External complaints & reports
CDC helps solve the biggest global development challenges by investing patient, flexible capital to support private sector growth and innovation.
We are the world’s first impact investor with over 70 years of experience of successfully supporting the sustainable, long-term growth of businesses in Africa and South Asia.
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 Code of Responsible Investing (the “Code”). You can find the Code here.
The Code covers the management of E&S and BI issues by our investment partners including portfolio companies, financial institutions and the managers of portfolio funds (“investees”). It also describes how CDC should apply E&S and BI requirements to its investments. This page provides guidance on how to report or complain to CDC about misconduct or malpractice by CDC or its investees, which is alleged to breach the Code.
External reports and complaints handling process
Who can make a report or complaint?
Individuals, groups, communities or other parties who believe they have been adversely affected or have the potential to be adversely affected by a CDC portfolio company, or a financial institution or fund in which CDC is invested, including prospective CDC investees.
How can reports or complaints be made?
Complaints and reports can be made in writing by emailing:
Please ensure that your report or complaint includes the following information:
- Your name and contact details
- Identification of the CDC investee (e.g. name of investee company, fund, fund manager , financial institution or project) to which the report or complaint relates
- Information regarding the misconduct or malpractice that is alleged to violate the Code
- Information regarding any harm caused by the alleged misconduct or malpractice, provided in as much detail as possible, including an explanation of whether you are directly affected
- Any documents that support the allegation of misconduct or malpractice
- Information on any steps taken prior to this report or complaint to address the alleged misconduct, malpractice or harm
- Whether your identity should be kept confidential
- Information on what you hope to achieve with your report or complaint: in other words, the redress or resolution sought
Will confidentiality of reports or complaints be respected?
It is CDC’s policy not to reveal the identity of an individual or entity making a report or complaint to any third party without explicit permission from the relevant individual or entity. Within CDC, relevant details of the report or complaint, and the identity of the external party making the report or complaint, are only shared with staff directly involved in the review of complaint. Sometimes the details of a report or complaint may need to be shared with third parties, including law enforcement authorities or regulators, which may make it difficult to protect the anonymity of the external party making the report or complaint. In these circumstances, we will discuss this with the relevant external party and seek to agree an appropriate way forward.
What happens when a report or complaint is filed?
CDC will acknowledge receipt of the report or complaint, and CDC’s Compliance team will determine the eligibility of your report or complaint for investigation. Reports or complaints that do not relate to CDC or its investees, or that do not allege misconduct or malpractice in breach of the Code, will not be eligible.
If your report or complaint is deemed ineligible, you will be notified and informed of the reason. If your report or complaint is deemed eligible, we set out below the process for handling the report or complaint.
How are eligible reports or complaints handled?
All eligible reports or complaints will be independently managed by CDC’s Compliance team under the supervision of the Head of Compliance.
The Compliance team will initiate an investigation of the misconduct or malpractice alleged in the report or complaint, and coordinate with the relevant internal teams to gather facts, determine whether there may have been a breach of the Code, and consider whether further action is required. The nature of the investigative process may depend on a range of factors, including (without limitation): the extent of our involvement in the alleged misconduct or malpractice; the seriousness of the allegation; the extent to which we have access to relevant information or documents; the existence of litigation, law enforcement action, or regulatory interventions in relation to the same or related allegations; and the willingness of other relevant parties (such as fund managers or portfolio companies) to cooperate with our investigative work.
Throughout the investigation process we will endeavour to keep the external party that made the report or complaint informed and updated unless, in our reasonable opinion, this is inappropriate. When dealing with some cases, CDC may need to consult an external adviser or investigator to assist with the investigation (subject to the need to preserve the complainant’s anonymity). In all cases, a formal written response will be provided to the external party that made the report or complaint on the outcome of the investigation.
CDC is committed to transparency in the complaint handling process, but external parties should be aware that our ability to provide detailed information on the steps we have taken in response to reports or complaints may be limited by the nature of the investigative work; our legal obligations to investee companies, funds or other third parties; our legal and regulatory duties; and the need to preserve legal professional privilege over our investigative process.