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Grievance Redress Mechanisms
On Paper and in Practice
Acknowledgements
This report was completed in April 2014 and summarizes the findings of a desk review and survey of
grievance redress mechanisms in design and implementation. The principal author was Aaron Seyedian,
with research assistance from Erfaan Mojgani, Masayuki Omote, Besa Rizvanolli, and Paloma Temiño. It was
prepared under the guidance of Amar Inamdar, Marie Brown, and Mark King. The following staff provided
advice and inputs or commented on earlier drafts: Sanjay Agarwal, Grant Milne, Scott T. Adams and Maria
Elena Garcia Nora.
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Grievance Redress Mechanisms
On Paper and in Practice
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Global Review of Grievance Redress Mechanisms in World Bank Projectsii
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iiiContents
CONTENTS
ABBREVIATIONS AND ACRONYMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
INTRODUCTION AND BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
REVIEW METHODOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3
FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5
RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13
CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
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Global Review of Grievance Redress Mechanisms in World Bank Projectsiv
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vAbbreviations and Acronyms
AFR Africa Region
ARD Agriculture and Rural
Development sector
CAO Compliance Advisor
Ombudsman
CPS Country Partnership Strategy
CSI Core Sector Indicators
DPL Development Policy Loan
DRP Dispute Resolution and
Prevention unit (OPCS)
EAP East Asia and Pacific Region
ECA Eastern Europe and Central
Asia Region
EDU Education sector
ENV Environment sector
FPD Financial and Private Sector
Development
GAC Governance and Anti-Corruption
GRM Grievance Redress Mechanism
HNP Health, Nutrition and Population
IBRD International Bank of
Reconstruction and
Development
ICT Information and
Communication Technology
IDA International Development
Association
IFC International Finance
Corporation
INT Integrity Vice Presidency
IPP Indigenous Peoples Plan
IPPF Indigenous Peoples Planning
Framework
ISDS Integrated Safeguards Data Sheet
ICR Implementation Completion
Report
ISR Implementation Status Report
LCR Latin America & Caribbean
Region
MENA Middle East and North Africa
Region
OPCS Operations Policy & Country
Services
OPSOR Operations Risk Management
ORAF Operational Risk Assessment
Framework
P4R Program for Results Loan
RAP Resettlement Action Plan
SAR South Asia Region
SDV Social Development
SP Social Protection
WBI World Bank Institute
ABBREVIATIONS AND
ACRONYMS
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Global Review of Grievance Redress Mechanisms in World Bank Projectsvi
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1INTRODUCTION AND BACKGROUND
INTRODUCTION AND
BACKGROUND
2013 was a big year for citizen engagement at the World Bank Group. In February,
the Dispute Resolution & Prevention team released the “Global Review of Grievance
Redress Mechanisms in World Bank Projects,” and over the course of the year, citizen
engagement strategies were drawn up in three regions and Operations Policy and
Country Services (OPCS). Perhaps most notably, President Jim Yong Kim called for
beneficiary feedback in 100% of projects with clear beneficiaries in what is now an
oft-cited speech from the Annual Meetings.
As the Strategic Framework for Mainstreaming Citizen Engagement in World Bank
Group Operations is finalized,1
the safeguards policy update completed, and the Stan-
dardized Operational Risk-rating Tool (SORT) rolled out for risk management, 2014
is on track to become a worthy successor. Considering how crucial grievance redress
mechanisms (GRMs) are to the citizen engagement movement specifically, the bank’s
performance generally, and our response to those negatively impacted by our projects
most importantly, Operations Risk Management (OPSOR) prepared this note to provide
insight into how GRMs on paper are actually functioning in practice.
The 2013 “Global Review of Grievance Redress Mechanisms in World Bank Projects”
provided staff and management with an overview of GRMs in project design by reviewing
the Project Appraisal Documents (PADs), and where available, the Environmental and
Social Impact Assessments (ESIAs), Environmental and Social Management Frameworks
(ESMFs), Resettlement Action Plans (RAPs), Resettlement Policy Frameworks (RPFs),
Indigenous Peoples Plans (IPPs), and Indigenous Peoples Policy Frameworks (IPPFs)
for all project approvals in fiscal year 2011.2
Its most basic finding, among many others,
was that 50% of approved projects in fiscal year 2011 contained a GRM.
1
Engaging with Citizens for Im-
proved Results, https://consultations
.worldbank.org/consultation/
engaging-citizens-improved-results
2
Excluding Development Pol-
icy Loans, Financial Intermedi-
ary Loans, and Trust Funds < $5
million.
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Grievance Redress Mechanisms On Paper and in Practice2
Good data on GRMs in project design had finally been gathered, but important ques-
tions remained. Will these GRMs actually be created? Of those that will, how well
will they work? How many complaints will they receive? Unfortunately, the review
was only able to examine a small subset of projects along this line of questioning.
This note will pick up where the “Global Review” left off.
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3REVIEW METHODOLOGY
REVIEW METHODOLOGY
The goal of this review is to provide management and staff with:
• An assessment of GRM existence in project design
• An assessment of GRM existence in practice
• An assessment of GRM quality in practice
• Recommendations for improving GRM quality in implementation and GRM
management at the corporate level
For the assessment of GRMs in project design, a desk review was conducted of all
approvals in fiscal year 2012, excluding Development Policy Loans, Financial Inter-
mediary Loans, and trust funds under $5 million (235 total projects; ~$23 billion
in total commitments). This is in line with the methodology of the fiscal year 2011
review. For each project, the team reviewed the Project Appraisal Document (PAD)
and where available, the Environmental and Social Impact Assessment (ESIA), Envi-
ronmental and Social Management Framework (ESMF), Resettlement Action Plan
(RAP), Resettlement Policy Framework (RPF), Indigenous Peoples Plan (IPP), and/
or Indigenous Peoples Policy Framework (IPPF). Using these documents, the team
asked the following questions:
1. Is there a reference to grievance redress in project documents? (Yes or No)
2. What is the extent of the reference? (Extensive or Minimal)
3. Will data be collected? (Yes or No)
4. Who is collecting data?
5. Are funds dedicated to the GRM?
For the assessment of GRMs in implementation, a survey was sent out to the Task
Team Leaders (TTLs) of each project where design documents indicated a grievance
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Grievance Redress Mechanisms On Paper and in Practice4
redress mechanism. This survey, sent out in the third quarter of fiscal year 2014,
asked TTLs the following questions to evaluate the existence and quality of GRMs:
Doestheprojecthaveaworkinggrievanceredressmechanism?
Ifyes...
