The design of the EPSGG-LVB project brings on board a multiplicity of stakeholders including the potential beneficiaries and populations residing around the participating enterprises. Since these stakeholders might be affected by project interventions in one way or another, it becomes imperative to put in place a mechanism through which they can raise grievances and have them satisfactorily addressed. A Grievance Redress Mechanism (GRM) also plays a critical role in preventing negative interruptions in project implementation occasioned by legal redress that are costly and time consuming. Further, the GRM have become one of key performance rating factor and requirement for World Bank-funded projects globally. It spells out avenues to mitigate grievances from stakeholders and provides a legitimate, accessible and cost-effective avenue for receiving and addressing grievances whenever they occur It is on this basis that it was found necessary to put in place a GRM for this project
Objectives of the GRM:
The overall objective of the EPSGG-LVB GRM is to provide people or groups of people and stakeholders affected by project interventions access to mechanisms that are legitimate, reliable, transparent, and cost-effective to enable them to present their grievances and find solutions that satisfy their needs and aspirations.
The specific objective of the GRM is to:
- Operationalize structures for receiving and addressing grievances emanating from project interventions and providing feedback;
- Sensitize stakeholders on the existing avenues and channels for registering and resolving grievances;
- Build capacity of relevant stakeholders on the implementation of the EPSGG-GRM; and
- Mitigate negative impact of grievances emanating from project interventions;
Scope and types of Grievances
The GRM for EPSGG-LVB will be solely dedicated to handling grievances that only relate to or emanate from activities that are financed by the project funds at national and regional levels and not the independent activities and operations of the targeted and participating enterprises. The type / scope of grievances to be accommodated include grievances related to:
- Inadequate stakeholders’ consultation and participation at any stage of project implementation;
- Negative social and environmental impacts emanating from the implementation of RECP options recommended by the in-plant assessments;
- Concerns on recommendations or content of the Regional and or national Consultancy work executed / funded under the project (both World-Bank & Client Executed);
- Concerns on prioritisation and / or distribution of project interventions;
- Concerns on social and environmental safeguards matters;
- Economic impacts and concerns emanating from or related to project interventions; and
- Gender and inclusivity related concerns.
Concerns that might be raised outside the above will be redirected to other GRMs at relevant levels at national and EAC levels. Matters that are within project management and coordination will not trigger the use of this GRM but will be dealt with administratively within the project.
Procedures and Time Frames for Grievance Redress
Step 1: Grievance reception/acceptance and record
Grievances will be reported to the Lake Victoria Basin Commission Secretariat. If this is not possible, the grievance may be reported at the National Cleaner Production Centres, National Focal Point Ministry Headquarter, their District offices, lowest administrative unit and the participating enterprise, who will immediately forward the same to the LVBC Secretariat. Complaints can be presented in a variety of forms including a letter addressed to the Executive Secretary, LVBC; an email to the address provided, or verbally to the administrator who will assist in documenting and reporting in the prescribed format. Once the compliant is received at the Secretariat, it will be accepted, stamped with a received stamp that indicates the date received and registered with a reference number in the grievance/complaint register by the designated Focal person (Registry Clerk) in a prescribed format provided.
If the complaint is received at the designated reception points, the designated officer will accept, stamp the complaint as received, record and forward it to LVBC Secretariat within 2 days of receiving it.
Step 2: Acknowledgement, assessment, and record
Having received and registered a complaint, the designated officer will notify the Executive Secretary and the grievance committee chair, who will then notify the complainant that their grievance has been received within a period of 3 days. The next step in the complaint-handling process is for the grievance committee either at NCPCs or LVBC level/designated officer at the participating enterprise to establish the eligibility of the complaint received.
If the complaint is not eligible, the complainant will be informed of the reasons.
If the complaint is eligible, the GC, will then agree on the appropriate investigation, and the complainant will be informed of the next steps and the time frames including any further information/documentation required will be requested. This should take place not later than 15 days after the compliant is received.
Step 3: Investigation
The GC at National (NCPCs), LVBC and Designated officer at the enterprise level will begin the investigation by assessing the seriousness of the complaint—classified in terms of high, medium, or low—and its impact on both the complainant and the project.
Assessing the severity and investigation of a complaint may require additional data collection. In this case the GC at National (NCPCs), LVBC and Designated officer at the enterprise level will collect this data by cross-checking the information already provided, through field visits to the sites, discussions and interviews with complainants and other relevant persons or groups in the community, and through follow up meetings between complainant and the offender in the presence of a neutral party. This process is recorded in terms of a report or minutes of the meeting. These records will be kept in the grievance data base located at the LVBC Secretariat.
Step 4: Resolution
Depending on the findings and their severity, a resolution will be decided immediately. However, if the case cannot be handled at 1st instance at the designated officer at the enterprise levels the matter is escalated to the 2nd instance at National level (NCPCs). If the matter is not resolved there, it shall be escalated to the 3rd level at LVBC. If the project GRM levels are unable to resolve the grievance, the case will be referred to national level grievance mechanism/court if it is national in nature; or to the GRM at the East African Court of Justice as will be deemed appropriate, if the complaint is regional in nature.
This process should take a maximum of 30 days from the time the parties are informed of the acceptance of the grievance.
Step 5: Complaints satisfaction
The outcome of the implementation of the resolution mechanism will be a written agreement signed by the plaintiff(s) and the Executive Secretary of the LVBC. This agreement will outline the agreed strategies for settlement of the grievances; including but not limited to
- requesting the relevant agencies responsible for the grievance to take appropriate measures to remove the cause of grievance,
- determining reasonable compensation for loss from the accused parties;
- signing agreements between APs and the project for solutions mutually agreed upon
In the event that a resolution is not arrived at the complaint will be referred to the next level ,the National Courts, or East African Court of Justice as will be deemed appropriate.
Step 6: Monitoring and Documentation management
The Grievance Committee (GC) at National (NCPCs), LVBC and Designated officer at the enterprise level will establish and document a monitoring/tracking process (after addressing the causes of the problem or paying compensation) to assess any further impacts of project-related work on the properties and livelihoods of the APs. The GC will be responsible for tracking and monitoring the process of grievance redress and the implementation of the decisions made and of seeing that redress is granted to APs in a timely and efficient manner. They also have the responsibility for giving regular feedback to the complainants about the progress of the grievance redress process.
The LVBC Secretariat, will maintain databases on all complaints, how they are resolved, and an update on implementation of the resolutions. The log will include a record of persons / committee responsible for a complaint and record dates for the following events, when the; (i) Complaint was reported, grievance log was uploaded on the project database; \(iii) information on proposed corrective action was sent to the complainant (if applicable); (iv) complaint was closed out; (v) response was sent to the complainant. The LVBC Secretariat will set up an evaluation system to assess the overall effectiveness and the impact of the GRM. The Mechanism will be evaluated annually, and their results used to improve the performance of the GRM and provide valuable feedback to project management.
Who and How
Who can submit a complaint?
The GRM accepts complaints that are:
- Related to the EPSGG-LVB Project;
- Filed by a person or community who believes they are directly and adversely affected by the EPSGG-LVB project
- Not filed anonymously. The identity of the complainant will be kept confidential if requested, but anonymous complaints will not be accepted.
How to file a complaint?
- Complaints must be in writing and addressed to the EPSGG-LVB Grievance Redress Mechanism (GRM) using the address provided below
- This EPSGG-LVB Project GRM complaint form may be used.
- Complaints will be accepted by email, letter and by hand delivery to: