Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

Addressing Complaints and Grievances

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

Addressing Complaints 2

Identifying and managing problems and risks in projects where grievances are being or are likely to be raised

Addressing legitimate concerns of project affected people while protecting the Bank from frivolous claims

Ensuring that concerns/grievances from the communities or others are promptly heard, analyzed, handled and answered in order to detect causes and take corrective or preventive actions and to avoid escalation to other levels of grievance redress, unless necessary

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

Complaints typically evolve… Early action pays off…3

Issue Concern Grievance

IssuePAP seeks solution internally

PAP seeks solution externally

Cost HigherCost Lower

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

Key challenge: Assess and appropriately address complaint

4

Concern is credible / serious / legitimate

Concern is not credible /serious /

legitimate

Pertains to Project/Bank

Address concern through project

Explore ways to resolve issue

Does not pertain to Project/Bank

Formally refer to national authorities

Formally refer to national authorities

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

Difficulties in assessing credibility & legitimacy of a complaint…

5

Non-project related issues /

legacy issues

Wrong perceptions / expectations about

project and its impacts

Broader political / ideological issues

Genuine project related concerns

Conflicts among communities and/or with Government

Opportunistic behavior to extract

advantages

Using Bank as intermediator in

grievances beyond the project

Using project as a platform for local

politics

Global / National (political)

campaigns

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

What is a credible / serious / legitimate complaint?6

Substance (founded) Significance (severity) Pertains to the Project / Bank

In sum: Anything that presents serious risk to the PAPs, the Project and/or the Bank.

frivolous/illegitimate complaints may need to be formally addressed to put them to bed

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

Escalation of issues - Why do reputational risks matter?7

Can damage the Bank’s credibility Can limit the Bank’s options to engage Can limit political support for the Bank Can harm the Bank’s ability to mobilize financial support Can limit Bank’s ability to attract staff Can trigger legal actions/litigation

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

Steps of Engagement for addressing Complaints8

1• Record and confirm complaint

2• Involve staff with relevant knowledge

3• Analyze complaint and complainant

4• Review project and context

5• Address complaint and complainant

6• Stay engaged

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

1. Record and Confirm 9

Promptly confirm receipt of complaint Assure response as soon as the issue has been reviewed Provide a clear time line when you will get back (doesn’t

mean a solution by then!) Do not simply refer complainant to the Government Log all communications

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

3. Analyze complaint and complainant10

Review complaint: Don’t dismiss complaint based on its presentation or form

Identify relevant issues: What pertains to the project and/or the Bank? and what to other actors?

Identify complainant: What is the relation to the project? PAP? local resident? NGO? Don’t dismiss complaints on the basis of complainant’s status

Identify complainant’s goal: This may be tangible or not: compensation, participation, project alternatives, safety concerns, etc. Again: don’t dismiss complaint on that basis

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

4. Review project and context (cont.)11

Fact finding: Important - GO ON SITE!! This cannot be done as a desk study!

Engage with project staff, the complainant and PAPs directly. Use all sources of information

Site visit allows verification of facts independently of the project authorities’ representations/assessments/judgment

Review project documentation and strengthen where necessary: Are documents complete? Disclosed? Online? Updated? Consistent?

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

5. Address complaint and complainant12

From the Start: Stay engaged and keep a record Always respond in writing (telephone follow-up) Offer to meet in person to discuss the issues Give clear timelines when you will get back to complainants Allow for sufficient time to assess and address the issues It is important that the complainant understands that the

Bank is in the process of dealing with the issue and that reasonable time is needed

Contact complainant regularly to advise on the complaint’s status

Module 12

Environmental Safeguards Accreditation Training, January 21 – 25, 2013

5. Address complaint and complainant (cont.)13

If complaint pertains to non-project / non-Bank issues, formally point this out to the complainant and inform that you have forwarded the complaint to relevant national authorities asking them to look into the matter

Follow up to make sure this is understood and (if possible) resolved before seeking another level/avenue of redress

successful complaints may trigger repeater complaints, or complaints about different issues (WB maybe seen as more responsive the Gov.)

Complaints may also trigger media coverage. NGOs may want to champion a particular issue.