Barwaaqo complaints handling mechanism

Somaliland Water for Rural Resilience Project

Overview of Barwaaqo SL Grievance Mechanism

	Details	Person responsible for checking and follow on
Email	[email protected]	Social specialist
Email GBV	[email protected]	GBV specialist
Hotline	9292	Social specialist
Hotline - GBV	9292	GBV specialist
In person	Barwaaqo Office in Ministry of Planning and National Development	Social specialist
In person GBV	Barwaaqo Office in Ministry of Planning and National Development	GBV specialist
GBV service mapping distribution to staff, contractors and community committees	In process	GBV specialist
Awareness raising – general	Website, posters in office & community centres, FM radio, and video clips	Communication/ GBV /social/ CDD specialist?
Awareness raising -  implementing partners	Training/ GM overview, posters in offices,  labour management process, and code of conduct.,	GBV/ Social/CDD specialist
Awareness raising -  contractors	Training/ GM overview, posters in offices, labour management process,  & code of conduct.	GBV/Social/CDD specialist
Awareness raising -  communities	During community meetings, posters in communities, GM overview & GBV.	GBV/ Social/CDD specialist
Awareness raising -  village development committees	Training, posters in offices, labour management process, GM overview & GBV.	GBV/ Social/CDD specialist
Grievance redress composition	Chair: PC, secretary: social specialist, environment, GBV, and Partner Ministries focal points.	PC
Workers grievance mechanism	Raise with the PC or HR department	PC

 

Overview

1. An accessible and functional grievance mechanism is an important in addressing community or stakeholder concerns as well as receiving feedback on a project so that it can be improved. It is a requirement for all World Bank projects and the responsibility of all project staff, any of whom may receive the grievance.
2. It is preferable that grievances are resolved in person at the lowest level, however different levels and channels of registering grievances should be available so that even the most marginalised person feels comfortable raising a grievance. GBV related complaints should be referred immediately the GBV specialist.
3. Grievances should be dealt with confidentially, on a need to know basis only, and without fear of backlash.  
4. Grievances can be raised by community members, workers and other stakeholder concerning project implementation including: adverse social or environmental impacts, misuse of funds; staff behaviour, workers’ conditions or safety, quality of service issues, sexual exploitation and abuse, forced or child labour etc.
5. Confidentiality and timelines: Grievances can be submitted anonymously by any complainant, and personal data should be anonymised for all complainants who raise GBV issues.  Grievances will be acknowledged within a week (7 days) of receipt and resolved if possible within 21 days including feedback to the complainant. The complaint will be addressed as fully and precisely as possible focusing on specific facts and events, showing understanding and never dismissing or belittling a complaint.
6. Cases of GBV/SEA: Such cases will be only handled by GBV focal points trained in survivor centric complaints handling and treated with utmost confidence, respect and empathy and managed in line with the complainants’ express wishes, including whether the complaint is registered and referred. The complaint will be anonymised, indicating a reference number rather than the name of the complainant.
   • All staff and GRM focal points should be informed that if a case of GBV is reported to them, the only information they should establish is if the incident involves a worker involved with the project, the nature of the incident, the age and sex of the complainant and if the survivor/complainant was referred to service provision. 
   • The complainant should be informed about available confidential health, psychological, legal and safe house or other support, including the importance of receiving PEP and PREP within 72 hours and if possible provided transport support to reach them.  The complainants wish to report and access services should be respected at all times.
   •  The GBV focal person is responsible to make a list of functioning GBV services and distribute it to all staff of the project, VDC GBV focal points and contractors GM focal points, so they are aware of where to refer complaints. This information should be displayed in the project office and infrastructure for ease of reference and updated regularly. Sharing such confidential information is a disciplinary offence.
   • AN ALLEGATION OF GBV SHOULD NEVER BE INVESTIGATED AS IT MAY DO MORE HARM TO THE SURVIVOR AND REQUIRES SPECIALIST HANDLING. If the complaint is against a worker involved in the project, the incident should be immediately reported to the National GBV specialist who will provide further guidance after consulting with the World Bank.

