SUPPORTED BY Assessing Project-Level Grievance Redress Mechanisms Using a Human-Rights-Based Approach Tips and Tools GUIDANCE FOR TASK TEAMS Acknowledgments This report was part of an effort to strengthen the right to provided by Sophia Georgieva, Camilla Marie Lindstrom, Luiza remedy in World Bank operations and beyond by building the Nora, G. Srihari, and Tatiana Tassoni. capacity of World Bank staff, clients, and project-affected people, especially the vulnerable and marginalized, to The authors would also like to thank Laura Johnson for her implement effective grievance mechanisms so that they can excellent editorial support. improve service delivery, risk management, and development outcomes. The core team, led by Sanjay Agarwal and Saki Finally, the authors are grateful to the Human Rights, Inclusion Kumagai, comprised Harika Masud and Hélène Pfeil at the and Empowerment Trust Fund (HRIETF) for supporting the World Bank. activities under this initiative. The findings, interpretations, and conclusions expressed in this report are entirely those of The lead authors of the report are Harika Masud and Hélène the authors and should not be attributed in any manner to the Pfeil, with invaluable contributions from Sanjay Agarwal and World Bank, to its affiliated organizations, or to members of its Saki Kumagai. Valuable inputs, comments, and guidance were Board of Executive Directors or the countries they represent. 1 1 Introduction T What characterizes an effective his note is a resource for World Bank task teams providing technical assistance to Borrowers on grievance redress project-level GRM? mechanisms (GRMs). The first step in strengthening a A GRM is a system through which queries, suggestions, positive project-level GRM, after discussing it within the task team and feedback, concerns, and complaints about a project can be informing the Country Management Unit (CMU), is to organize submitted and responded to; implementation issues resolved; a technical assistance mission to conduct a detailed GRM and complaints efficiently and effectively addressed (Post diagnostic for the project or group of projects selected. This and Agarwal 2011). Effective GRMs are widely accessible with helps the project implementation unit (PIU) and task team multiple uptake channels and provide beneficiaries with a fair understand the PIU’s capacity for grievance management, and predictable process and timeline for receiving a response. learn about grievance resolution experiences of PIU staff and potential complainants and project beneficiaries through field visits, share international experiences with grievance What is the GRM value chain? redress while building the capacity of relevant staff, and The GRM value chain is a useful framework for analyzing project- facilitate the preparation of a GRM strengthening action plan level GRMs. As depicted in figure 1, it outlines the six steps by relevant PIU counterparts. The guidance and tools provided that are necessary for a GRM to be functional and effective: (1) here, including templates and worksheets, can help social uptake; (2) sort and process; (3) acknowledge and follow up; (4) development specialists and other relevant task team members verify, investigate, and act; (5) monitor and evaluate; and (6) systematically plan and organize such missions. provide feedback to the complainant. While the documents presented here are primarily geared toward dedicated technical assistance missions focused on What is the added value of assessing GRMs, a GRM assessment using the approach outlined in this existing project-level GRMs? note could also be conducted by a task team or social specialist GRMs play a crucial role in strengthening environmental as a part of project supervision, although this would require a and social risk management, notably under the following significant amount of time, which the supervision mission would Environmental and Social Framework standards: ESS2: Labor need to account for. and Working Conditions; ESS5: Land Acquisition, Restrictions FIGURE 1. GRM VALUE CHAIN Uptake Sort Acknowledge Verify, Monitor Provide (locations and and and investigate, and feedback channels) process follow up and act evaluate 1 1. INTRODUCTION on Land Use and Involuntary Resettlement; ESS7: Indigenous For World Bank task teams, strengthening GRMs will improve Peoples/Sub-Saharan African Historically Underserved social and environmental risk management. PIUs and projects Traditional Local Communities; and ESS10: Stakeholder that benefited from such technical assistance can then serve Engagement and Information Disclosure. Moreover, information as good practice examples of how to receive and resolve a compiled through an effective GRM can provide valuable significant number of grievances in a satisfactory and timely insights on implementation progress and challenges, serve as manner—lessons that other operations can emulate. a performance management tool for implementing agencies; and increase citizens’ trust. A project-level GRM can serve as an effective tool for engaging citizens, in line with the Independent What Is a human-rights-based approach Evaluation Group’s recommendation to harness synergies to grievance resolution? between citizen engagement and the Environmental and Social A human-rights-based approach to grievance resolution Framework. A GRM that is accessible and available to vulnerable means paying attention to the principles of equal access, groups also promotes social inclusion. However, evidence from nondiscrimination, participation, inclusion, transparency, and the Inspection Panel, the World Bank’s Grievance Redress accountability in the design and operation of a GRM. GRMs are System, regional GRM portfolio