Grm p1 Final[1]

7/29/2019 Grm p1 Final[1]

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HOW-TO NOTESFeedback Matters:

Designing Effective Grievance Redress

Mechanisms for Bank-Financed Projects

Part 1: The Theory of Grievance Redress

DEALING WITH GOVERNANCE AND CORRUPTION RISKS IN PROJECT LENDIN

http://dfg

http://gacinprojec

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This note was prepared by David Post and Sanjay Agarwal o the World Bank’s Social Development Department

(SDV) as part o the eort by the Social Sustainability and Saeguards Practice Group, the Demand or Good

Governance Team, and the GAC in Projects team to provide guidance on ways to improve governance and

accountability in Bank operations. The authors are grateul to peer reviewers Steve Burgess and George

Soraya o the World Bank or their invaluable insights and comments. The authors would also like to thank Luiz

Alcoorado, Ivor Beazley, Elena Correa, Maninder S. Gill, Hélène Grandvoinnet, Elisabeth Huybens, Asmeen

Khan, Charles E. Di Leva, Albert Ninio, Ernesto Sanchez-Triana, Susan Wong, and other members o the Social

Sustainability and Saeguards Practice Group or additional comments.

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Feedback Matters Prt 1: T Tr Gr Rr 1

PaRT 1:The TheoRy

o GRievanceRedRess

T t Rm trt: wr tr gr trut r,

t pt w t t pl, t gr um utblt r wrk

t mt pru w pbl: t ur t r.

—Ml armtrg

As the World Bank’s governance and anticorruption (GAC) agenda moves orward,

grievance redress1 mechanisms (GRMs) are likely to play an increasingly prominent

role in Bank-supported projects (see Box 1). Well-designed and -implemented GRMs

can help project management signifcantly enhance operational efciency in a variety

o ways, including generating public awareness about the project and its objectives;

deterring raud and corruption; mitigating risk; providing project sta with practical

suggestions/eedback that allows them to be more accountable, transparent, and

responsive to benefciaries; assessing the eectiveness o internal organizational

processes; and increasing stakeholder involvement in the project. For task teams

more specifcally, an eective GRM can help catch problems beore they become more

serious or widespread, thereby preserving the project’s unds and its reputation.

This note aims to provide project teams with a better understanding o GRMs so

that they can help borrowers design GRMs that eectively collect and respond to

stakeholders’ inquiries, suggestions, concerns, and complaints.2 This Part 1 presents

the theory behind grievance redress; a companion note, Part 2, outlines a process

1. The terms grievance redress and complaints handling are used interchangeably throughout this note.

2. This note does not discuss employee grievance procedures or external non-project grievance redress mecha-

nisms (such as ministry-level grievance redress mechanisms, ormal judicial systems, or ombudsmen).

GRM r rgl rgz rtl tl r prmtg trpr

utblt Bk-f prt. T Qult aur Grup (QaG) r-

tl l Gac Bmrkg Lrg Rw tt t rp-

Bk-upprt prt t t Gac g. T rw u tt

GRM wr lu l 28 prt rw prjt. Mrr, m t

GRM wr tr rqur t mt wrtt rr gr r blg t

t gr pr wrtt bk. T QaG rprt lu tt

GRM r t mt uru m- gr tl t

tt “ mplt lg mm r t grw t t trumt r

Gac mtgt t wll mr rul g grtr ttt urg bt

prprt upr.” a t fg mtrt, tr mu rm r

Bk-upprt prjt t mpr prrm t rtl r.

Source: Qult aur Grup (2009)

box 1

T imprt GRM:

e rm Rt

QaG Rw

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2 How-to Notes

or designing an eective GRM. Both parts draw on examples rom World Bank-

supported projects.3

Grievance redress systems can be designed to unction at the project, sector, and

country levels; this note ocuses primarily on the project level. The GRM rame-

work presented here is equally applicable to both basic grievance redress systems

and those that are oriented to advanced inormation technology. In applying this

ramework, project managers must take into account the project’s unique operat-

ing context: or example, the size o the project management unit (PMU), types o

services delivered, benefciaries’ needs, and technical, fnancial, and human resource

constraints.

The ramework may be used either to design a new GRM or to improve the unction-

ing o an existing one. Box 2 provides a checklist that teams can use to assess theadequacy o existing GRMs.

3. Though it is preerable to draw on both notes when designing a GRM, parts 1 and 2 can also be used

separately.

T llwg qut wll lp tm wtr t GRM t wt

prjt utg up t t ull pttl. i t wr t t qut

n, tm ul r mprg t prjt’ GRM.