The social specialist is responsible for noting and reporting critical trends emerging in the GM process such as an increase/decrease in types of grievances to share with the GRC, as well as tracking complaints expressed on social media and whether and how these should be addressed. Throughout the process, the safeguards specialists will receive support from the PIU. The social specialist will use the GEMS form to register every complaint. The social specialist will receive an alert and validate the data and will download the data in excel at the end of every month and add the additional column for the log book and email to the PM.   

In summary:

1. Grievance focal points in the VDC: deal with minor info complaints or issues that can be resolved locally, inform social specialist using toll free line (who will log using the Kobo/ODK Grievance form);
2. Contractor: deal with minor info complaints or issues that can be resolved locally and communicate all complaints to the social specialist, initially via the toll free line (who will log using Grievance form in kobo), although contractors could be oriented to do that directly in future if easier;
3. E&S focal points for implementing agencies: deal with complaints due to lack of information or minor issues that can be resolved locally and communicate all complaints to the social specialist, initially via the toll free line (who will log on the Grievance form in Kobo), although contractors could be oriented to do that directly in future if easier;
4. The social specialist: refers all unresolved or serious complaints to the WB, is secretary of the GRC and follows up. GBV specialist liaises with WB GBV specialist on how to handle;
5. GBV specialist: handles all SEAH complaints.
6. Project Coordinator: Received serious incidents directly and forwards to the WB TTL within 48 hours. Chairs the GRC and oversees the functioning of the GM.

Toll-free lines, the social specialist will be responsible for operating the toll-free line, registering the complaints in Kobo and in the excel log book, and forwarding the cases to the proper entities/persons and following up the resolution and feedback to the complainant (within 21 days). In the absence of the Specialist or when on leave, the GBV specialist will be responsible for receiving the calls and filling the gap for the social specialist. Before activating the hotline, the social specialist, the GBV focal point, and other PIU staff will be trained on GM, registering the complaints, handing the GBV cases coming in through the hotline, GBV service referrals, and caller management skills. The hotline number will be operational only during office hours, from 8.00 am to 3:00 pm, Saturday to Thursday on working days. The social and GBV specialists responsible for receiving the calls, and the GRC who will be involved in the resolution of cases will all sign a confidentiality agreement to protect the complainants from any backlash.

REGISTERING A COMPLAINT:

Level	How to raise	Resolution	Type of complaints that can deal with	Awareness raising?
Village level: GRM focal person in Village Development Committee	Phone or in person	Resolve (in conjunction with VDC) or refer to social specialist	Minor complaints that can be easily resolved, especially information or adjustments by contractor	Verbally at community meetings Poster (with toll free number) on community centre or central point
Contractor: site supervisor or designate	Phone or in person	Resolve or refer to social specialist	Minor issues, adjustments in line with ESMP, dust, traffic etc.	Site handover and community meetings Overview in office and poster at site
Implementing agencies: E&S focal point	Phone or in person	Resolve (with PC/GRC) or refer to WB	All complaints should be logged into GEMS and the information downloaded every month to produce a register which is sent to the PC	Overview displayed in all offices and poster in public place and on website including of implementing agencies.
GBV specialist (in conjunction with PC and GRC), GBV focal point for complaints related to GBV	Phone or email or toll-free hotline number in Somaliland	Resolve (with PC/GRC) or refer to WB	All complaints should be logged into GEMS and the information downloaded every month to produce a register which is sent to the PC	Overview displayed in all offices and poster in public place and on website including of implementing agencies.

 

World Bank Somalia: If a grievance has been raised with the NPIU, and no satisfactory response has been raised, an email can be sent to [email protected]

World Bank Grievance Redress Service: If no response has been received from the World Bank Somalia office the grievance can be raised with the World Bank Grievance Redress Service email: [email protected]. For more information: http://www.worldbank.org/grs.

