LCT / 18-001

Complainant: Association des personnes victimes d’érosion côtière

Date Filed: 22 August 2018

Last update: 19 January 2024

Case Status: Monitoring


Lomé Container Terminal S.A. operates a transshipment container terminal at the coast of Lomé in Togo.

The complaint comprises concerns about the site selection of the project near to the community and environmental impacts predominantly derived from coastal erosion, including economic impacts, destruction of homes and significant cultural impacts.

Action taken

The panel assessed the information provided to it. On 8 October 2018 it determined that the complaint was admissible under the criteria of the Independent Complaints Mechanism Policy (2017), with the exception of having sufficient evidence from the named complainants that they represent the community. The complainants submitted such additional evidence on 17 October 2018.

According to the rules of the Independent Complaints Mechanism, contractual arrangements with the client should be there to allow for the processing of the complaint. As the financing agreement was concluded before the implementation of the ICM, such arrangements were missing. In December 2018 they were put in place.

A preliminary review was performed and the results were published on 23 January 2020. The ICM Panel concluded that the complaint should proceed to a compliance review and decided to focus on the time period after August 2016, the issuance of the CAO investigation report.

Based on the information obtained, the Panel judged the level of compliance of DEG and FMO in their final report. In reaction to this report, the Management Board of FMO and DEG published an official Management Response and will develop a Management Action Plan.


With the publication of the compliance review report, the complaint process under the ICM is closed. The follow-up process on the recommendations made is being monitored by the Independent Expert Panel for the Independent Complaint Mechanism of DEG and FMO.


CLIENT: Lomé Container Terminal S.A.

SECTOR: Logistics