• d t prjt lr, rml, trprt trl mm (.g.,

gr rr ut, gr rr mmtt, gt gr

rr fr) rul r rg gr?

• d prjt fl rpbl r gr rr t utrt t tk r

m rml t?• ar fl rpbl r gr rr blg t tk t ll gr-

?

• d prjt-t ppl l tt t lg gr wtut r

rtlt?

• ar prjt bfr wr tr rgt t fl gr t gr-

rr pr grl?

• ar tr trl pr pl t rr, trk, mtr t gr

t t tk tm?

• d t GRM pr tml bk (wrtt r trw) t t pttr

t tk?

• i tr ppl pr pl tt GRM ur t r ttf wt w tr gr b rl?

box 2

ag t aqu

Prjt’ GRM

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T rmwrk

Figure 1

Gr Rr

Mm:

a rmwrk

BUILDING BLOCKS OF GRMs

Organizational

commitmentAnalysisProcessesPeoplePrinciples

Use M&E data to identify problems and improve

operational processes and performance

GRM VALUE CHAIN

Uptake(locations and

channels)

Monitor and

evaluate

Verify,investigate,

and act

Acknowledgeand

follow up

Sortand

process

Providefeedback

5 Assign GR tasks

and train staff

4Develop and

publicize

GR policies

2Estimate users and

assess available

resources for GRM

1Survey existing

formal and informal

GRMs

3Develop standard

operating

procedures/flowcharts

6Stimulate

external demand

for GRM

STEPS IN DESIGNING AN EFFECTIVE GRM

Eective GRMs typically have common building blocks and characteristics: multiple

grievance uptake locations and multiple channels or receiving grievances; fxed ser-

vice standards or grievance resolution; clear processing guidelines; and an eectiveand timely grievance response system to inorm complainants o the action taken.4

The design o eective GRMs should take into account the building blocks, the value

chain, and the steps involved in designing a GRM (Figure 1).

4. At the outset it is important to note that while GRMs can curtail corrupt practices, they are also useul or col-

lecting other types o data. For example, out o 2,300 grievances received by the Kecamatan Development Pro-

gram’s complaints handling unit, 40% were related to corruption while the other 60% were queries, comments,

or grievances related to the project’s general perormance.

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4 How-to Notes

Bulg Blk et GRM

Organizational

commitmentAnalysisProcessesPeoplePrinciples

Figure 2

Bulg Blk

et GRM

The structure that GRMs take is likely to vary rom project to project, depending on

the services delivered, the size o the PMU, and the needs o benefciaries. For ex-

ample, some projects may successully use a centralized grievance redress system,while others may decentralize or outsource the unction. Or there may be separate

units or dierent unctions, such as dedicated units or handling grievances rom

members o parliament or grievances about a particular program area. Whatever the

model, eective GRMs typically build on fve core building blocks (see Figure 2).

onznl cmmmn

The project’s management and sta recognize and value the grievance process as

a means o strengthening public administration, improving public relations, and en-

hancing accountability and transparency. Grievance redress is integrated into the

project’s core activities. Management makes the GRM part o the project’s “DNA”

by integrating grievance redress unctions into project stas’ job descriptions and

regularly reviewing grievances data and trends at project management meetings. 5

Management also ensures that the GRM is properly staed and resourced.

Pnpl6

Eective GRMs usually embody six core principles.

• Fairness. Grievances are treated confdentially, assessed impartially, and handled

transparently.

• Objectiveness and independence. The GRM operates independently o all

interested parties in order to guarantee air, objective, and impartial treatment

to each case. GRM ofcials have adequate means and powers to investigate

grievances (e.g., interview witnesses, access records).

• Simplicity and accessibility. Procedures to fle grievances and seek action are

simple enough that project benefciaries can easily understand them. Project

benefciaries have a range o contact options including, at a minimum, a telephone

number (preerably toll-ree), an e-mail address, and a postal address. The GRMis accessible to all stakeholders, irrespective o the remoteness o the area they

live in, the language they speak, and their level o education or income. The GRM

does not use complex processes that create conusion or anxiety (such as only

5. In large projects, this can also be done by having a dedicated GR unit headed by (or reporting directly to) a

senior project unctionary.

6. Adapted rom Kalahi-CIDSS Project (2003).

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accepting grievances on ofcial-looking standard orms or through grievance

boxes in government ofces).

•

Responsiveness and efciency. The GRM is designed to be responsive to theneeds o all complainants. Accordingly, ofcials handling grievances are trained to

take eective action upon, and respond quickly to, grievances and suggestions.

• Speed and proportionality. All grievances, simple or complex, are addressed

and resolved as quickly as possible. The action taken on the grievance or

suggestion is swit, decisive, and constructive.