 

Resolution of complaints

A Grievance Redress Committee (GRC) will be established and chaired by the project coordinator, and the relevant PIU staff will be included as necessary depending on the complaint (Social, GBV, environment, M&E, and partner ministries focal points). The Social specialist will minute the meetings and follow up the grievance resolution process including feeding back to the complainant. The GRC will meet once every month to review summaries of the number and type of complaints and ensure that they have been satisfactorily followed up and to address any problems in the projects that may be causing complaints, review the development and effectiveness of the grievance mechanism, and ensure that all staff and communities are aware of the system and the project. Emergency meetings will be called in case of significant complaints or incidences.  For serious or severe complaints or incidences involving harm to people or the environment or those which may pose a risk to the project reputation, the social specialist should immediately inform the PC, who will inform the World Bank within 72 hours as per the Environmental and Social Incident Reporting (ESIRT) requirements.

Serious incidents

A serious incident is one that caused or may cause significant harm to the environment, workers, communities, or natural or cultural resources, is complex or costly to reverse and may result in some level of lasting damage or injury; or failure to implement E&S measures with significant impacts or repeated non-compliance with E&S policies; or failure to remedy Indicative non-compliance that may potentially cause significant impacts.

Examples of serious incidents may include injuries to workers that require off-site medical attention, exploitation or abuse of vulnerable groups, consistent lack of Occupational Health and Safety (OHS) plans in a civil works project, and large-scale deforestation. Serious incidents require an urgent response and could pose a significant reputational risk for the Bank.

A severe incident is one that caused or may cause great harm to individuals or the environment, or present significant reputational risks that could hamper the Bank’s ability to operate in a country or region. The Borrower’s inability or unwillingness to remedy situations that could result in serious or severe harm would be a factor in classification. A severe incident is complex and expensive to remedy (if possible), and is likely irreversible. A fatality is automatically classified as severe, as are incidents of major environmental contamination, forced or child labour, abuses of community members by project security forces or other project workers (including GBV) violent community protests a project, kidnapping, and trafficking in endangered species.

Workers grievance mechanism

A workers grievance mechanism separate from the project GM should be in place for all direct and contractor workers and consultants before recruitment. Typical work-place grievances include fair and equal opportunity for employment; labour wage rates and delays of payment; disagreement over working conditions; and health and safety concerns in work environment. Community workers will also be provided with information on workers’ GM when engaged in project activities. Such workers will be informed of the GM at the time of recruitment and the measures put in place to protect them against any reprisal for its use. Handling of grievances should be objective, prompt and responsive to the needs and concerns of the aggrieved workers, enabling them to prevent, mitigate, or resolve tensions and problems before they escalate into more serious issues that will require extra resources to address.

The workers in the PIU should be encouraged in the first instance to raise their grievances with their immediate supervision/hiring unit, the immediate supervisor shall then carefully consider the case and endeavour to settle it. If an aggrieved worker is dissatisfied with the proposed settlement, he/she shall submit a complaint, in writing to his/her Head of Department. The worker may in addition to this, request for personal hearing and may be accompanied by a colleague at such hearing. The Head of Department will then communicate his/her decision to the complainant. If the matter is still not settled to the satisfaction of the employee concerned, he/she shall appeal to the head of Human Resources Department who will then take up the matter with the management. If the matter remains outstanding (after having been attempted to address), the aggrieved worker shall refer it to the Director General (DG) who will then take up the matter with the management.

If the workers are not comfortable raising grievances with their supervisors/seniors, they can raise issues anonymously via the project complaints system and if they are not happy with the channel, they can raise with the World Bank GRS or Inspection panel. The worker GM will not impede access to other judicial or administrative remedies that might be available under the law or through arbitration procedures or mechanisms provided through collective agreements.

 

Contractors should have their own workers grievance mechanisms or use the project GM mechanism.

This should be included in the ESMPs and should be monitored.

Overview on website:

Suggestions, concerns and feedback are welcomed by the Barwaaqo project to improve its performance.  These can be communicated to project staff or via 9292 or sent to: [email protected], In the case of complaints relating to GBV these should be communicated immediately to 9292 or emailed to: [email protected]

All grievances will be treated confidentially, impartially and without retribution and can be submitted anonymously if required. GBV/SEAH complaints will be dealt with by the GBV Expert using a survivor centric approach.  Grievances will be acknowledged within 7 days of receipt and resolved within 21 days including feedback to the complainant.