reviews, implementation status 1 a means of fulfilling an individual’s right to effective remedy. In and results reports, and supervision missions indicates that the context of project-level GRMs, these principles translate into the vast majority of GRMs in World Bank-financed lending pragmatic considerations, including:4 operations are in need of considerable improvement, particularly in terms of their accessibility and the availability of evidence of 3 Providing a variety of grievance uptake channels, adapting complaints being received and processed. channels to local culture and language, and considering whether additional steps are needed to ensure that Accordingly, it makes sense trying to improve the functioning vulnerable groups can access the mechanism; and effectiveness of GRMs for Bank-financed operations through technical assistance and to do so, using a standardized 3 Tailoring communication methods to the needs of vulnerable approach that is replicable across the World Bank portfolio. 2 groups, such as those unable to read or write; This note proposes such a standardized approach.3 The benefits to Borrowers of this type of technical assistance include: 3 Upholding transparent procedures and guaranteeing fairness sensitization of PIUs to the intrinsic and operational value of of outcomes; and GRMs, just-in-time technical support and capacity-building through GRM orientation sessions for PIUs, participatory 3 Regularly assessing trends related to grievances and GRM diagnostics, and client-led identification of corrective disaggregating information about complainants while measures through a GRM strengthening action plan with clear respecting the need for confidentiality. accountability and deliverables. 1. Managed by the Operations Policy and Country Services (OPCS), the World Bank’s Grievance Redress System is an avenue for people and communities to submit complaints directly to the World Bank if they believe a Bank-funded project has or is likely to adversely affect them. The Grievance Redress System ensures that complaints received at the corporate level are promptly and proactively addressed by fostering dialogue and problem solving as well as applying relevant dispute resolution tools. Its activities and complaint-handling processes are guided by the Grievance Redress System Bank Procedure. 2. While the emphasis here is on IPFs, some of the elements presented in the note will also be relevant for the institutional approach required for PforRs. 3 The approach presented in this note has been tried in various projects in several countries such as the Philippines, Uganda, West Bank and Gaza, Egypt, and Georgia. 4. For more on how to encourage the participation of vulnerable groups in a GRM, see Pfeil and Agarwal. 2021. 2 2 Overview of Activities Before, During, and After a Technical Assistance Mission The guidance provided in this note is organized as three sets of activities: (1) those conducted prior to the technical assistance mission; (2) those conducted during the mission; and (3) those conducted after the mission. Activity √ BEFORE THE MISSION Reach out to the country management unit/regional GRM coordinator and the project’s social development specialist; engage the task team leader. Carry out a desk review of the project-level GRM (see worksheet in appendix A). Organize and hold a videoconference with relevant PIU officials to appraise them of the objectives of the initiative, the first mission, and the preparations required; identify the PIU GRM counterpart. Share the blank GRM self-assessment checklist (see appendix B) with each PIU and request their grievance logs; share the completed checklist with the project’s social development specialist and task team leader. As part of mission schedule preparation (see appendix C for sample agendas), request field trips to organize discussions with local PIU members and focus groups with project-affected parties from multiple categories, including women, youth, elderly, disabled, urban/rural, as well as potential and actual complainants. DURING THE MISSION Days 1 and 2 Meet with the GRM counterpart and other relevant heads of departments from the PIU; try to schedule a briefing on the mission with the PIU’s project or executive director. Finalize field visit schedule a (see following section on field visits and meetings). Organize GRM kick-off workshop with PIU(s) to complete the GRM self-assessment and conduct a strengths, weaknesses, opportunities, and threats (SWOT) analysis; share international best practices on grievance redress. Field visits and meetings Meet with representatives from all administrative and community levels who play a role in the GRM, such as district/field administration and community-level grievance committees. (See appendix D for list of suggested questions.) Meet with other relevant PIU teams, such as the information technology team in charge of the management information system, the monitoring and evaluation team, and the communications team (see appendix D); review available and relevant GRM logs. Meet with actual and potential complainants (see appendix E for list of indicative questions); collect examples of actual cases. Encourage the PIU GRM counterpart to begin developing possible activities for inclusion in the GRM action plan. Ask the GRM counterpart to submit project-level grievance data in reporting format (see appendix G). Consolidate findings and observations from meetings and field visits into a presentation for sharing in wrap-up workshop; identify existing gaps in GRM implementation and summarize them in the presentation. 