Arecitizensabletolodgeacomplaint
via...
Howmanycomplaintshavebeenreceived? Phone?
Howmanycomplaintshavebeenresolved? SMS(Texting)?
Howmanycaseshavebeenappealedbycomplainants? In-Person?
Arethereservicestandardsthatensuretimelyresponses? Mail?
RESPONSE RATE
79% (121/154) of those queried responded to the survey. The findings related to
GRMs in practice are representative of this cohort.
CONSTRAINTS
1. Only TTLs of projects which included a GRM in design were surveyed. It is con-
ceivable that some projects which did not commit to a GRM in design may have
created one in practice.
2. Answers were self-reported via email and no follow-up verification was done.
3. TTLs were given no guidelines as to what constitutes a working grievance redress
mechanism, so their answers can only be considered indications of their own
judgment.
4. Not all TTLs responded to the survey, so the sample is biased by those willing
to report. This may skew toward those with existing and/or high-performing
grievance redress mechanisms.
5. The definition of complaints which have been “resolved” is open to interpreta-
tion. What is thought to be “resolved” from the client/TTL perspective may not
necessarily be so from the perspective of the complainant.
6. As the review covers fiscal year 2012 approvals, some projects have not started
implementation. Although good practice dictates otherwise, many of these projects
are not soliciting complaints at this stage.
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5FINDINGS
3
“‘Governance and Anticorrup-
tion: A Benchmarking and Learn-
ing Review’ produced by QAG in
2009. The QAG statistic is based on
a limited sample of FY08 approv-
als and the exact methodology is
unclear. Therefore, the data are
not strictly comparable but can
be considered a rough compara-
tor.” p. 7, “Global Review of Griev-
ance Redress Mechanisms,” Marie
Brown, Dispute Resolution & Pre-
vention, February 2013.
FINDINGS
FINDINGS SNAPSHOT: ON PAPER
1. GRM coverage continued
to rise
Of all fiscal year 2012 approv-
als, 66% (154/235) included a
grievance redress mechanism
in project design. This was up
from 50% in fiscal year 2011
and 28% in fiscal year 2008.3
2. GRM descriptions tended
toward extensive
70% (108/154) of GRMs in
design were outlined “exten-
sively,” meaning they con-
tained more than a perfunc-
tory reference such as “The project will have a grievance redress mechanism.”
3. Roughly half of approvals committed to collecting data
53% (82/154) of projects articulated a commitment to collect the data the GRM
generates.
PercentofSampledProjects
0
60
20
40
80
2008
Fiscal Year
20122011
100
No GRM
GRM
72%
28%
50%
50%
34%
66%
Figure 1. World Bank Projects with a GRM
Reference in the PAD, RPF Documents
PercentofSampledProjects
0
60
20
40
80
FY11
Funds committed?
Commitment to
collect data?
FY12
100
No GRMGRM
34%
50%
50%
66%
Yes
22%
No
78%
No
47%
Yes
53%
Figure 2. GRMs in Project Design
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Grievance Redress Mechanisms On Paper and in Practice6
4. Committing funds was relatively rare
Only 22% (34/154) of approvals specified funds for the creation and/or operation
of the GRM.
FINDINGS SNAPSHOT: IN
PRACTICE
1. GRM coverage fell in practice
When surveyed, only 60% (72/121) of proj-
ects that planned a GRM in design reported
a working mechanism. This means that only
31% of projects approved in fiscal year 2012
had a working GRM in practice (72/235).4
2. More than a quarter of working GRMs
were unused
28% (20/72) of all projects reporting
a working GRM had zero complaints
received.
3. Nearly one in five GRMs had no data on complaints
19% (14/72) of all projects reporting a working GRM had no data on complaints
received. This was either because grievances were not logged or the TTL was
unable to get the data from the client.
4. Only 21% (15/72) of GRMs reported working received more than 20 complaints
(6% [15/235] of fiscal year 2012 approvals)
5. Aggregate resolution rate was 75%
As of the third quarter of fiscal year 2014, fiscal year 2012 approvals had received
2,000,271 complaints and resolved 1,503,371 complaints.5
4
Note that with 79% responding
to the survey, the 31% coverage
figure must be regarded as an esti-
mate. That said, the high response
rate and the likelihood that non-
repliers have a non-working GRM
over a working one lends confi-
dence to this estimate.
5
Note that of the total, 1,981,207
complaints received and 1,486,181
complaints resolved stem from one
large project.
GRM presence–
Project Design
(Surveyed Q3 FY14)
GRM presence–
Survey Response
69%
34%
66%
31%
Figure 3. FY12 Approvals
No data or zero 1 to 20
47%
More than 20
32%
(23 Projects)
19%
No Data
(14 Projects)
28%
Zero
Complaints
(20 Projects)
21%
(15 Projects)
Projects Reporting a Working GRM
Figure 4. Number of Complaints Received
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7FINDINGS
6. Most projects offered multiple
uptake channels, with SMS the
least prevalent
Among those responding to the
survey:
92% (66/72) accepted
complaints in-person
86% (62/72) accepted
complaints via mail
83% (60/72) accepted
complaints via phone
42% (30/72) accepted
complaints via SMS
7. Appeals processes were over-
whelmingly not used or not included
Of those projects confirming a working GRM, 60% (43/72) reported zero com-
plaints going to appeal. 26% (19/72) of reported working GRMs had no appeals
process.
8. Service standards were included in a majority of working GRMs
Service standards are timelines available to the public which outline how long
they can expect to wait for the acknowledgement, response, action, and resolution
of complaints. 63% (46/72) of projects reported having service standards.
9. South Asia led the regions with the highest percentage of projects reporting
working GRMs when one had been planned in design (dotted line indicates
average).
Percentofprojects
containinguptakechannel
0
60
20
40
80
In-person PhoneMail SMS
100
50
10
30
70
90
Projects Reporting a Working GRM
Figure 5. Available Uptake Channels
0
60
20
40
80
SAR EAPMNA ECA LCR AFR
50
10
30
70
90
Figure 6. Percent of Projects Reporting Working GRMs
by Region
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Grievance Redress Mechanisms On Paper and in Practice8
6
Full names, in order, are: Social
Development; Agriculture & Rural
Development; Education; Trans-
port; Energy and Mining; Urban
Development; Environment;
Health, Nutrition & Population;
Water; Financial & Private Sec-
tor Development; Social Protec-
tion; and Public Sector Governance.
Global Information & Communica-
tions Technology (GIC) and Finan-
cial Inclusion Practice (FIP) not
included because of extremely
small sample sizes.
0
60
20
40
80
SDV TRARD UD HE FPDEMTED ENV WAT SP PS
50
10
30
70
10. Social Development led the sectors6
with the highest percentage of projects
reporting working GRMs when one had been planned in design (dotted line
indicates average).
11. The correlations between extensive descriptions, planning to provide dedicated
funds, and planning to collect data in design and reporting a “working GRM”
in the survey ranged from slightly inverse to moderately positive
Funding—58% (15/26) of projects committing funds in design documents reported
working GRMs when surveyed, versus 62% (34/55) of those projects which did
not commit funds.
Descriptions—61% (54/88) of projects with extensive GRM descriptions reported
working GRMs when surveyed, versus 55% (18/33) of those with minimal
descriptions.
Data Collection—66% (43/65) of projects committing to collect GRM data in
design documents reported working GRMs when surveyed, versus 48% (21/44)
of those projects which did not commit to data collection.
12. High-performing GRMs (>20 complaints received), however, were associated
with extensive descriptions and commitments to collect data
73% (11/15) of projects with high-performing GRMs committed to collecting
data, and 80% (12/15) contained extensive descriptions in project design. Only
20% (3/15) indicated a funding commitment. Given that 73% (11/15) of these
GRMs were linked to involuntary resettlement, indigenous peoples, or both, it is
highly likely that their extensive descriptions and data collection commitments
stemmed from the requirements outlined by Operational Policies 4.10 and 4.12
(and, of course, the context which necessitates them in the first place).
Figure 7. Percent of Projects Reporting Working GRMs
by Sector
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9FINDINGS
7
Note that TTLs were not specifi-
cally asked why their GRMs were
not working. The 59% reporting
that implementation and/or phys-
ical works had not started volun-
teered this information.
13. GRMs were associated with imple-
mentation and/or physical works
Of those projects reporting a non-
working GRM despite having
committed to one in design, 59%
(29/49) of TTLs said their GRM is
not functional because implementa-
tion and/or physical works had not
started.7
Additionally, 60% (9/15) of
high-performing GRMs were addi-
tional financing projects, implying
that more complaints are solicited
as a project matures.
Fragile States and Conflict-Affected Situations in Focus
Paper&Practice:ProjectsinFCScountrieswerefarmorelikelytoinclude
aGRMinprojectdesignbutlesslikelytoreportaworkingGRMthanthe
rest of the portfolio.
For approvals in fiscal year 2012, 100% (25/25) of FCS projects included
a GRM in project design (versus 66% of approvals in general) but only
41% (9/22) of survey respondents reported a working GRM (versus
60% of approvals in general).
Uptake Channels: Projects in FCS countries were more likely to allow
complaintstobesubmittedviaSMSthanprojectsinthegeneralportfolio.
Forapprovalsinfiscalyear2012,67%ofFCSprojectsacceptedcomplaints
via SMS versus 43% of projects in the general portfolio.
“Establishment of a
specific unit in charge
of grievance redress
and high commitment
of the project owner’s
management.”
“Setting up various
channels to encourage
participation (SMS,
phone, email, mail).”
“The bank was
able to convince the
client governments
to consider GRM
as an integral part
of the program
administration.”
“A study into
technology options
that could be used
should have been
conducted from the
outset.”
Easy Difficult
TTLs of Projects with High-Performing GRMs: What made setting up a GRM easy?
What made it difficult? TTLs of projects with more than 20 complaints received were
asked to share what made setting up a GRM easy and what made it difficult. Below
are some of their responses:
“The project’s
commitment
to promoting
transparency and
regular disclosure
of project
information helped
trigger further
questions and
complaints.”
“Implementing
agency recognized
the importance
of setting up a
mechanism . . .
and had a strong
commitment to
implement it . . .
It was also made
a loan covenant
requirement.”
“In this country,
beneficiaries used to
go directly to street
demonstrations
to express their
disappointment
with delays or
dissatisfaction. With
the GRM, the ministry
has been able to avoid
public troubles.”
“Very remote and
hard to reach areas
made it difficult, in
some instances, to
socialize the GRM.”
“Insufficient
provision of training
among staff working
on the GRM meant
that the processing of
cases varied in terms
of process quality and
time.”
“Project
management . . .
[was] worried about
being swamped
with claims since
they were regularly
experiencing delays in
implementation.”
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Grievance Redress Mechanisms On Paper and in Practice10
TAKEAWAYS
1. Paper is not translating into practice
As has long been assumed, and borne out by smaller scale studies, GRMs planned
for on paper did not necessarily become working GRMs after board approval. Not
only did the coverage of GRMs in practice fall to roughly half of that planned in
design, but the correlation between robust design and the actual existence of a
GRM was not strong. While it was true that high-performing GRMs usually had
good designs, it did not appear that good designs in general strongly corresponded
to implementation.
2. “Working GRMs” do not conform to a standard of quality or principles of
good practice
The benchmark for quality in working GRMs appeared low. Roughly half of all
self-reported “working” grievance redress mechanisms reported either no com-
plaints received or had no data or access to data on grievances redress. While
necessarily difficult to glean from a desk review, even a generous estimate would
draw the conclusion that many of these GRMs were functionally non-existent,
even if roles and responsibilities had in fact been assigned in the hypothetical
event of a complaint.
Other indicators of quality were low as well. The data suggested that appeals
processes were largely unused, untracked, and possibly non-existent. It is true
that there must be de facto appeals processes for most GRMs via local legal
systems. But without assessing the credibility of the judiciary and providing an
alternative appeals process if necessary, task teams may be missing out on their
last opportunity to promote quicker resolution for the complainant and prevent
escalation and protraction of the complaint.
Service standards, the timelines for the acknowledgment, response, and resolution
of complaints, were more prevalent (63% of working GRMs had service standards)
but far from universal. While bank toolkits and guidance on creating adequate
grievance redress mechanisms exist, it appeared that most GRMs surveyed were
not following their prescriptions.
3. GRMs start functioning too late
In 59% of projects without a working GRM, TTLs said that the absence of a GRM
was because the project had not begun implementation and/or physical works.
One TTL explained: “No land acquisition has been initiated. No construction
is underway. Therefore, the grievance mechanism is not really relevant at this
stage.”
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11FINDINGS
With so many projects reporting this type of delay, it is clear that grievance redress
mechanisms are often viewed as tools which pertain to narrow eligibilities, time-
frames, and audiences. Certainly, all GRMs differ and there may be some cases
where this restrictive application is appropriate, but generally, the earlier a GRM
is functioning, the better.
Even before project components pertaining to construction or resettlement
begin, concerns about health and safety, environmental impact, project location/
alignment, and possible unintended consequences of the project, among other
concerns, are likely to be voiced. Furthermore, soliciting complaints early on
increases the likelihood that grievances will be addressed before they escalate to
potential intractability.
4. GRMs are not being used to prioritize supervision, aid project management
or improve project performance
Beyond the obvious benefits of grievance redress mechanisms to users, they can
be useful management aids which can point to weaknesses in a certain aspect or
location of a project. However, given how late many GRMs were being implemented
and how many reportedly working GRMs still recorded no complaints or no data,
it is likely that GRMs were not being used as an asset for better management and,
in turn, performance.
Anecdotally, many TTLs surveyed did not know the statistics on their project’s
GRM and had to request them from the client. This process sometimes took
weeks. The unavailability of real-time information for the task team has negative
implications for risk management.
5. High-performing GRMs are predominantly linked to bank policy
Nearly three-quarters of all high-performing GRMs (>20 complaints received)
reported by survey respondents were linked to bank policy on Indigenous Peoples
(OP 4.10), Involuntary Resettlement (OP 4.12), or both. This intuitive linkage
between high-performing GRMs and bank policy mandating grievance redress
was first established by the small qualitative review in the “Global Review of
Grievance Redress Mechanisms.” Its presence in a much larger sample establishes
this linkage more reliably and highlights the issue-specific approach that currently
stereotypes many of the wider portfolio’s GRMs.
6. GRMs are slow to embrace new technology
A large majority of projects with functioning GRMs allowed for complaints to be
lodged via phone, mail and/or in-person. SMS (texting) was conspicuously less
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Grievance Redress Mechanisms On Paper and in Practice12
available, despite the relative ubiquity of cellphones in poor countries and the
potential savings for users associated with this mode. FCS countries were a notable
exception, allowing complaints via SMS more often than the general portfolio.
Given the security and infrastructure challenges posed by FCS countries, it is no
surprise that SMS emerged as a preferred mode of communication.
Generally, projects will benefit by making as many as many uptake channels
available as possible, so as to exclude the least amount of potential users. While
no uptake channel should take precedence over others as the “best” form of
soliciting complaints, SMS is an important part of this mix (given the ubiquity
of cellphones amongst the poor) and should be increased accordingly. Many
bank teams are under the impression that expensive, built-to-order systems are
necessary for taking advantage of this mode technology, but there are free, out-
of-the-box tools available.8
8
“The Umpteenth Blog on using
SMS Feedback in Projects . . .
Now with Support!,” http://blogs
.worldbank.org/publicsphere/
umpteenth-blog-using-sms-
feedback-projects-now-support
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13RECOMMENDATIONS
RECOMMENDATIONS
1. Environmental and Social Standard 10 should be complemented by a surge
of support to grievance redress in projects
ESS 10 on Stakeholder Engagement, along with the more prominent role accorded
to grievance redress mechanisms throughout the standards, will likely increase the
coverage of GRMs in design and their prevalence in practice if OP 4.10 and 4.12
are any indication. ESS 10’s annex on grievance redress will provide a detailed
articulation of what constitutes a sound GRM. But in order to ensure not just
more “working” GRMs but high-performing, good practice GRMs, a corresponding
surge of training, guidance, and support to task teams must be provided.
A small but strong offering of training, guidance, and direct support from SDV
and OPCS already exists, but these efforts are not sufficient to meet the higher
levels of demand that ESS10 will precipitate. While many champions of griev-
ance redress are currently scattered throughout the bank, all TTLs will need to
understand and be able to communicate the value of GRMs to clients.
In order to do this, training must be offered on designing and implementing
GRMs on a rolling basis, including in country offices, and an e-learning module
on GRMs should be created. Furthermore, guidance on setting up GRMs needs
to be tailored specifically to multiple high-risk sectors so as to create a unified,
good practice approach to grievance redress and avoid “re-inventing the wheel”
with every project.
2. Bank systems and reporting requirements should be revised to provide data
on grievance redress
The limited data used to create this report was either pulled manually from project
documents or obtained via email survey. Needless to say, this is an extremely
inefficient method of obtaining information on the bank’s grievance redress
mechanisms.
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Grievance Redress Mechanisms On Paper and in Practice14
Simple indicators, such as the number of grievances received and resolved, if
made mandatory for projects with GRMs and if fed into internal systems for
automated tracking, would enormously improve bank management’s ability to
monitor and improve the portfolio vis-à-vis grievance redress.
Although OPCS’ Core Sector Indicators include one on grievance redress, it
appears that these indicators have not been used thus far. Along with the rollout
of the Standardized Operational Risk Tool (SORT) to replace the Operational Risk
Assessment Framework (ORAF), the procedures and requirements pertaining to
internal reporting should be revised to include mandatory indicators on grievance
redress as a means of strengthening risk management.
3. SMS (texting) should be institutionally embraced as a means of receiving
complaints
SMS remains mostly a curiosity. To move it from just another brown bag lunch
topic to a true component of project communications requires the institution to
embrace it as a tool. While many projects are using SMS to solicit complaints, it
appears that most of them simply allow for complainants to text an individual, for
example, the project liaison officer. This approach succeeds in creating another
channel, but fails when it comes to logging and tracking responses. Compared
to software that runs on a computer, a limited volume of texts can be efficiently
handled through a phone.
While many SMS gateways exist, the bank provides no formal training on using
SMS for project communications, has no partnerships with any SMS gateway
software provider, and restricts the use of necessary software on its on computers.9
The bank should provide expanded training on SMS gateways, among other
ICT-enabled feedback tools, and partner with a software provider if necessary.
The limits placed on experimentation and demonstration of these tools by our
IT procedures should be lifted through pre-approval and where appropriate,
pre-installation.
9
For example, FrontlineSMS, an
out-of-the-box SMS gateway, can-
not run using its recommended
modem without a staff member
contacting the Office of Information
Security and receiving a revision
to the software to be applied by
their local IT. Hurdles like these are
many and they discourage experi-
mentation, demonstration and ulti-
mately deployment.
8969-GRM Report.pdf 148969-GRM Report.pdf 14 5/12/14 2:56 PM5/12/14 2:56 PM
15CONCLUSION
CONCLUSION
The inclusion of grievance redress mechanisms in projects is on the rise, but more
effort is needed to make their prevalence meaningful. The bank is not lacking in good
examples and concomitant champions, but this has been true for some time now. As
reorganization along global practices begins and the reforms announced throughout
last year are made binding, a sustained push on the grievance redress front should
be made to assert, protect and expand their importance and inclusion in the new
environment.
OPCS is prepared to make this push. Regarding ESS10 and the demand it will pre-
cipitate, OPSOR will be ramping up in multiple areas. The roll-out of a corporate
grievance redress function to receive and triage complaints, and provide support if
needed, is close to launch. With it, a network of formal, regional GRM champions
will be assembled.
By creating a corporate window for complaints that sits below the Inspection Panel
and offers support to task teams in dealing with complaints, OPSOR will strengthen
the capacity of GRMs across the portfolio and use its bank-wide reach to encourage
the sharing of good practices.
OPSOR is also planning to offer training on grievance redress on a rolling, rather than
episodic, basis through a blended learning program (e-learning and face to face). Finally,
in order to target support where it is needed most, OPSOR will assemble packages
of sector-specific case studies and guidance for multiple high-risk global practices.
To improve bank systems and reporting on GRMs, OPSOR is currently coordinating
with Results, Openness and Effectiveness in OPCS to include the data gleaned from
this report as the baseline GRM data in the corporate scorecard. As the bank moves
to global practices, OPSOR will work with OPSRE to ensure that their Core Sector
Indicator on grievance redress is mainstreamed and made a reporting requirement.
To promote SMS, OPSOR already provides training on-demand, in partnership with
SDV, to task teams and clients who request it.
8969-GRM Report.pdf 158969-GRM Report.pdf 15 5/12/14 2:56 PM5/12/14 2:56 PM
Grievance Redress Mechanisms On Paper and in Practice16
All of these things are a good start, but none of them will succeed through the efforts
of OPSOR alone. And while we will continue to work with our partners in OPCS
and SDV along these lines, the promotion of grievance redress mechanisms must
ultimately be a bank-wide effort. Please contact the Dispute Resolution & Prevention
team at disputeresolution@worldbank.org to learn more, share ideas and help move
this issue forward.
Available GRM Guidance for Staff
As mentioned, internal guidance on GRM principles, best practices, and implementation
is available from OPCS and SDV. Items 1–4 from OPCS can be found at the friendly-url
“disputeresolution” and items 5–7 from SDV can be found at the friendly-url “dfggdb.”
Item 8 can be found on the International Finance Corporation’s Compliance Advisor
Ombudsman website.
1. Global Review of Grievance Redress Mechanisms in World Bank Projects: A desk
review of GRMs in the fiscal year 2011 portfolio as they are designed before Board
approval
2. The World Bank’s Approach to Grievance Redress in Projects: A practical frame-
work that can be used by clients and project teams to (i) assess anticipated
grievances,(ii) review the credibility and capacity of existing grievance systems,
and (iii) build or strengthen grievance redress capacity.
3. Evaluating a Grievance Redress Mechanism: A two-page checklist of questions to
evaluate existing grievance redress mechanisms.
4. Grievance Redress Mechanisms: Frequently Asked Questions.
5. GAC How-to Notes: Feedback Matters: Designing Effective Grievance Redress Mech-
anisms for Bank-financed Projects, Part 1 & 2.
6. Using Demand-Side Governance Approaches to Identify and Manage Risks in Projects.
7. Beneficiary Feedback and Third Party Monitoring in Bank-Financed Projects.
8. IFC CAO: A Guide to Designing and Implementing Grievance Mechanisms for
Development Projects.
8969-GRM Report.pdf 168969-GRM Report.pdf 16 5/12/14 2:56 PM5/12/14 2:56 PM
8969-GRM Report.pdf 178969-GRM Report.pdf 17 5/12/14 2:56 PM5/12/14 2:56 PM
Grievance Redress Mechanisms
On Paper and in Practice

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Grievance Redress Mechanisms

  • 1. Grievance Redress Mechanisms On Paper and in Practice
  • 2. Acknowledgements This report was completed in April 2014 and summarizes the findings of a desk review and survey of grievance redress mechanisms in design and implementation. The principal author was Aaron Seyedian, with research assistance from Erfaan Mojgani, Masayuki Omote, Besa Rizvanolli, and Paloma Temiño. It was prepared under the guidance of Amar Inamdar, Marie Brown, and Mark King. The following staff provided advice and inputs or commented on earlier drafts: Sanjay Agarwal, Grant Milne, Scott T. Adams and Maria Elena Garcia Nora. 8969-GRM Report.pdf b8969-GRM Report.pdf b 5/12/14 2:56 PM5/12/14 2:56 PM
  • 3. Grievance Redress Mechanisms On Paper and in Practice 8969-GRM Report.pdf i8969-GRM Report.pdf i 5/12/14 2:56 PM5/12/14 2:56 PM
  • 4. Global Review of Grievance Redress Mechanisms in World Bank Projectsii 8969-GRM Report.pdf ii8969-GRM Report.pdf ii 5/12/14 2:56 PM5/12/14 2:56 PM
  • 5. iiiContents CONTENTS ABBREVIATIONS AND ACRONYMS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v INTRODUCTION AND BACKGROUND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 REVIEW METHODOLOGY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 FINDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 RECOMMENDATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 CONCLUSION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 8969-GRM Report.pdf iii8969-GRM Report.pdf iii 5/12/14 2:56 PM5/12/14 2:56 PM
  • 6. Global Review of Grievance Redress Mechanisms in World Bank Projectsiv 8969-GRM Report.pdf iv8969-GRM Report.pdf iv 5/12/14 2:56 PM5/12/14 2:56 PM
  • 7. vAbbreviations and Acronyms AFR Africa Region ARD Agriculture and Rural Development sector CAO Compliance Advisor Ombudsman CPS Country Partnership Strategy CSI Core Sector Indicators DPL Development Policy Loan DRP Dispute Resolution and Prevention unit (OPCS) EAP East Asia and Pacific Region ECA Eastern Europe and Central Asia Region EDU Education sector ENV Environment sector FPD Financial and Private Sector Development GAC Governance and Anti-Corruption GRM Grievance Redress Mechanism HNP Health, Nutrition and Population IBRD International Bank of Reconstruction and Development ICT Information and Communication Technology IDA International Development Association IFC International Finance Corporation INT Integrity Vice Presidency IPP Indigenous Peoples Plan IPPF Indigenous Peoples Planning Framework ISDS Integrated Safeguards Data Sheet ICR Implementation Completion Report ISR Implementation Status Report LCR Latin America & Caribbean Region MENA Middle East and North Africa Region OPCS Operations Policy & Country Services OPSOR Operations Risk Management ORAF Operational Risk Assessment Framework P4R Program for Results Loan RAP Resettlement Action Plan SAR South Asia Region SDV Social Development SP Social Protection WBI World Bank Institute ABBREVIATIONS AND ACRONYMS 8969-GRM Report.pdf v8969-GRM Report.pdf v 5/12/14 2:56 PM5/12/14 2:56 PM
  • 8. Global Review of Grievance Redress Mechanisms in World Bank Projectsvi 8969-GRM Report.pdf vi8969-GRM Report.pdf vi 5/12/14 2:56 PM5/12/14 2:56 PM
  • 9. 1INTRODUCTION AND BACKGROUND INTRODUCTION AND BACKGROUND 2013 was a big year for citizen engagement at the World Bank Group. In February, the Dispute Resolution & Prevention team released the “Global Review of Grievance Redress Mechanisms in World Bank Projects,” and over the course of the year, citizen engagement strategies were drawn up in three regions and Operations Policy and Country Services (OPCS). Perhaps most notably, President Jim Yong Kim called for beneficiary feedback in 100% of projects with clear beneficiaries in what is now an oft-cited speech from the Annual Meetings. As the Strategic Framework for Mainstreaming Citizen Engagement in World Bank Group Operations is finalized,1 the safeguards policy update completed, and the Stan- dardized Operational Risk-rating Tool (SORT) rolled out for risk management, 2014 is on track to become a worthy successor. Considering how crucial grievance redress mechanisms (GRMs) are to the citizen engagement movement specifically, the bank’s performance generally, and our response to those negatively impacted by our projects most importantly, Operations Risk Management (OPSOR) prepared this note to provide insight into how GRMs on paper are actually functioning in practice. The 2013 “Global Review of Grievance Redress Mechanisms in World Bank Projects” provided staff and management with an overview of GRMs in project design by reviewing the Project Appraisal Documents (PADs), and where available, the Environmental and Social Impact Assessments (ESIAs), Environmental and Social Management Frameworks (ESMFs), Resettlement Action Plans (RAPs), Resettlement Policy Frameworks (RPFs), Indigenous Peoples Plans (IPPs), and Indigenous Peoples Policy Frameworks (IPPFs) for all project approvals in fiscal year 2011.2 Its most basic finding, among many others, was that 50% of approved projects in fiscal year 2011 contained a GRM. 1 Engaging with Citizens for Im- proved Results, https://consultations .worldbank.org/consultation/ engaging-citizens-improved-results 2 Excluding Development Pol- icy Loans, Financial Intermedi- ary Loans, and Trust Funds < $5 million. 8969-GRM Report.pdf 18969-GRM Report.pdf 1 5/12/14 2:56 PM5/12/14 2:56 PM
  • 10. Grievance Redress Mechanisms On Paper and in Practice2 Good data on GRMs in project design had finally been gathered, but important ques- tions remained. Will these GRMs actually be created? Of those that will, how well will they work? How many complaints will they receive? Unfortunately, the review was only able to examine a small subset of projects along this line of questioning. This note will pick up where the “Global Review” left off. 8969-GRM Report.pdf 28969-GRM Report.pdf 2 5/12/14 2:56 PM5/12/14 2:56 PM
  • 11. 3REVIEW METHODOLOGY REVIEW METHODOLOGY The goal of this review is to provide management and staff with: • An assessment of GRM existence in project design • An assessment of GRM existence in practice • An assessment of GRM quality in practice • Recommendations for improving GRM quality in implementation and GRM management at the corporate level For the assessment of GRMs in project design, a desk review was conducted of all approvals in fiscal year 2012, excluding Development Policy Loans, Financial Inter- mediary Loans, and trust funds under $5 million (235 total projects; ~$23 billion in total commitments). This is in line with the methodology of the fiscal year 2011 review. For each project, the team reviewed the Project Appraisal Document (PAD) and where available, the Environmental and Social Impact Assessment (ESIA), Envi- ronmental and Social Management Framework (ESMF), Resettlement Action Plan (RAP), Resettlement Policy Framework (RPF), Indigenous Peoples Plan (IPP), and/ or Indigenous Peoples Policy Framework (IPPF). Using these documents, the team asked the following questions: 1. Is there a reference to grievance redress in project documents? (Yes or No) 2. What is the extent of the reference? (Extensive or Minimal) 3. Will data be collected? (Yes or No) 4. Who is collecting data? 5. Are funds dedicated to the GRM? For the assessment of GRMs in implementation, a survey was sent out to the Task Team Leaders (TTLs) of each project where design documents indicated a grievance 8969-GRM Report.pdf 38969-GRM Report.pdf 3 5/12/14 2:56 PM5/12/14 2:56 PM
  • 12. Grievance Redress Mechanisms On Paper and in Practice4 redress mechanism. This survey, sent out in the third quarter of fiscal year 2014, asked TTLs the following questions to evaluate the existence and quality of GRMs: Doestheprojecthaveaworkinggrievanceredressmechanism? Ifyes... Arecitizensabletolodgeacomplaint via... Howmanycomplaintshavebeenreceived? Phone? Howmanycomplaintshavebeenresolved? SMS(Texting)? Howmanycaseshavebeenappealedbycomplainants? In-Person? Arethereservicestandardsthatensuretimelyresponses? Mail? RESPONSE RATE 79% (121/154) of those queried responded to the survey. The findings related to GRMs in practice are representative of this cohort. CONSTRAINTS 1. Only TTLs of projects which included a GRM in design were surveyed. It is con- ceivable that some projects which did not commit to a GRM in design may have created one in practice. 2. Answers were self-reported via email and no follow-up verification was done. 3. TTLs were given no guidelines as to what constitutes a working grievance redress mechanism, so their answers can only be considered indications of their own judgment. 4. Not all TTLs responded to the survey, so the sample is biased by those willing to report. This may skew toward those with existing and/or high-performing grievance redress mechanisms. 5. The definition of complaints which have been “resolved” is open to interpreta- tion. What is thought to be “resolved” from the client/TTL perspective may not necessarily be so from the perspective of the complainant. 6. As the review covers fiscal year 2012 approvals, some projects have not started implementation. Although good practice dictates otherwise, many of these projects are not soliciting complaints at this stage. 8969-GRM Report.pdf 48969-GRM Report.pdf 4 5/12/14 2:56 PM5/12/14 2:56 PM
  • 13. 5FINDINGS 3 “‘Governance and Anticorrup- tion: A Benchmarking and Learn- ing Review’ produced by QAG in 2009. The QAG statistic is based on a limited sample of FY08 approv- als and the exact methodology is unclear. Therefore, the data are not strictly comparable but can be considered a rough compara- tor.” p. 7, “Global Review of Griev- ance Redress Mechanisms,” Marie Brown, Dispute Resolution & Pre- vention, February 2013. FINDINGS FINDINGS SNAPSHOT: ON PAPER 1. GRM coverage continued to rise Of all fiscal year 2012 approv- als, 66% (154/235) included a grievance redress mechanism in project design. This was up from 50% in fiscal year 2011 and 28% in fiscal year 2008.3 2. GRM descriptions tended toward extensive 70% (108/154) of GRMs in design were outlined “exten- sively,” meaning they con- tained more than a perfunc- tory reference such as “The project will have a grievance redress mechanism.” 3. Roughly half of approvals committed to collecting data 53% (82/154) of projects articulated a commitment to collect the data the GRM generates. PercentofSampledProjects 0 60 20 40 80 2008 Fiscal Year 20122011 100 No GRM GRM 72% 28% 50% 50% 34% 66% Figure 1. World Bank Projects with a GRM Reference in the PAD, RPF Documents PercentofSampledProjects 0 60 20 40 80 FY11 Funds committed? Commitment to collect data? FY12 100 No GRMGRM 34% 50% 50% 66% Yes 22% No 78% No 47% Yes 53% Figure 2. GRMs in Project Design 8969-GRM Report.pdf 58969-GRM Report.pdf 5 5/12/14 2:56 PM5/12/14 2:56 PM
