The complaint mechanism is a core pillar of an environmental and social management system: Everyone who feels negatively affected by the projects backed by AEGF (or those who represent affected persons) can raise their concerns via this complaint mechanism.

Please note that complaint mechanisms established directly by the project developer, or the primary insurer may prove to be the most effective way to address complaints and other concerns regarding the project. Nonetheless, you are welcome to use the below complaint mechanism established and managed by SFRC. Further, filing a complaint with AEGF does not preclude recourse to national judicial authorities.

For complaints filed under this complaint mechanism, SFRC commits to support the assessment of the issues raised, to work towards the development and implementation of mitigation measures and, if necessary, supports a mediation process between the project and the complainant.

Filing a complaint

Complaints may be submitted by e-mail or mail. Anonymous complaints will not be processed.

Where / How to file

By e-mail:

By mail/post:
Sustainable Finance Risk Consulting GmbH
Gedonstraße 8
c/o Munich Re
80802 Munich

Please note that in the course of processing your complaint, it may become useful to involve the primary insurer due to their better understanding of the project. We may therefore wish to transfer your data (name, contact details, other information you may have transferred to us) to the relevant primary insurer. A data transfer to countries outside of the EEA (“third countries”) may take place, depending on the location of the primary insurer in question. This would require your prior consent based on European Law, so we may contact you with this regard prior to assessing the complaint.

Who can file?

  • Any stakeholder or their representatives

When to file?

  • Within one year from the date on which the facts upon which the allegation is based could reasonably be known by the complainant
  • At any time during the insurance cycle

What to file?

  • Policy expired or terminated
  • Generated to gain competitive advantage
  • Anonymous complaints / Lack of adequate identification of the issuer
  • Lack of substance to allow a meaningful processing
  • Project not related with AEGF

Complaints may be submitted in English, French or Portuguese. The working language of the complaint mechanism is English. Hence, additional time may be required for translation.

  • Contact information of the complainant
    Please provide your contact information. This includes your name and further contact details as address, email address and/or telephone number. If you are a representative, please state on whose behalf the complaint is submitted.
  • Complaint
    Please provide us with detailed information about the complaint so that we can understand the circumstances. This includes the subject matter of the complaint. Additional information could include project details, such as name and location, and a description of the problem or harm. Please also explain your expectations for the complaint. If other complaint mechanisms have been used, please indicate and provide details (i.e. the organisation whose complaint mechanism has been used and the current status of the process)

  • Confidentiality of identities. Please state whether or not you want to keep your identity confidential.

    Please note: SFRC cannot accept anonymous complaints. In case complainants want to keep their identities confidential, complainants' identities will be kept confidential from all parties other than the initial complaint processor (SFRC), unless complainants agree to disclose their identities. Authorized representatives' identities will be disclosed, unless they are complainants themselves.

Short process description

Receiving and acknowledging the complaint

Approximately 15 working days after receiving complaint or, if applicable, consent to transmit personal data to parties outside the EU

  • The complaint will be registered
  • The complaint will be checked regarding its admissibility by SFRC
  • The complainant will receive information about the admissibility of the complaint or in case the complaint is not admissible, a notification with a justification

Processing the complaint and informing the complainant

Approximately 60 working days after acknowledgement

  • The complaint will be initially reviewed and if necessary further information will be requested from the complainant by SFRC
  • A statement from the project about which the complaint was raised will be obtained
  • The complaint will be assessed in detail in cooperation with the primary insurer
  • Where necessary, the complainant and the project may also be included in the process. If needed, independent external experts will be involved
  • The complainant will be informed by SFRC about the results

Please note: This period may be extended (e.g. due to the consultation of external experts). However, the complainant will be informed about a possible time extension.