3 2. OVERVIEW OF ACTIVITIES BEFORE, DURING, AND AFTER A TECHNICAL ASSISTANCE MISSION Final day Organize a wrap-up workshop with PIUs to validate the preliminary GRM assessment findings, and invite PIUs to generate and present a GRM strengthening action plan. (See appendix F for an action plan template.) Encourage the PIU GRM counterpart to present the GRM strengthening action plan to PIU management. Hold wrap-up meetings to debrief relevant World Bank team members on the GRM assessment mission. Agree on follow-up dates and a potential follow-up mission, as needed. After the mission Immediately Finalize the GRM assessment. Provide inputs and recommendations based on the assessment’s findings for inclusion in aide-mémoire, implementation status and results reports, mid-term reviews, and project restructuring papers. Organize a follow-up videoconference with the social development specialist, as needed. Every two to three months Organize follow-up videoconferences with PIUs, as needed. Request regular reporting on GRMs. Request spot checking to evaluate the functionality of the GRM. a. If, due to external circumstances such as the COVID-19 pandemic, field visits are not possible, teams may consider conducting some meetings and interviews with GRM actors remotely using online communication tools or organizing in-person interactions in settings that guarantee the safety of participants (e.g., small group meetings in open spaces with protective personal equipment, respecting all sanitary and epidemiological safety guidelines). GRM = grievance redress mechanism; MIS = management information system; PIU = project implementation unit. 4 Appendixes T he appendixes presented in this section comprise a set of validation/action planning workshops with PIUs. Appendixes D easy-to-use tools for assessing a project-level grievance and E list indicative questions that can be used during GRM redress mechanism (GRM) using a human-rights-based assessment field visits, whether with stakeholders from approach. Appendix A provides guidance on how to conduct national and subnational PIUs or actual and potential GRM a desk review of a given project-level GRM. Appendix B is a users. Appendix F is a template of a GRM strengthening action suggested self-assessment checklist that can be filled out by plan. Finally, Appendix G proposes a standardized way to report relevant Project Implementation Unit (PIU) staff. Appendix C project-level grievance data. proposes sample agendas for GRM mission launches and Appendix A. Grievance Redress Mechanism Desk Review Worksheet Objective Methodology A pre-mission grievance redress mechanism (GRM) desk The GRM desk review should be prepared by the project’s review compiles information on the project-level GRM, first social development specialist. A worksheet (see below) can to determine if one has in fact been established, and then to aid in compiling information from the following documents: assess its functionality and effectiveness. This exercise can project appraisal document (and project restructuring paper identify information gaps to address during the mission; inform if applicable), project operations manual, implementation discussions with project implementation unit (PIU) staff; and status and results reports, aide-mémoires, and mid-term generate ideas for improving the GRM that can be discussed in reviews. For projects applying World Bank Safeguards detail with PIU staff. Policies or Environmental and Social Standards, the following additional documents should be reviewed: Environmental and Social Management Framework, Environmental and Social Management Plans, Environmental and Social Impact Assessment, Resettlement Policy Framework, Resettlement Action Plan, Indigenous Peoples Development Framework, Indigenous Peoples Development Plan, Environmental and Social Commitment Plan, and Stakeholder Engagement Plan. 5 APPENDIXES Desk Review Sample Worksheet I. Project information Name of project, including any additional financing Example: (and project number) Project name (P000000) Country Project implementation unit Task team leader(s) Lead global practice(s) Social development specialist/consultant(s) Effectiveness Closing date/revised closing date Project development objective Summary of project components ($) Example: Component 1: Description (Cost $xx M). Component 2: Description (Cost $xx M). Component 3: Description (Cost $xx M). Relevant safeguard policies and Environmental and Social Framework standards II. References to GRM in safeguard instruments, plans, and other project documents (e.g., project appraisal document, project operations manual, implementation status and results reports, aide-mémoires, and mid-term reports) Instruments/plans (date or sequence) Description Note: Since 2018, World Bank task teams have been required to answer three questions in internal semiannual project implementation status reports: (1) Is there a GM in place? (2) Is the GM accessible? (3) Is there evidence that the GM is receiving and resolving complaints? Reviewing the answers to these questions can serve as a useful starting point. III. References to GRM in project documentation (in chronological order) Name of document (date) Description IV. Information gaps and questions about the GRM V. Initial recommendations to improve the GRM (based on desk review findings) 6 APPENDIXES Appendix B. Checklist for Self-Assessment of Grievance Redress Mechanism Prior to or on the first day of a mission, the World Bank team should ask relevant project implementation unit (PIU) staff to complete and return the following checklist, which should then be shared with the project’s task team leader and social development specialist.