• Participatory and social inclusion. A wide range o project-aected people—

community members, members o vulnerable groups, project implementers, civil

society, and the media—are encouraged to bring grievances and comments to

the attention o project authorities. Special attention is given to ensure that poor

people and marginalized groups, including those with special needs, are able to

access the GRM.

Ppl

Dedicated and passionate grievance redress personnel are essential to the success

o a GRM. The project provides training to the sta working on grievance redress so

that they can eectively carry out their roles. Generally speaking, sound recruitment

practices, continuous training and learning opportunities, and systematic review and

eedback regarding sta members’ perormance are important to the success o

GRMs. In large decentralized projects a special Grievance Redress Unit (including

feld units with dedicated personnel) may be required.

P

Grievance redress processes play an important role in project activities. Project man-

agement and sta outline and publicize the six stages o the “value chain,” discussed

in the next section.

anly

Project management regularly analyzes reports and other monitoring and evaluation

data on grievances. Grievance-related data provide management with insights into

the eectiveness o the PMU’s programs and are used to identiy problem areas,

improve internal processes, enhance service delivery, and reduce the incidence o

grievances in the uture.

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6 How-to Notes

T GRM vlu c

i’ ntl cmmut empwrmt Prgrm (nceP) w rt

mplt uptk lt, u mplt bk mmut rtrt,

p, -ml, txt mg (sMs), prjt wbt, prjt t, t w m,

rprt rm t iptr Br dlpmt Prrm. T sMs uptk

pt pr prtulrl t, lggg rg r 250 mplt

pr mt. i ttmt t t t, nceP’ GRM lgg rl 16,000

mplt, wt rlut rt r 99%.

box 3

i:

it Uptk

The grievance redress process, shown in Figure 3 as a value chain, comprises six

steps. It is important to consider all o these steps in detail when designing a GRM.

up

Uptake reers to the methods by which the project will collect grievances. Taking

into account technology, unding, and capacity constraints, the project should havemultiple uptake locations (at the community, village, district, provincial/regional, and

PMU levels, etc.) and multiple uptake channels (mail, e-mail, telephone, project web-

site, project sta, text messaging/SMS, strategically placed complaints boxes, etc).

Since the cost and complexity o GRMs increase with the number o potential uptake

locations, teams should choose uptake locations strategically based on the goals o

the project (see Box 3).

sn n Pn

Various types o grievances typically require dierent ollow-up actions—or example,

some grievances can be resolved by means o a simple explanation or apology,

while others may require more extensive investigations. Thereore, grievances need

to be categorized, assigned priority, and routed to the appropriate entity (see Box4). Moreover, standardized internal processes need to be established to guide how

grievances are logged. For example, in Indonesia’s NCEP, complaints that cannot be

resolved at one level o the system are reassigned to actors at higher levels (Figure

4). Higher levels o the project are also responsible or monitoring the complaints-

handling perormance at lower levels. Grievances can be logged either manually or,

i resources allow, by using a computer-based system that will allow the project to

identiy trends in the data across time and geographic locations.

Figure 3

T GRM vlu cUptake

(locations and

channels)

Monitor

and

evaluate

Verify,

investigate,

and act

Acknowledge

andfollow up

Sort

andprocess

Provide

feedback

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anlmn n Fll-p

When a complaint is made, the GRM should acknowledge its receipt in a communi-

cation that outlines the grievance process; provides contact details and, i possible,

the name o the contact person who is responsible or handling the grievance; andnotes how long it is likely to take to resolve the grievance. Complainants should

then receive periodic updates on the status o their grievances. The GRM needs to

establish clearly defned timetables or acknowledgment and ollow-up activities. To

enhance accountability, these timetables should be disseminated widely to various

stakeholders, including communities, civil society, and the media.

s prjt r w rg mplt, rgg rm llgt r-

rupt t mpl uggt qur, t mprtt t urtl tgrz

rt tp. i t Kl-cidss Prjt t Plpp, t GRM g

t rp t ur tp mplt: () mmt, uggt, r qur; (b)

mplt rltg t prrm prjt blgt; () mplt rr-

rg t lt lw /r rrupt; () mplt gt prjt t r

mmut mmbr l prjt mgmt.

box 4

ctgrzg cmplt

Figure 4

lw Gr

Rr

i’ nceP

Complaints/problems

Relevant actor at complainants level

Cross check/clarification

True False

Complaint handling

facilitation

Actors at

higher levels

Resolved Unresolved

Dissemination of complainthandling result to the community

Handling line

Monitoring line

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8 How-to Notes

Vfn, invn, n an

This step involves gathering inormation about the grievance to determine its validity,

and resolving the grievance. The merit o grievances should be judged objectively

against clearly defned standards. Grievances that are straightorward (such as que-

ries and suggestions) can oten be resolved quickly by contacting the complainant.

