Black Sea Trade and Development Bank

Complaints Mechanism

Overview

The Black Sea Trade and Development Bank (BSTDB) was established by Albania, Armenia, Azerbaijan, Bulgaria, Georgia, Greece, Moldova, Romania, Russia, Turkey, and Ukraine which are the 11 founding countries of the Black Sea Economic Cooperation (BSEC) as a financial pillar of BSEC. BSTDB has operations in the key sectors of infrastructure, energy, transport, manufacturing, telecommunications, and the financial sector.

The BSTDB Environmental and Social Policy defines the main policy statements of BSTDB with regard to environmental and social aspects associated with its finance activities; the Bank’s approach towards integrating these aspects into the financing decision making; and the principles BSTDB follows and the commitments it makes in promoting through its financing the environmental and social sustainability in the Member States.

Concerns about environmental and social impacts of the BSTDB’s operation can be raised through the BSTDB's complaints mechanism. The rules and procedures for this mechanism are stated in the Procedure for the Receipt, Retention and Treatment of Complaints.

The complaints mechanism can also be used for complaints about suspected fraud, corruption, money laundering or terrorism financing, allegations of misconduct of staff members, a procurement or tender procedure, and access to information. This mechanism description relates only to complaints about environmental and social impacts. For information about other type of complaints, please refer to page 2 of the  Procedure for the Receipt, Retention and Treatment of Complaints under 'Treatment and Retention of Complaints'.

Who can access it? 

Any staff member, or an individual, or a group of persons, or a legal entity outside the bank that is affected or feeling affected by a decision of the Bank, or an operation funded by the Bank, may file a complaint.

Anonymous complaints are accepted, however, the Bank's capacity to follow up such reports may be limited.

The complainant may also request the Bank to keep their name confidential. In this case, the complainant's name will not be disclosed without their consent and any information received will be protected from unauthorized disclosure.

How does it work?

Complaints should be submitted to the Head of Internal Audit Department, which is an independent function within the Bank and is responsible for the management and coordination of the Bank’s independent accountability mechanism according to which such complaints and grievances are handled. Complaints may be submitted via one of the following five channels:

  • By using the designated web form
  • By mail: Internal Audit Department, Black Sea Trade and Development Bank, Komninon 1, GR-546 24 Thessaloniki, Greece
  • By E-mail: complaints@bstdb.org
  • By Fax: (+30)2310-290593
  • By the Complaints Hotline: (+30)2310-290524.

In order for a complaint to be formally considered, the subject of the complaint should be clearly stated with as much detail as possible and support documentation (if any). Persons or entities reporting a complaint are encouraged to submit written allegations providing their name and information in as much detail as possible, including, as a minimum:

  • what happened,
  • when it happened,
  • where it happened,
  • how it happened,
  • who committed the alleged illegal, unethical or questionable practice,
  • how the allegation is related to BSTDB’s business, and the name of the operation, if the allegation is related to the BSTDB’s lending activities, and
  • any corroborating evidence.

The complainant can also include what result they hope to achieve with the complaint.

Complainants are encouraged to submit their written complaints in English. Any correspondence should be marked as “CONFIDENTIAL”.

If contact details of the complainant are available, after the receipt of a complaint, the Internal Audit Department shall ensure that an acknowledgment of receipt is sent to the complainant within ten working days, as appropriate and in accordance with the Bank’s policies. However, the confidential nature of complaints may restrict disclosure of details of the investigation. No acknowledgement of receipt shall be sent in cases where complaints are deemed by the Head of Internal Audit in consultation with other Bank experts to have been filed fraudulently or for a frivolous or malicious purpose.

All complaints received are registered by the Internal Audit Department and reviewed to determine within which department’s, officer’s or Bank official’s authority or jurisdiction they fall in order to facilitate investigation according to the Bank’s policies and/or best practices. If a complaint relates to an incident or act that may involve a staff member of the Internal Audit Department then it should be reported to the Office of the President for review and treatment.

References 

Website Black Sea Trade and Development Bank

Environmental and Social Policy

Procedure for the Receipt, Retention and Treatment of Complaints at the Black Sea Trade and Development Bank

Complaints webpage

Last edited: 
January, 2016

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