Complaints & whistle-blowing

CDC's mission is to support the building of businesses to create jobs in Africa and South Asia and through this we aim to reduce poverty and improve lives in developing countries. CDC invests directly and through intermediaries, whereby CDC's capital is invested in companies by independent fund managers, who often have offices in developing countries. CDC expects high standards from all its investment partners and the companies in which its capital is invested.

 

These standards are detailed in CDC’s Code of Responsible Investing. Broadly speaking, CDC’s Code of Responsible Investing covers management of environmental, social and governance (ESG) issues by a company or fund manager in which CDC’s capital is invested (see below) or by CDC. Anti-bribery and corruption measures are included in the governance section of CDC’s Code of Responsible Investing and we welcome the reporting of any suspicions of money laundering, bribery, corruption or other financial malpractice.

CDC’s fund managers have day-to-day working relationships with the companies in which CDC’s capital is invested and are responsible for ensuring that the Code of Responsible Investing to which they have signed up is implemented at these companies. Where CDC is invested directly, CDC is responsible for such implementation.

Report a breach of CDC's Code of Responsible Investing

If you have evidence of or believe that you have been negatively affected by a breach of CDC’s Code of Responsible Investing, please use our Complaints Form to let us know. We will promptly investigate your complaint and, if we deem it eligible (please see below), seek a solution that addresses the complaint as quickly as possible. In cases where CDC’s capital is invested in a company through a fund manager, this will involve working with that fund manager to develop an appropriate solution within the legal framework applicable to that investment.

All concerns will be treated confidentially if this is requested.

Complaints can be submitted by an individual or a group directly and materially affected, or potentially directly and materially affected, by:

  • the operations of a company in which CDC’s capital is invested;
  • the operations of a fund manager through whom CDC’s capital is invested; or
  • the operations of CDC Group plc.

Complaints can also be submitted by:

  • an individual or group authorised to act on behalf of the complainant(s);
  • individuals or registered non-governmental organisations (NGO) with evidence of an apparent breach of CDC’s Investment Code or specific expertise in the topic to which the complaint refers. This may be particularly relevant in the case of environmental issues where the impact may primarily be on biodiversity rather than on people.

CDC will not investigate[1]:

  • frivolous or malicious complaints;
  • complaints motivated by an intention to obtain commercial, financial, personal, political or other advantage, not directly related to the nature of the complaint;
  • complaints filed after CDC’s capital is no longer invested in the business, company or project to which the complaint relates [2];
  • issues which CDC has:
    • previously reviewed [3];
    • made a recommendation; or
    • reached a decision;

unless justified by clear and compelling new evidence or circumstances not known at the time; or

  • complaints or queries relating to the adequacy or suitability of CDC’s own policies and procedures.


[1] As determined by CDC in its absolute discretion.

[2] If we are no longer invested in a company, our ability to resolve a situation is likely to be very limited. However, if we are able to contact the new owners to inform them that the issue has been raised, we will endeavour to do so and consider what other steps could be taken.

[3] In the context of a complaint under this complaints procedure or otherwise.

CDC takes all complaints seriously. We will acknowledge receipt of your complaint within 5 working days and then review whether your complaint is, in our view, eligible for further investigation. We commit to informing you of our decision regarding eligibility within 30 working days. Once a complaint has been accepted as eligible for investigation, CDC may contact the fund manager or, in the case of direct investments, the company management, to begin a process of investigation. CDC may encourage the fund manager or company management to work with the complainant, if the complainant agrees, as part of a process of finding an appropriate resolution to the problem.

CDC will contact the complainant to inform him / her of the steps it intends to undertake (if any) to progress the complaint. Once any investigation by CDC is concluded, the complainant will be provided with a summary of the outcome. CDC’s decisions will be final but may be reviewed if new evidence is brought to the attention of CDC.

CDC’s Board will oversee the handling of all complaints.

An anonymous summary of any complaints received by CDC and the manner in which they have been addressed will be provided on CDC’s website annually.

 

Click here for CDC's Complaints Form.

File a Whistleblower Report Regarding Fraud, Corruption or Other Malpractice

ecognises that not all matters of concern to the public may arise from a breach of our Responsible Investment Code – it therefore welcomes whistleblower reports drawing to its attention failures in its own, a fund manager’s or a portfolio companies’ systems or procedures or examples of misconduct. - See more at: http://dev.cdc.emperor-design.com/Get-in-touch/Raise-a-concern1/Whistle-blowers/?id=63_1609&idkeep=True&epslanguage=en#sthash.DbxpllGA.dpuf
ecognises that not all matters of concern to the public may arise from a breach of our Responsible Investment Code – it therefore welcomes whistleblower reports drawing to its attention failures in its own, a fund manager’s or a portfolio companies’ systems or procedures or examples of misconduct. - See more at: http://dev.cdc.emperor-design.com/Get-in-touch/Raise-a-concern1/Whistle-blowers/?id=63_1609&idkeep=True&epslanguage=en#sthash.DbxpllGA.dpuf
CDC has a developed Complaints handling process but recognises that not all matters of concern to the public may arise from a breach of our Responsible Investment Code – it therefore welcomes whistleblower reports drawing to its attention failures in its own, a fund manager’s or a portfolio companies’ systems or procedures or examples of misconduct. - See more at: http://dev.cdc.emperor-design.com/Get-in-touch/Raise-a-concern1/Whistle-blowers/?id=63_1609&idkeep=True&epslanguage=en#sthash.zOCiJ6NV.dpuf

CDC recognises that not all matters of concern to the public may arise from a breach of our Code of Responsible Investing – it therefore welcomes whistleblower reports drawing to its attention failures in its own, a fund manager’s or a portfolio companies’ systems or procedures or examples of misconduct.

Click here for more information.