* A. Systems issues h. Procedures for handling anonymous complaints? o Yes o No 1. Does the project invite feedback and grievances? o Yes o No i. Procedures for handling allegations of gender-based violence, sexual exploitation and abuse, and sexual 2. Does the organization have a written grievance redress harassment? policy? o Yes o No o Yes o No (If yes, please provide.) B. System and staff management 3. Does the grievance redress mechanism have the following 4. Is effective grievance redress supported by statements from features: project leadership? o Yes o No a. A comprehensive definition of all types of feedback that can be received? 5. Is a senior manager responsible for the operation of the o Yes o No grievance mechanism? o Yes o No b. A clear and understandable procedure for providing feedback and/or submitting a grievance? 6. Is there a grievance manual for staff? o Yes o No o Yes o No c. A statement about who is responsible for dealing with 7. Are the grievance policy and procedures communicated to feedback and grievances? all staff? o Yes o No o Yes o No d. Procedures for investigating and resolving grievances 8. Are financial resources allocated to the grievance depending on their seriousness and complexity? mechanism adequate for its effective functioning? o Yes o No o Yes o No e. A system for keeping complainants informed through 9. Is there adequate staff—in terms of numbers and status updates? competence—with assigned roles for grievance o Yes o No resolution? o Yes o No f. A system for recording feedback, grievances, and outcomes? 10. Do frontline staff have specific instructions on how to o Yes o No handle or refer grievances? o Yes o No g. Procedures for protecting the confidentiality of complainants? 11. Does the organization provide staff training on grievance o Yes o No management? o Yes o No *This checklist closely follows the Environmental and Social Framework GRM checklist with a few adaptations. 7 APPENDIXES 12. Is an internal review conducted when a complainant is 23. Are users able to submit feedback/grievances: dissatisfied with the organization’s initial response? a. Verbally/in-person, such as to a grievance redress o Yes o No mechanism focal point at a physical facility? 13. Are reviews carried out by an officer who is more senior o Yes o No than the original case officer? b. By letter (mail) o Yes o No o Yes o No C. Communication to grievance mechanism users c. By telephone/hotline? 14. Are users informed about how to submit feedback or a o Yes o No grievance? d. By email? o Yes o No o Yes o No 15. Is an informational brochure on the grievance mechanism e. Via an online form on a website? available to users? o Yes o No o Yes o No f. Through a tablet/smartphone application? 16. Are feedback/grievance forms available to users? o Yes o No o Yes o No g. Via social media (e.g., Facebook, Twitter)? 17. Are grievance forms or signs prominently displayed and o Yes o No readily accessible? o Yes o No h. By SMS/text, including WhatsApp? o Yes o No 18. Is there an available and advertised feedback/grievance hotline or toll-free number? i. Via a grievance box o Yes o No o Yes o No 19. Are the contact details of staff who receive feedback and 24. Is assistance available to users who need help submitting grievances published and publicly displayed? feedback/grievances? o Yes o No o Yes o No 20. Does the organization’s website include information on 25. Can the grievance mechanism be accessed free of charge? grievance management? o Yes o No o Yes o No 26. Do users have to create a profile or register before 21. Is information on grievance management available in local submitting an online complaint? languages? o Yes o No o Yes o No 27. Are users promised confidentiality? 22. Is information on grievance management available to o Yes o No people who are unable to read and write? 28. Are users informed about whether complaints can be o Yes o No submitted anonymously? o Yes o No 29. Are users informed about the appeals process? o Yes o No 8 APPENDIXES D. Recording of feedback and grievances F. Analysis and feedback 30. Are all feedback/grievance submissions recorded? 39. Is someone responsible for identifying grievance trends and o Yes o No underlying causes? o Yes o No 31. Are feedback/grievances submissions logged into a case management system? 40. Are regular internal reports produced for senior o Yes o No management on feedback and grievances? o Yes o No 32. Are inquiries, suggestions, and recommendations recorded? o Yes o No 41. Is one of the organization’s key performance indicators (or project-level results framework) related to grievance 33. Are all outcomes and responses to feedback and grievances resolution? recorded? o Yes o No o Yes o No 42. Is there a procedure or mechanism for collecting E. Performance standards satisfaction levels and other feedback from complainants 34. Are performance standards in place for dealing with upon closure of their cases? feedback/grievances? o Yes o No o Yes o No 43. Do feedback and grievance reports include data on: 35. Is the receipt acknowledged within a stipulated time frame? a. Number of feedback or grievance submissions received? o Yes o No o Yes o No 36. Are the grievances supposed to be resolved within a b. Compliance with performance standards? stipulated time frame? o Yes o No o Yes o No c. Issues raised in feedback and grievances? 37. Are interim or progress reports submitted within a o Yes o No stipulated time frame? o Yes o No d. Trends in feedback and grievances over time? o Yes o No 38. Is there a quality control system in place to: e. Profiles of complainants (e.g., gender, age, and a. Check if all grievances have been handled or disability)? addressed? o Yes o No o Yes o No f. Whether or not remedial action was warranted? b. Check if all aspects of a grievance have been o Yes o No addressed? o Yes o No g. The actual redress that was provided? o Yes o No c. Check if all necessary follow-up actions have been taken? h. Recommendations/strategies to prevent or limit future o Yes o No recurrences? o Yes o No d. Check that underlying problems have been identified and addressed? 