Strengthening IAMs: Lessons from Palm Oil Accountability

Community resistance and development finance failures

In West Kalimantan, Indonesia, Indigenous communities displaced by palm oil operations began to organize against the ongoing land grabs and environmental destruction carried out by the Wilmar Group, a powerful agribusiness conglomerate and one of the world’s top four traders in palm oil. As plantations expanded across their customary lands, residents protested the illegal seizure of forests, the degradation of ecosystems vital to their livelihoods, and the loss of land that had been stewarded by their communities for generations. Despite limited resources, they mobilized, documented harms, and began seeking channels of accountability for the violence done to their land and rights.

The Wilmar Group had long been a recipient of development finance, despite a broader track record of environmental degradation and labor rights violations. Since 2003, the International Finance Corporation (IFC), the private sector arm of the World Bank Group, invested millions into a series of the company’s investment projects. But Wilmar’s palm oil operations in Indonesia quickly drew criticism, with multiple formal complaints from affected Indigenous communities in Indonesia emerging after the IFC investments (in 2007, 2008 and 2011). These complaints detailed the Wilmar Group’s serious environmental and social abuses, including inadequate compliance with IFC operating procedures and due diligence requirements, illegal land grabs, and violations of national oil regulations.

From a CAO complaint to settlement 

In the first of these complaints, community members in West Kalimantan demanded that the company halt operations on the ground while proper environmental impact assessments were conducted.  Their efforts gained the attention of several local and international civil society organizations (CSOs). By allying with CSOs, Indigenous communities were able to advocate for their land rights and work to find solutions to the environmental issues they faced due to the Wilmar Group’s actions in the region.

The West Kalimantan community partnered with several organizations including the Forest Peoples Programme (FPP), a human rights organization that supports forest-dwelling peoples in securing their rights to land, livelihoods, and cultural survival. The FPP assisted affected community members in filing a complaint through the IFC’s accountability mechanism, the Compliance Advisor Ombudsman (CAO). The CSO conducted field investigations into the abuses perpetrated by Wilmar Group, alleging that a number of social and environmental violations had occurred, including the following: 

• "Illegal use of fire to clear lands
• Clearance of primary forests
• Clearance of areas of high conservation value
• Take over of Indigenous peoples’ customary lands without due process
• Failure to carry out free, prior and informed consultations with Indigenous peoples leading to broad community support
• Failure to negotiate with communities or abide by negotiated agreements
• Failure to establish agreed areas of smallholdings
• Social conflicts triggering repressive actions by companies and security forces
• Failure to carry out or wait for approval of legally required environmental impact assessments
• Clearance of tropical peat and forests without legally required permits."

These violations were compounded by failures on the part of the IFC. Despite years of documented concerns and publicly available evidence of Wilmar’s harmful practices, the IFC continued to classify its investments in Wilmar as low-risk “Category C” projects - a designation that bypassed the need for full environmental and social assessments. As noted in the complaint, this raised serious questions about the IFC’s due diligence, its transparency, and its commitment to responsible development finance. 

Through the CAO’s intervention, a dialogue process was initiated between Wilmar and the affected communities. Wilmar temporarily halted further land clearance while the CAO facilitated capacity-building and negotiation processes with the community representatives, CSOs and the company. After several rounds of dialogue, a settlement agreement was reached in late 2008. The settlement recognized the community’s rights over 1,493 hectares of land and established terms including: 

• Community access and use of land not yet converted to plantations
• Compensation for households whose land had been appropriated
• Community investment funds to support collective development and community opportunities.

Palm oil complaints and IAM outcomes

The Wilmar-01/West Kalimantan case demonstrates how Independent Accountability Mechanisms (IAMs) within international development banks can help yield tangible outputs for communities. Preliminary research conducted by Stanford students for Accountability Counsel analyzed 1,648 complaints in the Console database, including 120 complaints categorized under the Agribusiness sector. Within this group, we examined complaint status and CSO support. 

In the Console, a case is considered ‘closed with outputs’ when the IAM process completes at least one substantive phase (compliance review or dispute resolution) with a tangible output (e.g. a published compliance report or an agreement between parties). In our analysis, it was clear that the Agribusiness: Palm Oil sub-sector stood out: nearly all of its complaints were closed with outputs, making it an exception among agribusiness complaints overall (see Figure 1). 

