When IAMs fail women: Gendered harm needs gendered justice

Independent Accountability Mechanisms (IAMs) were created to provide redress for communities harmed by internationally financed development projects. All too often, however, these mechanisms fail to recognize or respond to the gendered nature of harm. Women and girls often experience project-related harm differently, but IAMs follow a one-size-fits-all approach that sidelines gender-specific concerns and perpetuates structural inequities.

The gendered nature of harm

Development projects disproportionately affect women and girls in ways that often go unaddressed in complaints to IAMs. Of the 2,011 complaints submitted to IAM mechanisms and tracked in Accountability Counsel's complaint database (the Console), only 38 (1.9%) explicitly raise issues of gender-related harm or gender-based violence (GBV), including sexual exploitation and abuse (SEA). The majority of these complaints stem from infrastructure and energy projects (See Figure 1). 

These complaints often center on harm to livelihoods, inadequate consultation and disclosure, health and safety issues, and physical and economic displacement (See Figure 2). 

But these numbers don't tell the whole story - gendered harm and GBV are pervasive in development projects, despite being underreported. As part of a broader research effort at Accountability Counsel to understand IAM outcomes, we interviewed communities around the world about their experiences with IAM processes. The disproportionate harm to women and marginalized groups emerged as a recurring theme in these conversations. 

Yet these harms are rarely cited as primary issues - not due to a lack of incidents, but because of significant barriers to reporting, including fear of retaliation, social stigma, repressive culture, and economic precarity. Banks and IAMs also lack the systems and sensitivity needed to provide safe spaces for women and marginalized groups seeking redress. This is particularly evident in the mishandling of GBV complaints, as some interviewees described. Moreover, IAM procedures often require clear documentation or corroboration of harm - failing to account for the complexities of GBV cases and further discouraging survivors from coming forward. These failures reflect a broader misunderstanding of gendered harm, a lack of institutional preparedness, and the absence of survivor-centered procedures - underscoring the critical need to embed gender expertise from the outset.  

In our own research, several cases we examined did not raise gendered harm in their formal complaints. However, when we created space for complainants to share their experiences, they spoke openly about the disproportionate harm they or those they knew had endured - revealing that much of this harm remains unspoken and unaddressed. 

One complainant in Brazil for example recounted how physical displacement devastated families and especially women in their community, forcing them to live among rubble and face social stigmatization. He described the long-lasting harm this caused. The Inter-American Development Bank refused to accept responsibility or provide reparations. He recalled:

“Some women were called sluts or prostitutes. A lot of families living in a single place. Bit by bit we cleaned. We stayed in that area for 13 years. Imagine for women to be in a place like that. My daughter is now 27, but at that time she left she was 7 and remembers what happened - being like a refugee, and having them throw a bomb in the church to keep people from staying there.” (São José dos Campos Urban Structuring Program, Brazil)

Even in cases where gender-related harm was formally raised, women told us they had no opportunity to meaningfully voice their experiences during IAM processes. For instance, women impacted by the Olkaria Geothermal project in Kenya, funded by both the World Bank and European Investment Bank, spoke about the disproportionate impact of harm they experienced. This project forced women to travel longer distances for work, negatively impacting their livelihood and increasing their exposure to risk. In addition, while most men received relocation housing, widowed women were left off the list. 

Some women reported experiencing harm but said they were never offered the chance to speak about it during IAM processes, which were often male-dominated settings. One woman shared her disappointment:

“One time I tried to raise my hand to say something and I was shut down by the chairman. In the Maasai culture, when men tell you to keep quiet, you keep quiet. I feel I was let down by the mechanisms because I hoped they would notice I had something to say and would overpower the chairman - and would ask me what I wanted to say. Until today, I am still waiting to be given an opportunity to speak my mind.” (Olkaria Geothermal, Kenya)

Another woman from a displaced community described feeling abandoned by IAM representatives:

“No one from the mechanism ever came to speak to [our tribes]. They didn’t come to me or to anyone in our community. Even after the process, they have never come back to see where the people who lived here are, or whether they had been resettled. They never cared about us. I wonder if they know we now live like dogs in the forest.” (Olkaria Geothermal, Kenya)

This woman was from a minority tribe, underscoring the intersectionality of marginalization. Her experience illustrates how ethnic and cultural minority groups can be further silenced within IAM processes, compounding the barriers already faced by women and other vulnerable populations. 