44. Are reports about feedback and grievances made public o Yes o No periodically? o Yes o No 9 APPENDIXES Appendix C. Sample Agendas for Grievance Redress Mechanism Launch and Validation Workshops with Project Implementation Units Strengthening the Grievance Redress Mechanism (GRM) for [Project Name] Example: Draft agenda for Launch Meeting with Project Implementation Units (PIUs) (half day—Mission Day 1 or 2) Time Description 8:00 a.m.–8:30 a.m. Welcome and Introduction • Introductory Remarks and Presentation of Context (GRM initiative, program, and mission objectives) • Introduction of Participants 8:30 a.m.–9:30 a.m. Session 1: What Makes a GRM Effective? • Establishing a Project-level GRM: What, Why, and How? • Guaranteeing the Human Right to Remedy Through Effective GRMs • Q&A 9:30 a.m.–9:45 a.m. Coffee Break 9:45 a.m.–10:45 a.m. Session 2: Best Practices for GRMs • Best Practice Examples (global and regional) • Dos and Don’ts 10:45 a.m.–12:00 p.m. Session 3: Group Activity: Assessing the Strengths and Weaknesses of a Project GRM • SWOT (strengths, weaknesses, opportunities, threats) analysis of GRMs (building on self-assessment survey filled out prior to the mission) • Report to the Plenary Strengthening the GRM for [Project Name] Example: Draft agenda for Validation Workshop and Action Planning (one day, at the close of the mission) Note: The following sample agenda assumes that the GRM assessment mission worked with several PIUs to strengthen GRMs across several projects. Time Description 9:00 a.m. –09:30 a.m. Meeting with PIU #1: Presentation of Mission Findings, Gaps, and Good Practices 09:30a.m.–10:00 a.m. Meeting with PIU #2: Presentation of Mission Findings, Gaps, and Good Practices 10:00 a.m.–10:30 a.m. Meeting with PIU #3: Presentation of Mission Findings, Gaps, and Good Practices 10:30 a.m.–11:00 a.m. Coffee Break 11:00 a.m.–11:30 a.m. Meeting with PIU #4: Presentation of Mission Findings, Gaps, and Good Practices 11:30 a.m.–12:00 p.m. Meeting with PIU #5: Presentation of Mission Findings, Gaps, and Good Practices 12:00 p.m.–1:00 p.m. Lunch Break 1:00 p.m.–2:40 p.m. Plenary Meeting with all PIUs Group Activity: Enhancing GRMs and Next Steps • Presentation of Action Plan Template (15 minutes) • Development of GRM Action Plans in Small Groups (60 minutes) • Report back to the plenary (5 minutes per group = 25 minutes) 2:40 p.m.–3:00 p.m. Wrap-Up • Key Takeaways and Next Steps • Closing 10 APPENDIXES Appendix D. List of Indicative Questions for National and Subnational Project Implementation Units and Other Stakeholders During Field Visits Note: Task teams should select the relevant questions from the following list. Not all questions are applicable or relevant to every project-level grievance redress mechanism (GRM) or context. Country Relevant project(s) Name of project implementation unit (PIU)/institution Location Name, designation, and contact information of respondent Date Indicative Questions Findings and Observations National Level Subnational Level CROSS-CUTTING PIUa Other PIUa Other Stakeholdersd Stakeholdersb Organizational structure Is there a GRM manual that specifies systems, processes, procedures, and roles/ •  responsibilities? Are there clear principles of GRM (e.g., fairness, objectiveness, independence, •  confidentiality, accessibility, responsiveness, efficiency, proportionality, social inclusion)?e Does the GRM have multiple levels/tiers that allow for an escalation or appeal? •  Does the GRM have an advisory body/group to ensure that grievance redress •  outcomes are satisfactory and that the GRM is performing well? Is there a GRM focal point at the PIU level and/or at each relevant office? If so, •  how many? How are grievances about the World Bank-financed project treated if they are •  channeled through the in-country systems or as a plea to the prime minister’s office, to a minister, or to elected officials? Is there a stipulated resolution timeline? What is the current practice? •  How are allegations of gender-based violence, sexual exploitation and abuse, •  and sexual harassment being handled? 11 APPENDIXES PIUa Other PIUa Other Stakeholdersd Stakeholdersb Communications and awareness raising Are there any communication materials (e.g., booklets or posters) available to •  PIU and frontline GRM staff on grievance resolution processes and procedures? Are there any communication materials available for the public? What are they? •  How are they disseminated? Are they provided in local languages? Do they reach people who are unable to read or write? Are clear timeframes/standards for the various steps of the GRM process •  (acknowledgment, update, and response) publicly available? Do nongovernmental organizations and civil society organizations play a role in •  grievance collection and/or resolution? Do they play a role in communications and awareness raising? Were there any consultations with project-affected parties/beneficiaries during •  the GRM design stage on preferred channels for submitting feedback and/or receiving updates on the GRM? Did the consultations involve a variety of groups, such as women, youth, and rural/urban populations? Training and peer-to-peer learning Is any training available on grievance collection and resolution for staff at all •  levels? If so, is it mandatory for all PIU members? Is there a way for PIU GRM focal points and frontline GRM staff to communicate •  and share information with one another, such as WhatsApp or Facebook? GRM VALUE CHAIN Uptake What