By Witness Radio Team

Germany’s state-owned development bank, KfW, is facing renewed scrutiny as Civil Society Organizations (CSOs) issue detailed recommendations to reform its Complaint Mechanism, citing systemic failures to prevent harm, address reprisals, and ensure accountability in projects it finances across developing countries.

The recommendations follow the release of “Irresponsible Banking”, a report by the Coalition for Human Rights in Development launched in September 2025, which documented alleged links between KfW-backed projects and land dispossession, environmental degradation, and threats against human rights defenders (HRDs).

The report documented cases in Indonesia, Mexico, and Tanzania in which affected communities claimed to have faced intimidation, livelihood losses, and violations of their right to Free, Prior, and Informed Consent (FPIC) by KFW-backed projects.

In response, a coalition of organizations, including Asia Indigenous Peoples Network on Extractive Industries and Energy (AIPNEE), Community Empowerment and Social Justice Network (CEMSOJ), Defenders in Development Campaign (DiD), and Protection International, has submitted over 20 detailed recommendations aimed at fundamentally strengthening the independence, transparency, and effectiveness of KfW’s Complaint Mechanism.

Some of the key recommendations include a call for structural independence, a separate budget for the mechanism established and managed independently of the management of the KFW Bank, taking into consideration reprisals suffered by project-affected people, and mentioning that the Complaints Office will commit to implementing a more comprehensive approach, looking beyond individual complainants, among others.

These proposals stem from documented concerns that communities affected by KfW-funded projects struggle to access meaningful remedies.

According to the KFW irresponsible banking report, projects branded as sustainable and pro-development have, in several cases, been linked with forced displacement, inadequate consultation, and reprisals against those who speak out.

“KfW calls it ‘responsible banking’, but it’s using German taxpayers’ money to bankroll projects that displace Indigenous Peoples, destroy ecosystems, and endanger human rights defenders. If KfW wants to demonstrate real responsibility, it needs to listen to local communities and ensure their voices are not silenced.” Dalile Antunez, collaborative researcher at the Coalition for Human Rights in Development.

Being fully owned by the German government, CSOs emphasize that its operations must align with the United Nations Guiding Principles on Business and Human Rights and Germany’s Supply Chain Due Diligence Act.

According to the United Nations Guiding Principles on Business and Human Rights, business enterprises are expected to respect human rights, meaning they should avoid infringing on others’ human rights and address adverse human rights impacts with which they are involved. This is in addition to Germany’s Supply Chain Due Diligence Act, which requires enforcement of corporate accountability for human rights and environmental standards across global operations.

But such standards have never been adhered to by development projects such as KFW-funded projects.

KfW bank is further urged to adopt a comprehensive anti-reprisals framework, including concrete measures such as suspending project disbursements where threats persist, documenting all reported reprisals in a public registry, providing emergency assistance where needed, and communicating incidents to oversight bodies such as the German Institute for Human Rights.

Civil society groups argue that these recommendations demonstrate the need not only for stronger safeguards but also for genuine participation by affected communities in remedial processes.

The recommendations, therefore, propose that complainants have the authority to choose whether their case proceeds through dispute resolution, prior resolution, or compliance review.

They also call for guaranteed access to all information used in decision-making, publication of both admissible and inadmissible complaints, and extended deadlines for filing complaints to account for delayed discovery of harm.

Additionally, CSOs advocate for a simplified complaint process that allows grievances to be submitted orally or through accessible channels, recognizing the barriers faced by remote or marginalized communities.

“Many Indigenous communities in remote areas may face barriers such as limited access to technical support or a lack of experience in preparing formal written complaints, particularly in the absence of supporting NGOs. So, they should be able to file complaints verbally or in other forms and through various channels. The current system is overly complex, creating barriers for communities to submit grievances independently without supporting NGOs,” reads part of the recommendations.

CSOs argue that unless KfW Bank strengthens the independence of its Complaint Mechanism and adopts enforceable protections against reprisals, its sustainability commitments risk remaining utopian rather than realistic and transformative.

Fisher women play a vital role in sustaining household food security, yet remain under‑recognised, excluded from permits, and denied equal income opportunities in the fishing sector.Photo Credit: The Green Connection.

By Witness Radio team.

South Africa produces enough food to feed its population, yet millions go to bed hungry every night.

According to Statistics South Africa’s General Household Survey 2024, released in 2025, about 14 million people experienced hunger, representing 22.2% of households reporting inadequate or severely inadequate access to food. The Northern Cape (34.3%), Eastern Cape (31.3%), and Mpumalanga (30.4%) recorded the highest levels of food insecurity.