Even when IAMs confirm that gendered harm occurred, remedy often remains out of reach. In one case involving an energy project, women described the long-term consequences of sexual exploitation on their community by company employees. After an independent review, the IAM confirmed that the bank had failed to identify and protect vulnerable groups. Ten years later, two women shared:

“They caused so [many] problems for women, who have been abused by [the Company’s] workers. Some of them can’t get married because they can’t bear children in the home for the next man, because of abortion. So those are some of the problems in the community where [the Company] resided for over 10 years.” 

“They abandoned the women. They abused the women’s rights and turned their back and abandoned them. Because [there’s] nobody to advocate for you. You don’t have money - who will you go to?” 

This highlights the deep, long-lasting impact of gendered harm when left unaddressed. IAM processes not only often fail to prevent such abuses or provide safe spaces to report this harm, but also fall short of delivering meaningful remedy, leaving women without accountability or justice. 

Why IAMs fail survivors of gendered harm

IAMs, as currently structured, are ill-equipped to handle gendered harm and GBV complaints effectively. 

The challenge with dispute resolution for GBV cases

Dispute resolution processes currently at IAMs are not survivor-centered and thus insufficient to address GBV cases more specifically. Dispute resolution relies on voluntary participation and consensus, which can be problematic in addressing GBV, where power imbalances, cultural norms, and economic dependence frequently silence survivors. These processes often re-victimise survivors by assuming all parties have equal agency and influence in negotiations, which is rarely the case in gendered harm situations, where complainants - especially survivors of GBV - face entrenched power imbalances, social stigma or economic precarity. In a previous article, I analyzed the significant power imbalance inherent in dispute resolution processes - imbalances that become even more pronounced in cases involving gendered harm.

Many are deeply skeptical of dispute resolution’s suitability for GBV cases. As Elana Berger, Executive Director of Bank Information Center noted: 

“We strongly believe dispute resolution is never appropriate in cases of sexual exploitation and abuse (SEA). There are a few reasons for this - power dynamics, the history of how dispute resolution has been used in SEA cases, such as forcing a woman who is raped to marry her rapist, or her father being given livestock as compensation. It is not survivor-centric, and can re-victimize women and girls.” 

Survivors often face additional risks by engaging in dispute resolution, particularly when required to negotiate directly with perpetrators or project actors. They may face stigma within their communities or have their experiences sidelined in favor of broader community grievances, making it difficult to advocate for gender-specific remedy. IAMs currently lack specialized procedures to protect complainants from retaliation and re-traumatization.

However, some practitioners see the potential for dispute resolution to be an effective process for gendered harm, if it takes on gender-sensitive reform, including the integration of survivor safeguards, GBV-trained mediators, and mechanisms to address the broader power imbalances that disadvantage women and marginalized groups. 

Can compliance review offer real remedy?

Compliance review processes are seen by some as better suited for addressing GBV and other forms of gender-related harm, particularly where complainants want to remain anonymous or are seeking systemic policy change. An investigation report acknowledging harm can be a crucial form of remedy for survivors, leading to broader systemic and institutional reforms based on lessons from individual cases. By nature, compliance review investigates the actions of the financial institution, not the client, and can (though does not always) provide direct remedy to affected communities.

However, compliance review processes also often fall short in practice, with limited enforcement of findings and a lack of gender-sensitive policies, trauma-informed approaches, and gender expertise among investigators. IAMs would benefit from embedding investigators trained in gender-sensitive, trauma-informed practices, ensuring investigation teams include female professionals, and incorporating expertise on structural gender inequality; this helps create safer spaces for survivors to share testimony. IAMs should also ensure confidentiality protections, specialized expertise, and lower evidentiary thresholds. Without these, compliance reviews risk reinforcing the same structural barriers that silence survivors and others facing gendered harm in legal and community settings, and may re-traumatize those who come forward. Remedy and its enforcement also remain a significant gap, with many GBV cases seeing little to no follow-up action.

The energy project mentioned earlier illustrates how, even when harm is confirmed by an IAM, communities can be left without lasting remedy. Survivors of GBV faced long-term consequences that remain unresolved - yet follow-up and enforcement were lacking, and meaningful remedy is still out of reach a decade later. As one woman explained earlier, the women were abandoned - left without advocacy or support, and no means to seek justice. 

