Today, BankTrack launches a Users’ Guide to banks’ human rights complaints channels, an online tool that gives people affected by bank finance and their allies practical guidance on how to raise environmental and human rights complaints or grievances with banks. 

The launch follows the development of a “first generation” of human rights grievance mechanisms by commercial banks. These are formal channels that can address and in theory provide remedy for human rights complaints. 

Banks and banking sector initiatives are required to develop or participate in such grievance mechanisms since the advent of the UN’s Guiding Principles on Business and Human Rights in 2011. However, they have been slow to do so. BankTrack’s 2024 Global Human Rights Benchmark found six banks out of the 50 evaluated now have such a mechanism, up from just two in 2022. [1] 

BankTrack’s Users’ Guide explains how these mechanisms work, what to expect once a complaint is filed, and sets out key indicators for each. The indicators show whether the mechanisms developed so far have set out clear timelines, are equipped to deliver remedy, and have a register of complaints, among other factors. The mechanisms vary in their performance on these factors. 

The User’s Guide is structured in three sections:

• Section 1 provides a guide to how existing bank grievance mechanisms work in practice. It includes the mechanisms of ANZ, Commonwealth Bank, and National Australia Bank in Australia; ABN AMRO in the Netherlands; Deutsche Bank in Germany; and JaCER, a grievance platform used by Japan’s MUFG, SMBC and Mizuho. The guide sets out how each of these eight mechanisms operates, including how complaints can be filed, expected timelines, who handles cases, the level of transparency on outcomes, and the banks’ approach to remedy.

• Section 2 sets out other avenues that may be used to raise human rights complaints with or about commercial banks. These include: banks’ whistleblowing channels; OECD National Contact Points; the UN Special Procedures; independent accountability mechanisms of development banks; industry-level grievance mechanisms in which banks participate; and BankTrack’s Equator-Complaints.org channel for communities affected by harmful projects financed under the Equator Principles.

• Section 3 gives an overview of the main international human rights frameworks that define banks’ responsibilities on grievance mechanisms and remedy. This section aims to support people and groups filing complaints, including guidance around the extent and limits of banks’ duties of confidentiality.

“Banks’ grievance mechanisms are a welcome new development, but they differ in scope and operation, and information about them is often difficult to find or interpret from a rights-holder’s perspective”, said Giulia Barbos, Human Rights Researcher at BankTrack. “Banks need to do more to ensure rights-holders know these mechanisms exist and how to use them. To fill this gap, we hope to provide a useful resource that helps people evaluate and use these accountability channels by bringing this information together in one place, and keeping it up to date. The more these mechanisms are tested, the more we can learn about their strengths and weaknesses - and the more we can push banks to improve them and ensure they are effective.”

BankTrack’s Users’ Guide is a living resource and will be updated as more bank grievance mechanisms become available. 

Notes:

[1] This Users’ Guide reviews a total of eight mechanisms. This includes the six covered in the Global Human Rights Benchmark: as well as Commonwealth Bank of Australia, which did not receive a full point in the 2024 Benchmark as its scope is limited to Australia’s First Nations people; and SMBC, which joined JaCER, the grievance platform of Japanese banks, since the publication of the Benchmark.