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Task 11 - Compliance reviews and close-out audits

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Independent third-party oversight is required from the commencement of resettlement implementation (see 4F.2 Guidance, Task 9). This oversight is achieved through compliance reviews, the first of which must be conducted six months after the commencement of implementation. If no material concerns are raised by the independent third-party, subsequent compliance reviews should take place annually. If a compliance review, conducted at any point during implementation, identifies material gaps in the implementation process, a follow-up compliance review is required after six months. If material non-compliances have been addressed adequately, annual compliance reviews can resume.

Suitable parties for providing independent oversight may include a reputable and suitably experienced NGO or civil society organisation. If no such organisation is available, an independent consultant (not the same consultant responsible for planning and implementing the DMP – see 4F.2 Guidance, Task 7 – 9) should be appointed.

The scope of a compliance review should include, but is not limited to, the following:

  • Review the DMP and its operationalisation to confirm that these comply with international good practice (see 4F.2 Guidance, Tasks 7 – 8);
  • Review progress and monitoring reports to verify that the plan is being implemented effectively and is achieving its intended objectives;
  • Undertake targeted engagement with selected stakeholders to confirm the veracity of reported progress and achievement of resettlement objectives; and
  • Document the findings and, if necessary, make recommendations for addressing identified shortcomings.

The resettlement project team and/or operations team should review the findings of compliance reviews to determine if any corrective actions are required and update the M&E plan accordingly.

Where possible, compliance reviews should be conducted alongside other social and environmental audits to allow identification of cross-cutting issues that can only be addressed holistically. If displacement impacts are significant, however, separate reviews may be preferable but information sharing and co-ordination between disciplines remains essential.

An independent close-out audit must be commissioned once the operations team is satisfied with the outcome of implementation activities. The completion audit should be conducted no more than three years after completing physical relocation (in the case of a RAP) and/or after initiation of livelihood restoration activities (in the case of a LRP). In the case of a LAP (temporary displacement only), the timeframe for the completion audit may be shortened in accordance with the nature of displacement impacts. The purpose is to determine whether the implementation process was successful in meeting applicable standards and planning objectives, especially in terms of livelihood restoration outcomes. To achieve close-out, criteria indicative of successful outcomes must be agreed with the RWG during planning, and M&E results must be endorsed by the RWG. It should be noted that several external factors can affect resettlement outcomes and complicate full livelihood restoration. As such, the definition of success must be represented as KPIs that are both achievable in the socio-economic context and acceptable to the RWG.

The completion audit must be documented in a comprehensive report, including conclusions on the success of physical relocation (if relevant), sustainability of livelihood-restoration measures and close-out (corrective) actions that are required to ensure completion criteria are met. The audit findings must specify whether:

  • it is necessary to develop a Remedial Plan; or
  • corrective actions should include minor adjustments to existing planning.

Post-investment review

At an agreed point after commencement of Task 9 (see 4F.2 Guidance, Task 9), a PIR will be conducted as per the IDM.

4F.2 Guidance | Check
4.Impact and risk prevention and management  |  4F Land Access, displacement and resettlement  |  4F.2 Guidance  |  Check