Figure 1 shows the total number of complaints, complaints closed with outputs, and complaints closed without outputs across all Agribusiness sub-sectors

While almost every other Agribusiness sub-sector had at least half its complaints ‘closed without outputs’, Palm Oil had none. Although it accounts for a relatively small number of complaints overall, 83% of its complaints were closed with outputs, and the remaining 17% are still active. Why do complaints in the Palm Oil sub-sector seem to do better than others? 

The role of civil society support

One possible explanation is the high level of CSO involvement. Despite the relatively small number of complaints in the Palm Oil sub-sector, they show the highest rates of support from both international CSO (ICSO) and local CSO (LCSO) (see Figure 2). 

Figure 2 shows the percentage of complaints in each sub-sector that were supported by LCSOs and/or ICSOs

An analysis of Agribusiness complaints on the Console reveals a strong correlation between civil society involvement and successful complaint outputs. Among all Agribusiness sub-sectors, Palm Oil stands out: it has both the highest rate of CSO involvement, at 83% (Figure 2) and the fewest complaints closed without outputs (Figure 1). In contrast, the Irrigation sub-sector shows the opposite trend - with no complaints supported by CSOs (Figure 2), and 17 of 19 complaints closed without outputs (Figure 1). This contrast suggests that CSO involvement may play a key role in driving complaint outputs. 

While Palm Oil is a smaller sub-sector, the consistency of its complaint outcomes - and the high level of CSO engagement - points to a pattern worth further exploration. Accountability Counsel’s broader research across 2,397 IAM complaints reinforces this pattern, showing that while only 11.6% of cases had CSO support, these complaints accounted for over half (56.8%) of all commitments made by development banks. Civil society support may be instrumental in helping communities file stronger complaints, navigate accountability processes, and reach meaningful outcomes. While this pattern points to a strong correlation, CSO involvement is likely one of several factors influencing whether a complaint results in outputs. 

In the case of Indonesia: Wilmar-01/West Kalimantan, the community members filing the complaint received a significant amount of support from the FPP, as well as other CSOs. These CSOs conducted field investigations, supported community members throughout their complaints process, and publicly documented Wilmar’s harm, which would have been helpful to their cases. 

However, the need for sustained CSO involvement to result in outcomes for communities reflects a deeper issue: IAM processes remain complex and inaccessible, often requiring expert navigation that should not fall solely on communities experiencing harm. The Wilmar case illustrates what is possible when communities receive the support they need, but also what must change to make accountability truly community-centered and accessible to all. 

Reducing barriers and strengthening support

To help ensure more complaints result in outputs that can advance accountability and justice, and to shift IAMs towards community-centered practice, the following should be considered: 

1. Reform IAM processes to be more accessible for all communities

The complexity of IAM processes often creates a reliance on CSOs for navigation, documentation and engagement. While CSO support can be valuable, it should not be a prerequisite for justice. IAMs must simplify procedures, reduce technical and language barriers, and ensure processes are culturally appropriate and transparent. Reforms should focus on enabling communities to engage directly, without needing intermediaries. Support should also be directed toward building the capacity of communities themselves. 

2. Strengthen CSO networks strategically and responsively

Communities should be allowed access to CSO support in IAM cases, and efforts should be made to ensure this support is equitably distributed across regions and sub-sectors. For instance, CSOs should be resourced to support complaints in under-resourced sub-sectors like Agribusiness:Irrigation and Agribusiness:Fertilizer, where few complaints currently reach resolution.

3. Conduct Further Research on structural barriers in IAM access

Deeper research is needed not only on CSO effectiveness, but also on the systematic barriers that make IAMs inaccessible to so many communities in the first place. It is necessary to figure out where there is room for improvement at IAMs to identify gaps and issues in accessibility and reform processes to be more community-centered. 

Conclusion

The Wilmar case in West Kalimantan highlights what is possible when affected communities receive strong support in navigating accountability mechanisms. We can attribute part of their success, and the success of complaints in the Palm Oil sub-sector, to CSO involvement. However, successful outputs for communities should not depend on the presence of expert intermediaries. To make accountability truly accessible, IAMs must simplify procedures, center communities, and dismantle the structural barriers that prevent many from filing complaints or securing remedy. Strengthening support for communities is not just about expanding CSO involvement, but about redesigning these systems to serve those they were created for.