are the uptake channels for grievances (e.g., website, social media, •  grievance box, email, telephone, mail, in person, smart phone app)? How many uptake channel locations are there? If the mechanism is a grievance •  box, where is it located, who opens it, and how frequently? How many and what types of grievances are collected? Are grievance data •  disaggregated by location, gender, age, beneficiary/citizen, and other indicators? Can a GRM user submit an anonymous complaint? •  Sorting and processing How is feedback categorized, logged, and prioritized? •  To what department are feedback cases referred when they are categorized and •  prioritized? Acknowledgement and follow up Do GRM users receive an acknowledgment of their feedback or grievance •  submission? If so, how? Are users given a case number and information on how to receive updates? How are GRM users provided progress updates? Do they need to proactively seek •  them or does the PIU periodically update feedback providers and complainants? Are GRM users informed of the timeline and process for addressing their •  feedback? 12 APPENDIXES PIUa Other PIUa Other Stakeholdersd Stakeholdersb Verification, investigation, and actions How does the PIU gather additional information or insights that may be •  necessary to resolve the issue? How is feedback resolved? •  How is feedback escalated to higher levels at the backend, absent an appeal by •  a complainant? Is there a mechanism to verify the resolution and actions taken within the PIU/ •  agency? Monitoring and evaluation How are grievances documented? Is there a GRM module in the Management •  Information System or a standalone GRM Management Information System? Is the grievance database paper-, book- or Excel-based? How are grievances received through various uptake channels and/or collated •  and reported on at multiple levels? Does the grievance log accurately reflect the entirety of project-related GRM •  submissions by affected people, including grievances received verbally or submitted at the local level? How is feedback tracked by the PIU management? •  Are feedback data analyzed and reported? How? How are they used? •  Does the PIU management and ministry/agency receive regular reports on trends •  in feedback receipt and resolution? What indicators are used to report on the GRM’s performance and trends? Is the GRM and citizen feedback part of the PIU meeting agenda? •  Is resolution of grievances a key performance indicator for the PIU or agency? •  Providing responses to GRM users Are GRM users informed of the action(s) taken in response to their feedback? •  How? When responses are provided to GRM users, is there a mechanism for those •  users to rate or comment on their experiences with the resolution service (i.e., to evaluate the satisfaction of GRM users)? How is this feedback collected? How are these data and information being used? Is information about the feedback and the action(s) taken in response made •  available to the public (e.g., in an annual report)? If anonymous complaints are accepted, how does the PIU/agency communicate •  about the outcomes and action(s) taken in response to them? Does the GRM administer a satisfaction survey of complainants to close the •  feedback loop? GRM = grievance redress mechanism; PIU = project implementation unit. a. National-level PIU: GRM specialist, social and environmental safeguards specialists, monitoring and evaluation specialist, communications specialist, management information system specialist, procurement specialist b. Other national stakeholders: Relevant staff from the same agency/ministry, relevant staff from other agencies/ministries, third-party monitors, ombudsman, anticorrup- tion commission, NGOs, gender-based violence service providers, media c. Subnational-level PIU: Field coordinators, GRM specialists, monitoring and evaluation focal points, management information system specialists, community liaisons, grievance committee members d. Other subnational stakeholders: Laborers, contractors, community monitors, NGOs, gender-based violence service providers, media e. For a more specific breakdown of the implications of each of these principles for the functioning of a GRM, see Post and Agarwal 2011. 13 APPENDIXES Appendix E. List of Indicative Questions for Actual and Potential GRM Users for Field Visits Note: Task teams should select the relevant questions from the following list. Not all questions are applicable or relevant to every project-level grievance redress mechanism (GRM) or context. Ideally, different categories of users should be consulted to investigate whether the GRM matches the preferences of the various segments of project-affected parties (such as women, youth, and people with disabilities). Country Relevant project(s) Name of respondent Name of locality Visitation date Indicative Questions Areas Actual GRM Users Potential GRM Users Cross-cutting Communications and awareness How did you learn about the project-level GRM? •  Are you aware of the project/program GRM? •  raising When you submitted your feedback to the project’s •  If yes: GRM, did you use any other GRM in parallel? How did you learn about it? •  If yes: If you had a question, complaint, or suggestion •  Can you share information on the other GRM? •  for the project, would you use: (1) the project’s GRM; (2) another GRM (please specify); (3) both; or (4) none? If yes to (2) or (4): • What are your concerns about this GRM? If no: What would have been a useful source of •  information for you to know about this GRM? GRM value chain Uptake How did you provide feedback? Was it easy for •  Do you know what channels you can use to provide •  you to access the GRM? Did you need to pay for feedback through this GRM? something to submit feedback? (e.g., cost of Do you know what type of feedback you can provide? •  call, transportation to travel) Or ask someone to facilitate the process? In case you used a complaint/grievance/feedback •  form, was it easy to fill it out? Did someone help you prepare the form? If you submitted a complaint in person or over the •  telephone, did you feel that you are treated with respect? What is your preferred method of grievance •  submission? 