UNDP: Social and Environmental Compliance Unit (SECU)

Accountability Mechanism

Overview

This description relates to the Social and Environmental Compliance (SECU) Unit of the United Nations Development Programme (UNDP). For a description of the UNDP Stakeholder Response Mechanism (SRM), click here.

UNDP is the development network of the United Nations, working in more than 170 countries and focused on eradicating poverty and reducing inequality. UNDP helps countries develop policies, leadership skills, partnering abilities, and institutional capabilities in order to achieve development results, inclusive growth, environmental sustainability, good governance and security.

All UNDP Projects and Programmes must comply with UNDPs Social and Environmental Standards (‘SES’). The SES seek to:

  • Strengthen the social and environmental outcomes of UNDP Programmes and Projects
  • Avoid adverse impacts to people and the environment
  • Minimize, mitigate, and manage adverse impacts where avoidance is not possible
  • Strengthen UNDP and partner capacities for managing social and environmental risks
  • Ensure full and effective stakeholder engagement, including through an accountability mechanism to address concerns of project-affected people

To ensure compliance with Standards, UNDP must conduct a Social and Environmental Screening Procedure for all proposed projects. The SESP assesses project activities for social and environmental risks and opportunities, and helps ensure that SES requirements are considered and addressed during project preparation.

The SES are supported by an Accountability Mechanism that includes two avenues for responding to concerns related to UNDP-supported projects and programmes:

  • A Social and Environmental Compliance Unit (SECU), which investigates concerns of project-affected stakeholders that UNDP is not in compliance with the Standards and Screening Procedure, and
  • A Stakeholder Response Mechanism (SRM), which helps project-affected stakeholders, UNDP's partners (governments, NGOs, businesses) and others jointly address grievances or disputes related to projects supported by the UNDP.

Groups or individuals who wish to raise concerns about the impacts of a UNDP project have a choice. They can:

  • Ask SECU to investigate UNDP's compliance with its social and environmental commitments,
  • Attempt to resolve complaints and disputes through the SRM, or
  • Ask for both compliance review through SECU and an engagement process through SRM. 

Who can access it? 

Any person or group who believes the environment or their wellbeing may be affected by a UNDP-supported project or programme may file a complaint. Complaints can also be filed by a representative, such as a civil society organization, on behalf of affected communities. Anonymous complaints are not accepted. However, complainants may request that SECU protect their names and identities.

How does it work?

Complaints can be filed by mail, email, telephone, or facsimile. There are no strict format or language requirements to filing a complaint. Complainants may choose to use the complaint submission form to describe their complaint. The complaint form can then be sent to SECU by email.

Reports should be as specific as possible. They should describe current or future adverse impacts that have a link to a UNDP-supported activity and, if possible, the UNDP social and environmental commitments that are believed to have been violated. In addition, it is helpful if the complaint includes the following information:

  • Name, address, telephone number, and other contact information.
  • Whether the complainant(s) wish to keep their identity confidential, and if so, why.
  • Name, location, and nature of the UNDP project or programme (if known).
  • How the complainants believe they have been, or are likely to be, adversely affected by the UNDP-supported project or programme.
  • If a third party, such as a civil society organization, is filing a complaint on behalf of an affected individual or community, the complaint should include evidence the third party is working on behalf of the individual or community.
  • Specific UNDP standards or policies (such as the UNDP's Social and Environmental Standards) – this is helpful but not necessary. 

SECU will assess the complaint in an independent, impartial, and transparent manner, following a specific procedure:

1.       SECU will determine if the complaint is eligible for further review by asking the following questions: Does the complaint relate to a project or programme that is receiving financial or other support from UNDP? Is it submitted by or on behalf of people affected by the activity? Does it raise issues relating to compliance with UNDP's social and environmental commitments?

2.       SECU will then investigate whether UNDP is meeting its social and environmental commitments, and will recommend measures UNDP can take to meet commitments that have not been met. The investigation will:

  • Notify the complainants and other potentially-affected persons that the investigation process has been initiated;
  • Interview those people with relevant information, including, for example, both the Complainants and Project Manager of the project at issue;
  • Obtain documents and other related evidence;
  • Evaluate information and evidence;
  • Conduct on-site visits. 

SECU is housed in UNDP’s Office of Audit and Investigations, which functions independently from the rest of UNDP operations. It is managed by a Lead Compliance Officer.

Outcome 

After completion of an investigation, SECU will issue a compliance report that includes:

  • A discussion of the procedural steps taken to address the complaint;
  • Any factual findings, including any findings of non-compliance;
  • Recommendations to bring UNDP into compliance with social and environmental commitments or to mitigate harm to the complainants; and
  • A proposed plan for monitoring implementation of any recommended actions that UNDP decides to take in response to the complaint.

Compliance can be encouraged through several options, including:

  • Revisions to the project;
  • Suspension of UNDP's financial disbursements;
  • Restoring claimants to a pre-harm state;
  • Conditioning future UNDP participation in a project or programme on compliance with UNDP policies;
  • Include in underlying legal documents provisions indicating that breaches of social and environmental policies are material breaches of the project agreements. 

Monitoring and Enforcement

The compliance review function is not a court of law and does not create any legally enforceable responsibility, immunity, or liability for UNDP or its affiliated organizations. 

Part of the compliance review report is a proposed plan for monitoring implementation of any decisions made as a result of a compliance investigation. At a minimum, SECU will issue a monitoring report on the status of implementation at least annually until the actions have been completed. As part of the monitoring plan, SECU will consult with the complainants. All monitoring plans and monitoring reports will be made available to complainants and the public on the SECU website.

References 

UNDP Webpage

UNDP Social and Environmental Standards

UNDP Social and Environmental Screening Procedure

Investigation Guidelines: Social and Environmental Compliance Unit

Complaint submission form

SECU and SRM Brochure

Last edited: 
January, 2016

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