disclosed).
  • CAO Monitoring & Evaluation Stakeholder Feedback Surveys (2015 – 2021): These surveys gather specific stakeholder feedback regarding parties’ experiences with CAO processes at two stages: the conclusion of assessment and the conclusion of dispute resolution. While these surveys started in 2009, the results presented here are aggregated from 2015 onwards, to align with the latest set of revisions. The results reflect views of each of the relevant respondent groups and are not weighed at the case level; they are not meant to be representative of the CAO caseload. The category, “complainants, NGO” refers to civil society organization representatives who support or advise complainants during the CAO process.
  • Management Action Tracking Record, or MATR (2015 – 2021): This was developed jointly with IFC/MIGA to track institutional responses to CAO’s interventions. Again, the results aggregated here are from 2015 onwards only, to align with the latest set of revisions.

Methodological Notes

The table below highlights key methodological notes that should be considered in interpreting the data presented in this piece. These are broken down by section of the full CAO in Numbers website.

Section
Time Range
Source
n
Unit
Relevant Notes
New CAO complaints
2001 - 2021
Caseload Process
213
Complaint
Relevant Notes

Year-on-year count (flow) of all eligible complaints received (n=203) and triggered cases (n=10) for the total number of complaints taken in by CAO each year.

Issues of concern
2001 - 2021
Caseload E&S Issues
203
Complaint
Relevant Notes

To create data from complaints, CAO has coded text drawn from publicly disclosed complaints and CAO reporting. The information contained is classified using different indicators (issues) that track the frequency of the environmental & social issues reported as they align thematically with the requirements of the performance standards. When CAO receives complaints that raise issues that span multiple performance standards or are articulated in ways that do not clearly fit a singular performance standard, CAO captures these as cross-cutting issues, to preserve the fidelity of concerns raised. Timeseries—percentage of complaints received* year-on-year that raise the indicator reported (among others) CAO Sector—aggregated count of relevant complaints as they relate to each sector Assessment Outcome—percentage of relevant complaints broken down by assessment outcomes—closed, dispute resolution or compliance Note that the data in this section excludes complaints that are triggered.

The Regions
2001 - 2021
Caseload Process
213
Complaint
Relevant Notes

Countries—aggregated count (stock at End of Year - EoY) of all eligible complaints received and cases triggered Regions—percentage of caseload (stock at EoY) of all eligible complaints received and those triggered. IFC updated the structure of its regions in July 2021. Regions represented in this publication do not reflect this shift given the historical nature of the data.

The Sectors
2001 - 2021
Caseload Process
213
Complaint
Relevant Notes

Percentage of caseload (stock at EoY) of all eligible complaints received and cases triggered

E&S Categories
2001 - 2021
Caseload Process
213
Complaint
Relevant Notes

Percentage of caseload (stock at EoY) of all eligible complaints received and cases triggered. Note, when multiple E&S categories (through multiple projects) are tied to a complaint, the highest risk/impact category is captured by CAO.

Ineligible Complaints
2014 - 2021
Caseload Process
96
Complaint
Relevant Notes

Percentage of ineligible complaints received between 2014 and 2021— in 2014 CAO started capturing and analyzing data on why cases were found ineligible, hence the cutoff.

Complainant Profiles
2001 - 2021
Caseload Process
213
Complaint
Relevant Notes

Percentage of caseload (stock at EoY) of all eligible complaints received and cases triggered

Learning about CAO
2015 - 2021
M&E
136
Respondent
Relevant Notes

Percentage of respondents in relevant category—complainants, community (n=136). Data reports individual responses from the post-assessment stakeholder feedback survey.

Prior Attempts
2015 - 2021
M&E
137
Respondent
Relevant Notes

Percentage of respondents in relevant category—complainants, community (n=137). Data reports individual responses from the post-assessment stakeholder feedback survey.

Filing a Complaint
2015 - 2021
M&E
116
Respondent
Relevant Notes

Percentage of respondents in relevant category—complainants, community (n=116). Data reports individual responses from the post-assessment stakeholder feedback survey.

CAO Outreach
2007 - 2021
Ad-hoc
78, 62
Country
Relevant Notes

Total number of countries reached (participants from the country attended (n=78), and total number of countries where CAO has held or participated in an outreach event (n=62).

Approach to Threats & Reprisals
2018 - 2021
Ad-hoc
101
Case
Relevant Notes

Trend—percentage of all cases handled* each year (flow) since 2018, when CAO started capturing this information. Note that the data in this section reports on cases handled, and hence are counted multiple times if active over multiple years. Sources of Threat—percentage of threats and reprisals raised between 2018 and 2021, broken down by perceived source of threat (as related by the complainant)

Assessment Outcomes
2008 – 2021
Caseload Process
150
Complaint
Relevant Notes

Percentage of complaints that have closed in assessment between 2008 and 2021. Note: data from hereon only includes observations from 2008 onwards, to align with the implementation of the 2007 Operational Guidelines, which marks the most significant change in existing practice—see the CAO Governance section of this methodological attachment for more detail.

Who Chooses Compliance versus Dispute Resolution
2012 – 2021
Caseload Process
64
Complaint
Relevant Notes

Percentage of complaints that have closed in assessment and proceeded straight to compliance between 2012 and 2021. This data is consistently available from 2012 onwards, hence the cutoff.

How is CAO Perceived
2015 – 2021
M&E
126, 43
Respondent
Relevant Notes

Percentage of respondents in relevant category—complainants, community (n=126); company representatives (n=43). Data reports individual responses from the post-assessment stakeholder feedback survey.

Dispute Resolution Cases
2008 – 2021
Caseload Process
74
Complaint
Relevant Notes

Total number of complaints handled in dispute resolution between 2008 and 2021.

Dispute Resolution Elements
2008 – 2021
Caseload E&S Issues
41
Complaint
Relevant Notes

Frequency count of process elements publicly reported in a total of 41 complaints concluded* in dispute resolution since 2008. The process elements are captured based on the language included in the publicly disclosed Close-out/Conclusion report, and hence may be underreported.* Closed here means the dispute resolution process has closed (settled, partly settled, or fully transferred to compliance), and not that the case has closed in dispute resolution.

Dispute Resolution Outcomes
2008 – 2021
Caseload E&S Issues
41
Complaint
Relevant Notes

Frequency count of outcomes observed in a total of 41 complaints closed* in dispute resolution since 2008. The outcomes are captured based on the language included in the publicly disclosed Close-out/Conclusion report, and hence may be underreported. * Closed here means the dispute resolution process has closed (settled, partly settled, or fully transferred to compliance) and not that the case has closed in dispute resolution.

Trust-building in DR
2015 - 2021
M&E
119, 94, 30, 28
Respondent
Relevant Notes

Percentage of respondents in relevant category—post-assessment: complainants, community (n=119) and company representatives (n=30) post-dispute resolution: complainants, community (n=94) and company representatives (n=28); Data combines individual responses from both the post-assessment and post-dispute resolution stakeholder feedback survey.

Settlement Rates
2008 – 2021
Caseload Process
56
Complaint
Relevant Notes

Percentage of complaints that have closed in dispute resolution between 2008 and 2021. Note: data here drops cases that are undergoing dispute resolution or dispute resolution monitoring. * Closed here means the dispute resolution process has closed (settled, partly settled, or fully transferred to compliance) and not that the case has closed in dispute resolution.

Compliance Cases
2008 – 2021
Caseload Process
111, 90
Complaint & Case
Relevant Notes

Total number of complaints handled in compliance between 2008 and 2021 (n = 111). When parallel complaints are combined at appraisal, 90 cases have been handed in compliance over the same time range.

Proceeding to Investigation
2008 – 2021
Caseload Process
107, 87
Complaint & Case
Relevant Notes

Percentage compliance appraisals that proceeded to investigation, again including two versions: the first uses complaints as the unit of measure and the second uses complaints merged into cases as the unit of measure. Note data here drops cases where the appraisal report is pending.

Institutional Responsiveness
2015 - 2021
MATR
18
Case
Relevant Notes

Percentage of compliance cases rated in the MATR, aggregated over six years, excluding observations rated Too Early to Tell. IFC/MIGA response is rated both at the project level and at the systems level and given one of the following ratings for each case: Highly Satisfactory, Satisfactory, Partly Unsatisfactory, Unsatisfactory, Too Early to Tell, or Not Applicable.

Advisory
2001 - 2021
Ad-hoc
40, 29
Product
Relevant Notes

2010 Performance Standards Review—Percentage of recommendations (n=40) made by CAO leading to substantive changes, as noted in IFC’s Response. GRM Toolkit Survey—Percentage of respondents (n=29) from the voluntary survey conducted

Annex. CAO Caselog Fiscal Year 2001 – 2021