  • 14. Grievance Redress Mechanisms On Paper and in Practice6 4. Committing funds was relatively rare Only 22% (34/154) of approvals specified funds for the creation and/or operation of the GRM. FINDINGS SNAPSHOT: IN PRACTICE 1. GRM coverage fell in practice When surveyed, only 60% (72/121) of proj- ects that planned a GRM in design reported a working mechanism. This means that only 31% of projects approved in fiscal year 2012 had a working GRM in practice (72/235).4 2. More than a quarter of working GRMs were unused 28% (20/72) of all projects reporting a working GRM had zero complaints received. 3. Nearly one in five GRMs had no data on complaints 19% (14/72) of all projects reporting a working GRM had no data on complaints received. This was either because grievances were not logged or the TTL was unable to get the data from the client. 4. Only 21% (15/72) of GRMs reported working received more than 20 complaints (6% [15/235] of fiscal year 2012 approvals) 5. Aggregate resolution rate was 75% As of the third quarter of fiscal year 2014, fiscal year 2012 approvals had received 2,000,271 complaints and resolved 1,503,371 complaints.5 4 Note that with 79% responding to the survey, the 31% coverage figure must be regarded as an esti- mate. That said, the high response rate and the likelihood that non- repliers have a non-working GRM over a working one lends confi- dence to this estimate. 5 Note that of the total, 1,981,207 complaints received and 1,486,181 complaints resolved stem from one large project. GRM presence– Project Design (Surveyed Q3 FY14) GRM presence– Survey Response 69% 34% 66% 31% Figure 3. FY12 Approvals No data or zero 1 to 20 47% More than 20 32% (23 Projects) 19% No Data (14 Projects) 28% Zero Complaints (20 Projects) 21% (15 Projects) Projects Reporting a Working GRM Figure 4. Number of Complaints Received 8969-GRM Report.pdf 68969-GRM Report.pdf 6 5/12/14 2:56 PM5/12/14 2:56 PM
  • 15. 7FINDINGS 6. Most projects offered multiple uptake channels, with SMS the least prevalent Among those responding to the survey: 92% (66/72) accepted complaints in-person 86% (62/72) accepted complaints via mail 83% (60/72) accepted complaints via phone 42% (30/72) accepted complaints via SMS 7. Appeals processes were over- whelmingly not used or not included Of those projects confirming a working GRM, 60% (43/72) reported zero com- plaints going to appeal. 26% (19/72) of reported working GRMs had no appeals process. 8. Service standards were included in a majority of working GRMs Service standards are timelines available to the public which outline how long they can expect to wait for the acknowledgement, response, action, and resolution of complaints. 63% (46/72) of projects reported having service standards. 9. South Asia led the regions with the highest percentage of projects reporting working GRMs when one had been planned in design (dotted line indicates average). Percentofprojects containinguptakechannel 0 60 20 40 80 In-person PhoneMail SMS 100 50 10 30 70 90 Projects Reporting a Working GRM Figure 5. Available Uptake Channels 0 60 20 40 80 SAR EAPMNA ECA LCR AFR 50 10 30 70 90 Figure 6. Percent of Projects Reporting Working GRMs by Region 8969-GRM Report.pdf 78969-GRM Report.pdf 7 5/12/14 2:56 PM5/12/14 2:56 PM
  • 16. Grievance Redress Mechanisms On Paper and in Practice8 6 Full names, in order, are: Social Development; Agriculture & Rural Development; Education; Trans- port; Energy and Mining; Urban Development; Environment; Health, Nutrition & Population; Water; Financial & Private Sec- tor Development; Social Protec- tion; and Public Sector Governance. Global Information & Communica- tions Technology (GIC) and Finan- cial Inclusion Practice (FIP) not included because of extremely small sample sizes. 0 60 20 40 80 SDV TRARD UD HE FPDEMTED ENV WAT SP PS 50 10 30 70 10. Social Development led the sectors6 with the highest percentage of projects reporting working GRMs when one had been planned in design (dotted line indicates average). 11. The correlations between extensive descriptions, planning to provide dedicated funds, and planning to collect data in design and reporting a “working GRM” in the survey ranged from slightly inverse to moderately positive Funding—58% (15/26) of projects committing funds in design documents reported working GRMs when surveyed, versus 62% (34/55) of those projects which did not commit funds. Descriptions—61% (54/88) of projects with extensive GRM descriptions reported working GRMs when surveyed, versus 55% (18/33) of those with minimal descriptions. Data Collection—66% (43/65) of projects committing to collect GRM data in design documents reported working GRMs when surveyed, versus 48% (21/44) of those projects which did not commit to data collection. 12. High-performing GRMs (>20 complaints received), however, were associated with extensive descriptions and commitments to collect data 73% (11/15) of projects with high-performing GRMs committed to collecting data, and 80% (12/15) contained extensive descriptions in project design. Only 20% (3/15) indicated a funding commitment. Given that 73% (11/15) of these GRMs were linked to involuntary resettlement, indigenous peoples, or both, it is highly likely that their extensive descriptions and data collection commitments stemmed from the requirements outlined by Operational Policies 4.10 and 4.12 (and, of course, the context which necessitates them in the first place). Figure 7. Percent of Projects Reporting Working GRMs by Sector 8969-GRM Report.pdf 88969-GRM Report.pdf 8 5/12/14 2:56 PM5/12/14 2:56 PM