Given the challenges in both dispute resolution and compliance review, both processes must be reformed to better serve women, girls and others facing gendered harm. Complainants should have access to both processes, and the flexibility to move between them, depending on the nature of the harm and the remedy they seek. 

Building gender-responsive IAMs

How can IAMs adapt their processes to better address gendered harm? A survivor-centered framework prioritizes both prevention - through awareness-raising, education, and early intervention - and healing. These reforms, coupled with transformative justice principles and a human rights-based approach, can reshape IAMs into mechanisms that prevent and respond to gendered harm more effectively. 

As Teresa Mutua, Communities Co-Director at Accountability Counsel, explains:

“Dispute resolution processes at IAMs are not survivor-centered and thus insufficient to address GBV and gendered harm, however they can be. IAMs could integrate gender-sensitive systems such as: (a) including GBV and gender-related sections in complaint forms so issues are captured from the outset; (b) requiring all mediators, staff and consultants to undergo GBV training; (c) providing access to specialized mediators and experts; and (d) ensuring flexibility between dispute resolution and compliance review, so that GBV and other gendered harm cases can be processed in the function that best meets the complainants’ remedy needs.

It is important to identify what types of remedy each function can provide. Compliance review may offer survivors institutional recognition, systemic reform, and in some cases direct remedy, particularly where anonymity is critical. A gender-sensitive dispute resolution process can enable clients to provide direct support, such as medical care, compensation and livelihood restoration. Survivors should have access to both processes, depending on what best meets their needs.”

Integrating gender-sensitive systems into IAM processes can provide women, girls and survivors with choice, agency, and access to meaningful remedy. Applied to IAMs, these reforms could mean:

• Ensuring survivor-centered support: Providing trauma-informed assistance, including access to independent legal and psychosocial support, alternative reporting mechanisms that minimize re-traumatization, and flexibility between dispute resolution and compliance review to ensure that cases of gendered harm are addressed in the process that best fits the nature of the harm and the complainants' needs.
  
  
• Embedding gender expertise in IAMs: Hiring gender specialists to advise on cases and safeguards, and facilitate survivor engagement. Ensuring all mediators and investigators are trained in GBV, gender-sensitive approaches, trauma-informed practices, and are equipped to mitigate gendered power imbalances.
  
  
• Shifting power to marginalized voices: Creating safe spaces for survivors, women and gender-diverse complainants to share their experiences and consult on processes - outside hierarchical, male-dominated settings - while also providing anonymity and options for consultations outside larger groups. Using gender-balanced investigation teams, and training staff to recognize gendered harm, even when not explicitly mentioned.
  
  
• Strengthening survivor protection and access to remedy: Enhancing policies to protect complainants from retaliation, including options for anonymous participation. Lowering evidentiary thresholds for GBV cases to reduce reporting barriers and protect survivors from re-traumatization.
  
  
• Institutionalizing GBV policies: Requiring financial institutions to implement GBV prevention measures, while ensuring IAMs have clear mandates and gender expertise to investigate gender-related harm and provide remedy.
  
  
• Approaches to remedy: Designing reparative programs that address long-term trauma and support survivors’ healing, while ensuring direct remedy for gendered harm through both compliance review and dispute resolution. Women, girls and survivors must be central in designing and shaping solutions that meet their needs.
  

• Strengthening implementation and follow-through: IAMs must follow up on agreements, monitor outcomes, and report transparently on progress, so communities can see the real-world impact of engaging with these mechanisms. It’s essential that remedy is not just promised but realized. Whether through compliance review or dispute resolution, both processes must deliver concrete actions that address harm and ensure women, girls and all those impacted by gendered harm receive meaningful remedy. Without effective follow-through, IAMs risk reinforcing the very injustices they were created to remedy.  

The path forward

The current approach to gender within IAM processes is inadequate. While IAMs were designed to address harm caused by development projects, they largely fail to recognize, prevent or remediate gendered harm meaningfully. By integrating a gendered lens, IAMs can begin to bridge this gap - ensuring that accountability processes are not only accessible but also responsive to the needs of those most vulnerable. IAMs must address gendered harm as a core component of justice - without systemic reform, IAMs risk reinforcing the very injustices they were created to address. True accountability requires more than recognizing harm, it requires transforming systems so that those most harmed are heard, protected, and made whole. Without that transformation, justice remains out of reach.