Reports & complaints
We help to solve the biggest global development challenges by investing patient, flexible capital to support private sector growth and innovation.
In carrying out this mission, we expect high Environmental and Social (“E&S”) and Business Integrity (“BI”) standards from all our investment partners and portfolio companies. These standards have been implemented for all new investments since 2012 and are outlined in our Policy on Responsible Investing (the Policy). You can find the Policy here.
The Reporting and Complaints Mechanism allows anyone outside BII to report alleged breaches of the BI or E&S provisions of the Policy by BII, a BII Investee, or a portfolio company of a fund in which BII has invested.
The Reporting and Complaints Mechanism Rules are available here.
What issues can be raised using the Reporting and Complaints Mechanism?
The Reporting and Complaints Mechanism can be used to report alleged or anticipated breaches of the BI or E&S provisions of the Policy. It cannot be used to raise reports regarding:
- BII’s investment model or investment policies;
- commercial or investment decisions by BII or BII Investees that do not relate to alleged breaches of the BI or E&S provisions of the Policy;
- BII’s relationships with its employees; or
- contractual or commercial disputes involving BI and/or BII investees that do not relate to alleged breaches of the BI and E&S provisions of the Policy.
Who may use the Reporting and Complaints Mechanism?
Any external party including individuals, community groups, non-governmental organisations, or other persons or entities may make a report under the Reporting and Complaints Mechanism.
BII employees and BII nominees to the boards of directors of BII Investees have access to separate reporting processes.
How can reports be submitted?
Reports and complaints can be submitted by email to [email protected] or by mail to:
Attn: Information and Complaints Office
British International Investment plc
123 Victoria Street
London
SW1E 6DE
United Kingdom
What information needs to be included in a report?
We encourage the inclusion of the following information in reports, to the extent relevant:
- the name and contact details of the party submitting the report;
- the name of the BII Investee to which the report relates (for example, the name of the relevant company, fund, fund manager, project, financial institution or bank);
- information regarding the reason for the complaint and/or the alleged breach of the BI or E&S provisions of the Policy, including relevant supporting documents;
- information regarding any adverse impacts caused by the alleged breach;
- information regarding any steps taken to address the alleged breach prior to submitting the report to the Reporting and Complaints Mechanism, including the outcome of any such steps;
- information regarding any redress or resolution sought with respect to the alleged breach; and
- any special requests regarding the confidentiality of the person or entity making the report (for example, requests not to disclose the identity of the party making the report to a BII Investee).
Although this information is not mandatory, it may be more difficult for BII to take action in response to a report if the information is not provided.
Who will see the information in a report?
Relevant details of reports are only shared with the BII employees who are involved in reviewing and responding to the reports. If BII engages a professional advisor to review and respond, BII will ensure that appropriate confidentiality protections are in place.
When a report has also been submitted to other bodies in addition to BII, such as co-investors or the Foreign, Commonwealth and Development Office, BII may have discussions with relevant counterparts for the purposes of developing the response plan or deciding whether further action is required.
Can the identity of the person making the report be kept confidential?
BII will seek to comply with a request for confidentiality regarding the name of the person or entity making the report, but there may be occasions in which BII has to share the details of a report with others, such as law enforcement authorities or regulators. In those circumstances, the Information and Complaints Office will seek to agree an appropriate way forward, subject to BII’s legal and regulatory obligations.
What if the person making the report is concerned about retaliation?
BII does not tolerate retaliation against any person that submits a report in good faith. Where an external party raises a concern about potential retaliation, the Information and Complaints Office will engage with the external party to consider steps to mitigate the risk of retaliation.
Who will review the report and are they independent of BII’s management?
Decisions required under the Reporting and Complaints Mechanism Rules are made independently of the departments that are involved in pre-investment due diligence and post-investment monitoring of BI and E&S issues.
BII’s Information and Complaints Office is led by the Head of Compliance who will review reports submitted to the Reporting and Complaints Mechanism. The Head of Compliance has a direct reporting line to the Audit and Compliance Committee of BII’s Board of Directors.
How does the Information and Complaints Office decide what to do in response to a report?
The Information and Complaints Office reviews all reports to decide whether they are eligible for the Reporting and Complaints Mechanism. If a report is eligible, the Information and Complaints Office will decide what further action is required in relation to the report, if any.
Further details regarding this process are set out in the Reporting and Complaints Mechanism Rules, which are available here.
In the event of any inconsistency between the information on this page and the Reporting and Complaints Mechanism Rules, the Reporting and Complaints Mechanism Rules will prevail.
If I submit a report, will I hear back from BII?
Yes, the Information and Complaints Office will acknowledge receipt within five working days of all external reports submitted in writing to the email address or office address above.
In addition, following its initial review, the Information and Complaints Office will let you know whether the report is eligible for the Reporting and Complaints Mechanism. The Information and Complaints Office aims to send this confirmation within 20 business days of receiving a report, but this may take longer if the report contains information and documents in languages other than English, or if it is not submitted by email.
If your report is eligible for the Reporting and Complaints Mechanism, the Information and Complaints Office will also summarise what action, if any, BII is taking in response to the report.
What action will BII take in response to an eligible report?
If the Information and Complaints Office decides that further action is required, the response plan will depend on the specific factual circumstances. However, it may include (among other things):
- investigative steps to ascertain the facts regarding the alleged breaches of the Policy;
- implement actions to improve Business Integrity and Environmental and Social outcomes
- referrals to relevant law enforcement authorities or regulators;
- review by 3rd party specialist mediators and/or dispute resolution services
- measures to enable redress or remediation to individuals or communities impacted by a proven Policy breach, and/or
- steps to learn lessons about proven Policy breaches, to mitigate the risk of similar breaches occurring in the future.
There may be some situations in which the Information and Complaints Office decides that no further action is required — for example, where the allegations have already been investigated by BII or a third party or referred to a relevant law enforcement authority or regulator. In this case the complainant would be notified of the outcome.
A list of issues that the Information and Complaints Office may consider when deciding how to respond to eligible reports is set out in the Reporting and Complaints Mechanism Rules, which are available here.
BII will aim to ensure the complainant is kept informed of significant developments in the review process.