Grievances that cannot be resolved at one level o the system should be reerred to a

higher level and/or an outside entity or verifcation and urther investigation according

to a clearly defned timetable. Project sta should ensure that investigators are neu-

tral and do not have any stake in the outcome o the investigation. Potential actions

include responding to a query or comment, providing users with a status update, im-

posing sanctions, or reerring the grievance to another level o the system or urther

action. Generally speaking, the project should take some action on every grievance.

Mnn n evln

Monitoring and evaluation are critical to the success o any GRM. Monitoring reers

to the process o tracking grievances and assessing the extent to which progress is

being made to resolve them. Projects that serve a large number o citizens or bene-

fciaries—such as community-driven development, rural roads, water and sanitation,

health, education, or social protection projects—are likely to receive a large number

o grievances and should ideally have an electronic system or entering, tracking, and

monitoring grievances (see Box 5).

The project monitoring and evaluation inormation system should also include indica-

tors to measure grievance monitoring and resolution. These grievance redress indica-

tors can also be incorporated into project results rameworks (see Box 6).

Pakistan’s Punjab Rural Water Supply and Sanitation Project has developed a

credible mechanism to handle comments, suggestions, and grievances. The

mechanism includes a “monitoring system” database to monitor adherence to

the standards listed in the Procurement Manual. The database is designed as

an online instrument (with restricted access) that allows recording and retrieval

o all cases received, responses sent, dates o actions taken, and response

times.

box 5

Pkt:

crtg

Mtrg dtb

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Evaluation involves analyzing grievance data and using it to make policy and/orprocess changes to minimize similar grievances in the uture. Thereore, reports on

grievances data and trends (e.g., average time to resolve grievances, percentage o

complainants satisfed with action taken, number o grievances resolved at frst point

o contact)7 should be submitted regularly. Senior project management should moni-

tor grievance resolution data and grievance trends in their progress review meetings

and should randomly call complainants rom dierent areas and groups to get eed-

back on whether the GRM is unctioning eectively (see Box 7).

7. Reports to management also typically include such inormation as the number o grievances about a particular

issue, spikes in grievances, geographical spread o grievances, and characteristics o the complainants.

T mt mm gr rr mtrg tr tt prjt r-

prt tr rult rmwrk r t llwg:

• numbr mplt/ gr rgtr

• Prtg gr rl

• Prtg gr rr wt tpult tm pr

• Tm rqur t rl mplt (ggrgt b rt tp gr-

)

• Prtg mplt tf wt rp gr rr

pr

• Prtg prjt bfr tt t t GRM

box 6

Gr Rr

Mtrg itr

nceP t mmbr put mtrg lut t rtl t wbt

tt t PMU Wrl Bk t “rl-tm” t but t GRM. T

wb-b mgmt rmt tm t t u mplt

rmt, tl t , mt t prblm, pttl llw-

up t, w t gr w rl. Tu t tb t

rtul “ lbrr” pt gr, lg wt t bk rwr pr

t gr. hg t t rl-tm t llw prjt mgmt

t mr l t prblm r, qukl lz uggt mmt

but t prjt’ prrm, trtg t rllt rur

upgr pr t prtl f.

box 7

Rl-Tm Mtrg

elut

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10 How-to Notes

T r trut t GRM, t Rurl cmptt Prjt hur u

umbr mm t pr bk but gr rr, u

mtg gr rgtr publg gr r p

ull; prg t Bk wt mul rprt gr rr;

rtg rgl-ll tklr ultt mm t pr upt

t prjt’ prrm gr rr.

box 8

hur:

Prg Uul

bk

Pv F

The fnal step—inorming GRM users and the public at large about the results o in-

vestigations and the actions taken—enhances the visibility o the GRM among bene-

fciaries and increases users’ trust in the system (making it more likely that they will

lodge grievances). Projects can provide eedback by contacting the complainant

directly (i his or her identity is known) and/or posting the results o cases in high-

profle locations and conveying the results through radio broadcasts and other media

(see Box 8). The project should also inorm GRM users about their right to an appeal

i they are dissatisfed with the decision, speciying both internal and external (e.g.,

judicial review, ombudsman, line ministry) review options.

