Real stories from communities who have filed IRM complaints

Multinational Lakes Edward and Albert Integrated Fisheries and Water Resources Management (LEAF II) Project, Uganda

Compliance review

Bank: AfDB

Complaint Office: IRM

Multinational Lakes Edward and Albert Integrated Fisheries and Water Resources Management (LEAF II) Project

Context

The LEAF II Project, financed by the African Development Bank (AfDB), aimed to improve fisheries management and water resources in Uganda’s Lake Edward and Lake Albert regions, which are home to over 500,000 community members and several protected areas and forest reserves. While intended to reduce poverty and promote sustainable livelihoods, the project resulted in significant harm to local fishing communities. Communities faced economic hardship, food insecurity, and displacement due to strict fishing restrictions and the failure to provide promised alternative livelihoods. The militarization of enforcement through the Fisheries Protection Unit (FPU) led to harassment, arrests, and fatalities, with thousands of boats and nets destroyed.

Filing a complaint with the IRM

On November 17, 2021, the Twerwaneho Listeners Club (TLC), a Ugandan civil society organization, filed a complaint with the AfDB’s Independent Recourse Mechanism (IRM) on behalf of affected fishing communities. This complaint highlighted inadequate consultations, loss of livelihoods, forced displacement and human rights abuses, including violence and retaliation, and the failure to secure Free, Prior and Informed Consent (FPIC). The complainants demanded an independent investigation, emergency remediation, proper consultations and stronger human rights safeguards.

Stages of the complaint

Stage 1: Registration & Management Response

On December 7, 2021, the IRM registered the complaint after confirming it met the eligibility criteria. AfDB Management submitted its response to the complaint on January 7, 2022, denying the claims of non-compliance, and asserting, amongst other things, that extensive consultations had been respected.

Stage 2: Eligibility

On June 7, 2022, the IRM published its eligibility assessment report. While not a judgment on the merits of the case, the IRM found enough credible evidence of harm and potential AfDB policy violations to warrant a full compliance review.

Stage 3: Compliance review

The IRM conducted a compliance review and published its report on June 27, 2023. It found the AfDB in violation of its policies in several critical areas, including:

Inadequate consultation and transparency: The bank failed to ensure meaningful, transparent and inclusive consultations with affected communities, including women and vulnerable groups, and failed to disclose key environmental and social management documents.
Failure to assess and mitigate livelihoods impact: The project caused significant livelihood loss for 400,000 fisherfolk, without adequate assessment, mitigation measures or compensation.
Gender-based violence (GBV) risks: The bank ignored GBV and sexual exploitation risks, despite clear evidence of harm. Survivors lacked access to grievance mechanisms.
Use of excessive force and retaliation: The FPU used AfDB-funded patrol boats and operational funds for enforcement actions that resulted in harassment, asset destruction, and fatalities. The bank failed to monitor these activities or provide redress.
Weak oversight of safeguards: AfDB failed to enforce its own environmental and social protections, leaving communities without recourse.

Significantly, the IRM explicitly recommended several remedial actions, emphasizing that AfDB’s non-compliance directly contributed to the harm suffered by communities. The IRM urged the bank to provide remedial action, even though the project had closed. This included:

Providing redress for harmed communities, including compensation and livelihood restoration programs.
Strengthening stakeholder engagement by setting clear minimum consultation requirements and ensuring full disclosure of environmental and social documents.
Developing stronger gender protections, including GBV risk assessments, support services for survivors, and mandatory project oversight on SEAH issues.
Reforming enforcement practices, including human rights policies for security forces, and independent investigations in FPU abuses.
Establishing stronger grievance mechanisms to protect communities from retaliation and violence.

Stage 4: Monitoring

On May 14, 2024, AfDB Management released its Management Action Plan (MAP), acknowledging non-compliance but maintaining that compensation was the borrower's responsibility, not the bank’s. While AfDB committed to monitoring the Government of Uganda’s response and strengthening its policies and practices for future projects, it refused to take direct responsibility for ensuring remedy for the affected communities.

Conclusion

This case highlights the potential power of IAMs to demand justice, with the IRM explicitly recommending remedy for communities harmed by a bank-financed project. The IRM’s call for compensation and livelihood restoration sets a strong precedent for what IAMs can and should demand when serious harm results from bank non-compliance.

However, AfDB’s refusal to take direct responsibility - choosing instead to defer the matter to the client - highlights a critical gap in accountability. While the IRM underscored the bank’s role in enabling harm, to date the bank has failed to respond adequately and adopt the IRM’s recommendations for remedy.

Issues and sectors

Issues

Sectors

For further information

Multinational Lakes Edward and Albert Integrated Fisheries and Water Resources Management (Leaf II) Project Complaint

A guide to the AfDB's Independent Recourse Mechanism (IRM)