In 2013, IFC invested USD 60 million in Delonex Energy Limited to support the acquisition, exploration, and development of its oil and gas assets in East and Central Africa. Two years later, in 2015, IFC made a USD 50 million equity investment in Africa Oil Corporation (AOC) to aid its exploration and appraisal activities, particularly focused on the South Lokichar Basin in Kenya. Both AOC and Delonex partnered with Tullow Oil to explore Block 12A, a region covering five counties in Kenya: Elgeyo Marakwet, Baringo, West Pokot, Turkana, and Samburu.

In August 2019, CAO received a complaint submitted by the Kerio Valley Community Organization, on behalf of local community members from the Kerio Valley, with support of a Canadian-based civil society organization Justice and Corporate Accountability Project. The complaint raised concerns related to lack of information and stakeholder consultation; failure to address relevant project risks; breach of the IFC Sustainability Framework; and impacts on land, livelihoods, and the environment. 

In September 2019, CAO found the complaint eligible for assessment. During the assessment, the complainants and Delonex chose to address the issues through a CAO-facilitated dispute resolution process, while AOC indicated that it would not participate in the process. CAO extended the assessment period to consult Tullow Kenya B.V., which shared its views on the complaint and participated in the CAO-facilitated dialogue between the Complainants and Delonex, as an observer. The Assessment Report is available in English and Kiswahili. 

Between November 2020 and April 2021, the complainants, Delonex, and Tullow (as observer) participated in capacity-building sessions and bilateral meetings, and in an initial joint session facilitated by CAO in May 2021. In November 2021, Tullow withdrew from the dispute resolution process, and the sessions continued between Delonex and the complainants, mostly through bilateral meetings.

In August 2022, despite the parties' efforts to resolve the issues raised in the complaint, they could not reach an agreement. Accordingly, the case was transferred to CAO’s Compliance function at the request of the complainants and in accordance with CAO’s Policy in March 2023. CAO conducted a compliance appraisal to determine whether an investigation of IFC’s environmental and social performance was warranted in relation to the issues raised in the complaint or whether to close the case. The Dispute Resolution Conclusion Report is available in English and Kiswahili. 

In December 2024, CAO completed its compliance appraisal with the decision that a compliance investigation was not merited. Although CAO acknowledged the seriousness of the harms alleged by the complainants and found preliminary indications of potential IFC non-compliance in relation to its investments, it concluded that an investigation would not provide significant value in terms of accountability or learning, particularly considering the World Bank Group's commitment to cease financing upstream oil and gas projects as of 2019. 

Furthermore, CAO noted the lack of a clear path for remedial action due to IFC's exit from Delonex Energy and AOC's exit from Block 12A and Kenya. While local populations continued to raise concerns about ongoing oil and gas exploration in Block 12A, CAO suggested that IFC should consider using its good offices to facilitate a platform for engagement with all relevant stakeholders. Based on these considerations, CAO decided to close the case after compliance appraisal.

The Compliance Appraisal Report is available in English, with the Kiswahili translation forthcoming.