clu As the GAC agenda moves orward, GRMs are likely to be an increasingly impor-

tant component o Bank-supported projects. The eectiveness o GRMs rests on

three interconnected actors: ensuring a clear organizational commitment to griev-ance redress, creating well-designed internal processes or addressing grievances,

and tailoring the GRM to the unique operating environment. In addition to addressing

and resolving grievances, GRMs should be designed to serve as a conduit or solicit-

ing inquiries, inviting suggestions, and increasing community participation. (Figure 5

shows some o the most important “dos and don’ts” that project teams should keep

in mind while designing the processes encompassed in the GRM value chain.) To the

extent that projects are able to achieve success on these dimensions, GRMs can

provide operations with a wide range o benefts, such as curbing corruption, collect-

ing inormation that can be used to improve operational processes and perormance,

empowering vulnerable populations, and enhancing the project’s legitimacy among

stakeholders. Thus eective grievance redress systems represent a step towardgreater accountability and, ultimately, better project outcomes.

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Figure 5

GRM vlu c

d d’t

DO STAGE DON’T

• Create accessible uptake locationsand channels

• Maintain log books at various levels

to record all complaints, inquiries,

and suggestions received.

• Publicize uptake options/contact

information on communication

materials, in offices, etc.

• Clearly outline who is responsible for

handling different types of complaints

• Establish clear timetables for the

complaints-handling process

• Assign each complaint a unique ID

number

• Inform users about steps in the

complaints-handling process• Try to resolve the complaint at the

first point of contact

• Stick to agreed timetables for

responding to users

• Objectively evaluate the complaint’s

merit on the basis of facts

• Ensure that investigators are neutral

• Take action that is proportional to the

comment or complaint

• Signal importance of complaints-

handling putting topic as agenda

item for management meetings

• Establish a tracking system to record,

classify, and assess complaints

• Analyze grievance redress data andmake improvements

• Contact users to explain how their

complaint was resolved and how

they can appeal

• Publicize results of investigations to

enhance visibility of and increase

trust in the GRM

Uptake

Sort and

process

Acknowledge

and

follow up

Verify,

investigate,

and act

Monitor

and

evaluate

Provide

feedback

• Create barriers to complaining by making uptake processes time-

consuming or complicated

• Forget to take measures to ensure

that vulnerable groups are able to

access the GRM

• Leave any ambiguity about how

complaints are supposed to be routed

• Develop a GRM that does not

differentiate between different types

of complaints

• Divulge complainant’s identity to

others• T reat GRM users as if their complaint

is an inconvenience

• Expect users to prove they are right;

this is the purpose of an investigation

• Forget to update users on the status

of their complaint

• Appoint investigators that are biased

• Miss the opportunity to integrate the

GRM into the project’s management

information system

• View the resolution of complaints as

an end in itself—it is just a first step in

improving processes

• Neglect to follow up with users; this

undermines trust in the GRM

• Keep complaint results private; this

undermines transparency

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12 How-to Notes

Rr Rur

Asian Development Bank (2009). Handling Complaints Efciently. Manila: Asian Development Bank.

Commonwealth Ombudsman (2009). Better Practice Guide to Complaint Handling. Canberra: Common-

wealth o Australia.Kalahi-CIDSS Project (2003). “Guide to the Kalahi-CIDSS Complaints Handling System.” World Bank.

National Community Empowerment Project-Urban (2008). “Complaint Handling Unit.” PowerPoint pre-

sentation, July 2008.

World Bank Department o Institutional Integrity (2007). “Complaint Handling Systems.” PowerPoint pre-

sentation, Washington, DC.

World Bank Department o Institutional Integrity (2008). “Leveraging Complaints Handling in Projects.”

PowerPoint presentation, April 16, 2008, Washington, DC.

World Bank Quality Assurance Group (2009). Governance and Anticorruption in Lending Operations:

A Benchmarking and Learning Review. Washington, DC: World Bank.

atl GRMRur

The Social Development Department has compiled a comprehensive set o resources that task teams can

draw upon in developing a GRM:

Grievance Redress Mechanism Sel-Assessment Tool

GRM PAD Speak —a document that summarizes what various project PADs say about GRMs

Grievance Redress Indicators: a database o indicators on grievance redress used by dierent projects

Guide to the Kalahi–CIDSS Project Grievance Redress System

Checklist o Activities or Integrating Grievance Redress into World Bank Projects

Better Practice Guide to Complaints Handling

Inormation Typically Included on a Complaints Handling Form

Introduction to ISO 10002 (and Extended Version o Australia ISO 10002 with annexes)

Helping Local People Understand the Complaints Handling Mechanism

Tips or Making a Complaint

Ways to Present Complaints Data

The resources listed above are available online on the Social Development Department’s website at:

http://connect.worldbank.org/explore/SDV/DFGG/deault.aspx.

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