1. Module 12 Environmental Safeguards Accreditation Training, January 21 – 25, 2013 Addressing Complaints and Grievances

2. 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

3. Module 12 Environmental Safeguards Accreditation Training, January 21 – 25, 2013 Complaints typically evolve… Early action pays off… 3 Issue Concern Grievance Issue PAP seeks solution internally PAP seeks solution externally Cost HigherCost Lower

4. 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

5. 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

6. 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

7. 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

8. Module 12 Environmental Safeguards Accreditation Training, January 21 – 25, 2013 Steps of Engagement for addressing Complaints 8 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

9. 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

10. Module 12 Environmental Safeguards Accreditation Training, January 21 – 25, 2013 3. Analyze complaint and complainant 10  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

11. 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?

12. Module 12 Environmental Safeguards Accreditation Training, January 21 – 25, 2013 5. Address complaint and complainant 12  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

13. 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.