14 APPENDIXES Indicative Questions Areas Actual GRM Users Potential GRM Users Verification, investigation, and Were you asked to submit additional information and action documents? Were you provided with an explanation of why additional information and documents are needed? Was it easy to submit them? How did you submit them? Did you need to travel to submit documents or pay for a service (e.g., fax, scanning, the internet connection)? Monitoring and evaluation Were you asked to provide feedback on your experience using the project-level GRM? How? As a result of your feedback, have there been any changes in the project team’s actions or policies so that similar experience would be less likely to occur? Can you share examples? Responding to the GRM user Were you informed of the result(s) and any actions Are you aware of how GRM users are informed taken? How did you learn about it? about the resolution? Do you talk about feedback at community meetings? How long did it take for the feedback to be resolved? Are you aware of how many feedback cases have been Were you informed about the appeal process in collected and resolved? case you were not satisfied with the outcome of the resolution? Are you aware that there is an appeals process for those dissatisfied with the outcome or the process of Did you decide to appeal? If not, why (Were you grievance resolution? satisfied with the resolution outcomes and/or processes, or was there something else?)? If you Are you aware of any retaliation against people who decided to appeal, how was your experience? have previously complained? Are you aware of any retaliation against people who have complained before? 15 APPENDIXES Appendix F. Worksheet/Template for GRM Strengthening Action Plan (with Illustrative Activities) Country Project Implementation Unit (PIU)/project name Project effectiveness and closing dates Name and contact of PIU head Name and contact of PIU grievance redress mechanism (GRM) focal person Responsible Additional Person and Human Status Contact Details Resources Budget Timeframe 3 completed (name, position, Required Allocated Required (Completion g in progress GRM Area Proposed Actions email) (if any) Budget (if any) Date) 7 not completed Comments Cross-cutting Organizational 1. Appoint GRM focal point at headquarters. structure 2. Appoint committee at municipal level per the Resettlement Action Plan or GRM operations manual. 3. Develop a GRM manual (standalone or as part of the operations manual) with clear processes and procedures. 4. Generate resolution processes and stipulate resolution timelines for various types of complaints. 5. Institute an additional level of appeal for dissatisfied complainants. 6. Coordinate with the public relations/ communications department and utilize their outreach channels. 7. Other (specify): 16 APPENDIXES Responsible Additional Person and Human Status Contact Details Resources Budget Timeframe 3 completed (name, position, Required Allocated Required (Completion g in progress GRM Area Proposed Actions email) (if any) Budget (if any) Date) 7 not completed Comments Communication 1. Produce GRM communication materials in line with and awareness project-affected people’s preferred communication raising channels. 2. Disseminate GRM communication materials (specify location and frequency). 3. Integrate information about GRM in training materials for project staff. 4. Integrate GRM information into project communication materials intended to raise awareness in communities as well as on the website. 5. Circulate hard copies of GRM communication materials, including the grievance receipt form (along with the Resettlement Action Plan and Environmental and Social Management Plan) during consultations. 6. Arrange for periodic awareness-raising sessions for senior management and other headquarters staff (legal and operations), as needed. 7. Other (specify): Training and peer- 1. Develop easy-to-understand GRM communication to-peer learning materials (e.g., handbook, booklet, posters) for GRM staff. 2. Carry out onboarding and refresher trainings for all GRM focal points at headquarters and at other relevant local levels (e.g., regional and municipal). 3. Integrate an information session on GRM into the PIU/project staff training and into a management meeting. 4. Other (specify): 17 APPENDIXES Responsible Additional Person and Human Status Contact Details Resources Budget Timeframe 3 completed (name, position, Required Allocated Required (Completion g in progress GRM Area Proposed Actions email) (if any) Budget (if any) Date) 7 not completed Comments Gender-based 1. Assign a GBV focal person in the PIU. violence, sexual 2. Develop a clear policy on how to handle allegations exploitation and of GBV and SEA/SH; refer survivors to relevant service abuse, and sexual providers and notify the World Bank. harassment 3. Conduct GBV training and/or information session for relevant PIU staff. 4. Include a GBV module in worker trainings on the code of conduct and in awareness-raising campaigns in communities. 5. Other (specify): Labor and staff- 1. Clarify how the project addresses staff grievances in related issues the operations manual or other document. 2. Specify how the contractor will address grievances received from workers. 