One in four children in South Africa is stunted due to chronic malnutrition. In the Eastern Cape alone, 70 children under the age of five reportedly died from malnutrition-related complications between January and July 2025.

In response to the growing problem, the South African Human Rights Commission, a national institution established to support constitutional democracy, declared last year that it would hold a National Public Inquiry into the Constitutional Right to Food. This inquiry will examine how communities, corporations, laws, and policies shape food systems and seek to address the structural causes of hunger.

As a result, the investigation will try to describe a future in which food is once again understood as sustenance, dignity, and justice.

Thousands of small-scale fishers along South Africa’s 3,000 km coastline depend on marine resources for their livelihoods, highlighting their vital role in the nation’s food security and cultural fabric.

Many fishing families struggle to make ends meet, even though they harvest food from the ocean. The livelihoods and food security of about 28,000 small-scale fishermen are directly reliant on marine resources. Yet, existing policies-such as restrictive permits and limited market access-exclude them from full participation, perpetuating food insecurity.

For these communities, food systems are not abstract policy concepts. They shape daily survival, dignity, livelihoods, and cultural identity.

“As part of our submission, we emphasize that concrete policy changes-such as recognizing customary fishing rights and improving market access-will directly enhance the livelihoods and food security of small-scale fishers and coastal communities, making the case for urgent reform.” Says Buthelezi

The Green Connection, a registered non-profit organisation, works with coastal communities to promote environmental justice, human rights, and accountable governance.

In the submission, the Green Connection states that the inquiry is timely as it will examine the structural and economic dynamics that perpetuate hunger. “It will assess the concentration of power in the food value chain, affordability and access, land and tenure security, policy coordination, and the realization of the constitutional right to food. This includes its links to dignity, health, water, culture, and a healthy environment.” The submission reads.

The Green Connection further argues that the Commission’s examination of governance, participation, and accountability must include scrutiny of marine and ocean policy.

“Poor implementation of the Small-Scale Fisheries Policy, limited market access, inadequate infrastructure, and weak consultation processes continue to undermine the sector. Women – who make up less than 30% of participants – remain under-recognised. At the same time, young people leave coastal communities due to declining economic prospects,” says Khetha Buthelezi, Economics Officer at The Green Connection, adding that, “Food and the systems we put in place to produce it cannot be separated from human dignity, livelihoods, and cultural rights. These issues are not abstract policy debates. For small-scale fishing communities, food from the ocean is not merely a commodity – it is a foundation of identity, survival, and social cohesion.”

The organisation also raises concerns about the potential impacts of offshore oil and gas expansion under Operation Phakisa. It further adds that Seismic surveys, drilling, and increased shipping activity can threaten fish stocks and restrict access to traditional fishing grounds, thereby directly affecting food security and livelihoods.

“For small-scale fishers, these are not abstract environmental issues. It is about income stability, cultural survival, and the constitutional rights to food, livelihoods, and participation in decision-making, and protecting these rights and resources for future generations,” says Buthelezi

Several fishing communities consulted shared testimonies describing worsening conditions.

“While small‑scale fishers support around 28000 people in South Africa, many of us can no longer catch or sell enough fish to feed our own families. Walter Steenkamp says on behalf of Aukotowa Small‑Scale Fishers Co‑operative in Port Nolloth, Northern Cape.

Steenkamp adds that Decisions are often made without consulting them, which reflects an intended exclusion from decision-making. “We hope this inquiry will result in the recognition of our customary rights, the return of our fishing grounds, and for the government to listen to those of us who live from the sea, so that we can feed our families with dignity.”

According to Kristie Links from the Sal-Diaz Small-Scale Fisher Co-operative in Saldanha Bay, Western Cape, farmers are forced to use larger boats that they cannot afford. “We have no money for the bigger boats they want us to use, and the areas we are given have little or no fish.

Industrial boats continue to overfish, especially at night, while our communities struggle to put food on the table. This situation is destroying our livelihoods, our food security, and our right to be recognised as small-scale fishers,” Kristie adds.

The organisation argues that poor implementation of the Small-Scale Fisheries Policy, weak consultation processes, and inadequate infrastructure continue to undermine the sector.

“Our message to the SAHRC is clear. If South Africa is serious about tackling hunger and inequality, it must ensure food systems governance is transparent, inclusive, and accountable. Coastal communities are not asking for charity – they are demanding justice.” Buthelezi concludes

The deadline for written submissions has been extended to 27 February 2026, with public hearings scheduled for March during Human Rights Month.