The Project will aim to protect a person’s confidentiality when requested and will guarantee anonymity in annual reporting. Individuals will be asked permission to disclose their identity.
Investigations will be undertaken in a manner that is respectful of the aggrieved party and based upon the principle of confidentiality. There may be situations when disclosure of identity is required. If this is the case, the CLO and DGDC will identify this and ask if the aggrieved party wishes to continue with the investigation and resolution activities.
TRANSPARENT AND FAIR
Grievance Reporting and Resolution
A formal log of grievances will be developed and the CLO will be responsible for logging all grievances. A comments sheet will also be provided for complaints or other comments. Comments or complaints can be made directly to DGDC or the contractor, through the CLO or through a community representative (e.g. through the village elders). The procedure for lodging grievances and their resolution will be included in appropriate Project communication materials such as non-technical summaries or the Project. In the first instance, grievances will be directed to the CLO who will classify grievance according to Table below.
|Low||No or low||Unsubstantiated||CLO will conduct investigation, document findings and provide a response|
|Medium||Possible risk and likely a one-off event||Possible substantiation||CLO and an appropriate investigation team will conduct investigation. The Site Manager or Occupation Health and Safety Manager may decide to stop work during the investigation to allow the corrective preventive actions to be determined. The CLO will provide a response.|
|High||Probable risk and could reoccur||Probable substantiation||CLO will get the contractor to organise a Major Investigation Team including DGDC and GoCD for prompt investigation and resolution. Work will be stopped in the affected area. The CLO will provide a response.|
The CLO will log the receipt of a comment, formally acknowledge it, track progress on its investigation and resolution, and respond in writing with feedback to the aggrieved party. They will initiate the investigation and ensure its speedy conclusion aiming to provide a response with ten working days, unless there are exceptional circumstances. If the Project receives a large number of unsubstantiated grievances, the process will be reviewed to define instances when no response is needed.
WHERE INVESTIGATIONS ARE REQUIRED
Project staff and outside authorities as appropriate will assist with the process
The CLO will collaborate with GoCD to identify an appropriate investigation team with the correct skills to review the issue raised and to decide whether it is Project related or whether it is more appropriately addressed by a relevant authority outside the Project.
The investigation will also aim to identify whether the incident leading to the grievance is a singular occurrence or likely to reoccur. Identifying and implementing activities, procedures, equipment and training to address and prevent reoccurrence will be part of the investigation activities. In some cases, it will be appropriate for the CLO to follow up at a later date to see if the person or organisation is satisfied with the resolution or remedial actions.
The CLO will summarise grievances to report on Project performance weekly during construction and bi-annually during operation, removing identification information to protect the confidentiality of the complainant and guaranteeing anonymity.
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