3. Other (specify): GRM value chain Uptake 1. Identify complaint uptake locations that project- affected people would feel most comfortable using. 2. Widen the range of complaint uptake channels (e.g., create dedicated hotline and email address). 3. Design or improve complaint-receipt forms. 4. Other (specify): 18 APPENDIXES Responsible Additional Person and Human Status Contact Details Resources Budget Timeframe 3 completed (name, position, Required Allocated Required (Completion g in progress GRM Area Proposed Actions email) (if any) Budget (if any) Date) 7 not completed Comments Sort and process 1. Create clear sorting and processing procedures from complaint uptake to resolution. 2. Develop an escalation mechanism. 3. Establish a simple filing/catalog system for complaints. 4. Other (specify): Acknowledgement 1. Generate a complaint number and provide it to and follow up complainant. 2. Issue an acknowledgment of received complaint. 3. Inform complainant on the stipulated resolution timeframe and next steps. 4. Issue final response to complainant. 5. Other (specify): Verify, investigate 1. Establish an investigation and resolution process and act at the PIU and local levels with clear procedures and assignments. 2. Ensure that the PIU verifies all actions taken. 3. Assign a point person (preferably from management) to conduct periodic spot checks on grievances. 4. Other (specify): 19 APPENDIXES Responsible Additional Person and Human Status Contact Details Resources Budget Timeframe 3 completed (name, position, Required Allocated Required (Completion g in progress GRM Area Proposed Actions email) (if any) Budget (if any) Date) 7 not completed Comments Monitor and 1. Create, design, or improve the complaints evaluate registration database. 2. Analyze grievance data (e.g., disaggregated by gender, province/district, vulnerable group, type of complaint, and uptake channel). 3. Regularly produce reports on grievance resolution for the PIU and the public (specify frequency and type of report). 4. Start discussing the grievance resolution performance and monitoring data at the PIU grievance management committee meetings. 5. Other (specify): Provide feedback 1. Collect feedback from complainants on their experiences and levels of satisfaction. 2. Disclose findings in annual report on grievance redress or include information on progress and challenges related to grievance redress in the organization’s annual report to the public. 3. Other (specify): GBV = gender-based violence; GRM = grievance redress mechanism; PIU = project implementation unit; SEA/SH = sexual exploitation and abuse/sexual harassment. Note: This table compiles the most common activities of various action plans. If any of the listed activities do not relate to a given project, they should be omitted. 20 APPENDIXES Appendix G. Suggested Reporting Format for Collecting Project-Level Grievance Data Project Name P Number Lead Sector Additional Sector(s), if applicable Country Name Task Team Leader Key project information Name(s) of person(s) filling out form Contact details for person filling out form Date of project effectiveness Date of GRM Action Plan Development Date at which this form was filled out Number of months between project effectiveness and GRM Action Plan Dvt #VALUE! (calculated automatically) Number of months between GRM Action Plan Dvt and today (calculated #VALUE! automatically) Phase 1 Phase 2 Phase 3 From project 3 months after AP 6 months after AP Notes or Comments from individual(s) completing Reporting indicators effectiveness to AP development development (+ 90 days) development (+ 120 days) worksheet Volume of grievances 1 Number of grievances brought forward/carried over from previous period 0 0 0 2 Number of grievances received during reporting phase 3 Number of grievances resolved 4 Number of grievances pending for more than 30 days 5 Average number of grievances received per month #VALUE! 0.0 0.0 6 Percentage of grievances resolved #DIV/0! #DIV/0! #DIV/0! Responsiveness of GRM Average number of days between complaint receipt and complaint 7 acknowledgment 8 Average number of days between complaint receipt and complaint resolution Data analysis about complaints 9 Data about complainants can be analyzed by: gender Yes 10 Data about complainants can be analyzed by: location; urban/rural 11 Data about complainants can be analyzed by: age 12 Data about complainants can be analyzed by: employment 13 Data about complainants can be analyzed by: disability Closing the feedback loop 14 Is a satisfaction survey being administered with complainants? 15 Percentage of complainants satisfied with resolution Legend: Cells with a yellow background color need to be filled out. Kindly indicate the data requested. Cells with an orange background color have a drop-down menu option: please select "yes" or "no". Cells with a grey background color are pre-populated and automatically calculated. You don't need to fill these out. Note: This table provides an example of how grievance data can be reported. An excel-based reporting format is also available. Kindly send an email to Sanjay Agarwal (sagarwal2@worldbank.org) to request it, if needed. 21 SUPPORTED BY © 2022 International Bank for Reconstruction and Development/The World Bank 1818 H Street NW, Washington, DC 20433 202-473-1000 | www.worldbank.org Some rights reserved. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. Nothing herein shall constitute or be considered to be a limitation upon or waiver of the privileges and immunities of The World Bank, all of which are specifically reserved. Rights and Permissions The material in this work is subject to copyright. 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