HBL is one of the largest private sector banks in Pakistan, with over 1,600 branches and 2,100 automatic teller machines globally and a presence in over a dozen countries. In April 2015, IFC made equity and general-purpose loan investments in HBL. The objectives of these investments were to support the Government of Pakistan’s divestment from HBL and support HBL’s domestic and international growth, including in rural and agriculture finance, women owned and operated small and medium enterprises (SMEs), and sustainable energy finance. In 2021, IFC and HBL also agreed on an advisory services engagement to support HBL improve its Environmental and Social (E&S) performance and risk management.

The complainant is a former employee of HBL whose position was Deputy General Manager and Head of Planning and Implementation of HBL’s Social and Environmental Management Systems (SEMS) unit.

The complaint raised concerns regarding HBL’s alleged non-compliance with national and international E&S standards, including IFC’s Performance Standards. The complaint also raised concerns related to the complainant’s alleged unauthorized dismissal as Deputy General Manager and Head of Planning and Implementation of HBL’s SEMS unit. Finally, the complaint raised concerns around HBL’s alleged mismanagement of its whistleblowing mechanism.

CAO received the complaint in March 2022 and found it eligible for assessment in April 2022. At the request of the complainant, the complaint was referred to IFC in accordance with the CAO Policy.

In August 2022, the complainant requested for the complaint to be referred back to CAO and to end the engagement with IFC. CAO’s assessment formally began on September 7, 2022.

In January 2023, CAO completed its assessment. During the assessment process, both parties expressed no interest in engaging in a CAO dispute resolution process. Consequently, the case proceeded to CAO’s Compliance function for appraisal.

CAO concluded the compliance appraisal in June 2023 determining that an investigation was not merited. The appraisal did not find preliminary indications of potential IFC noncompliance in relation to Performance Standard 2 requirements and the complainant’s dismissal. CAO did conclude that there were preliminary indications of potential IFC noncompliance in relation to IFC’s review and supervision of HBL’s E&S performance. However, while the complaint raises concerns about HBL’s E&S governance, systems, and procedures, it makes no specific allegations of adverse E&S impacts from HBL-financed projects (‘harm’). Consequently, the CAO Policy requirement of a plausible link between alleged harm and potential noncompliance is not satisfied.

The compliance appraisal report, along with other case-related documents, is available in the "Documents Section" below.