  • 17. 9FINDINGS 7 Note that TTLs were not specifi- cally asked why their GRMs were not working. The 59% reporting that implementation and/or phys- ical works had not started volun- teered this information. 13. GRMs were associated with imple- mentation and/or physical works Of those projects reporting a non- working GRM despite having committed to one in design, 59% (29/49) of TTLs said their GRM is not functional because implementa- tion and/or physical works had not started.7 Additionally, 60% (9/15) of high-performing GRMs were addi- tional financing projects, implying that more complaints are solicited as a project matures. Fragile States and Conflict-Affected Situations in Focus Paper&Practice:ProjectsinFCScountrieswerefarmorelikelytoinclude aGRMinprojectdesignbutlesslikelytoreportaworkingGRMthanthe rest of the portfolio. For approvals in fiscal year 2012, 100% (25/25) of FCS projects included a GRM in project design (versus 66% of approvals in general) but only 41% (9/22) of survey respondents reported a working GRM (versus 60% of approvals in general). Uptake Channels: Projects in FCS countries were more likely to allow complaintstobesubmittedviaSMSthanprojectsinthegeneralportfolio. Forapprovalsinfiscalyear2012,67%ofFCSprojectsacceptedcomplaints via SMS versus 43% of projects in the general portfolio. “Establishment of a specific unit in charge of grievance redress and high commitment of the project owner’s management.” “Setting up various channels to encourage participation (SMS, phone, email, mail).” “The bank was able to convince the client governments to consider GRM as an integral part of the program administration.” “A study into technology options that could be used should have been conducted from the outset.” Easy Difficult TTLs of Projects with High-Performing GRMs: What made setting up a GRM easy? What made it difficult? TTLs of projects with more than 20 complaints received were asked to share what made setting up a GRM easy and what made it difficult. Below are some of their responses: “The project’s commitment to promoting transparency and regular disclosure of project information helped trigger further questions and complaints.” “Implementing agency recognized the importance of setting up a mechanism . . . and had a strong commitment to implement it . . . It was also made a loan covenant requirement.” “In this country, beneficiaries used to go directly to street demonstrations to express their disappointment with delays or dissatisfaction. With the GRM, the ministry has been able to avoid public troubles.” “Very remote and hard to reach areas made it difficult, in some instances, to socialize the GRM.” “Insufficient provision of training among staff working on the GRM meant that the processing of cases varied in terms of process quality and time.” “Project management . . . [was] worried about being swamped with claims since they were regularly experiencing delays in implementation.” 8969-GRM Report.pdf 98969-GRM Report.pdf 9 5/12/14 2:56 PM5/12/14 2:56 PM
  • 18. Grievance Redress Mechanisms On Paper and in Practice10 TAKEAWAYS 1. Paper is not translating into practice As has long been assumed, and borne out by smaller scale studies, GRMs planned for on paper did not necessarily become working GRMs after board approval. Not only did the coverage of GRMs in practice fall to roughly half of that planned in design, but the correlation between robust design and the actual existence of a GRM was not strong. While it was true that high-performing GRMs usually had good designs, it did not appear that good designs in general strongly corresponded to implementation. 2. “Working GRMs” do not conform to a standard of quality or principles of good practice The benchmark for quality in working GRMs appeared low. Roughly half of all self-reported “working” grievance redress mechanisms reported either no com- plaints received or had no data or access to data on grievances redress. While necessarily difficult to glean from a desk review, even a generous estimate would draw the conclusion that many of these GRMs were functionally non-existent, even if roles and responsibilities had in fact been assigned in the hypothetical event of a complaint. Other indicators of quality were low as well. The data suggested that appeals processes were largely unused, untracked, and possibly non-existent. It is true that there must be de facto appeals processes for most GRMs via local legal systems. But without assessing the credibility of the judiciary and providing an alternative appeals process if necessary, task teams may be missing out on their last opportunity to promote quicker resolution for the complainant and prevent escalation and protraction of the complaint. Service standards, the timelines for the acknowledgment, response, and resolution of complaints, were more prevalent (63% of working GRMs had service standards) but far from universal. While bank toolkits and guidance on creating adequate grievance redress mechanisms exist, it appeared that most GRMs surveyed were not following their prescriptions. 3. GRMs start functioning too late In 59% of projects without a working GRM, TTLs said that the absence of a GRM was because the project had not begun implementation and/or physical works. One TTL explained: “No land acquisition has been initiated. No construction is underway. Therefore, the grievance mechanism is not really relevant at this stage.” 8969-GRM Report.pdf 108969-GRM Report.pdf 10 5/12/14 2:56 PM5/12/14 2:56 PM
  • 19. 11FINDINGS With so many projects reporting this type of delay, it is clear that grievance redress mechanisms are often viewed as tools which pertain to narrow eligibilities, time- frames, and audiences. Certainly, all GRMs differ and there may be some cases where this restrictive application is appropriate, but generally, the earlier a GRM is functioning, the better. Even before project components pertaining to construction or resettlement begin, concerns about health and safety, environmental impact, project location/ alignment, and possible unintended consequences of the project, among other concerns, are likely to be voiced. Furthermore, soliciting complaints early on increases the likelihood that grievances will be addressed before they escalate to potential intractability. 4. GRMs are not being used to prioritize supervision, aid project management or improve project performance Beyond the obvious benefits of grievance redress mechanisms to users, they can be useful management aids which can point to weaknesses in a certain aspect or location of a project. However, given how late many GRMs were being implemented and how many reportedly working GRMs still recorded no complaints or no data, it is likely that GRMs were not being used as an asset for better management and, in turn, performance. Anecdotally, many TTLs surveyed did not know the statistics on their project’s GRM and had to request them from the client. This process sometimes took weeks. The unavailability of real-time information for the task team has negative implications for risk management. 5. High-performing GRMs are predominantly linked to bank policy Nearly three-quarters of all high-performing GRMs (>20 complaints received) reported by survey respondents were linked to bank policy on Indigenous Peoples (OP 4.10), Involuntary Resettlement (OP 4.12), or both. This intuitive linkage between high-performing GRMs and bank policy mandating grievance redress was first established by the small qualitative review in the “Global Review of Grievance Redress Mechanisms.” Its presence in a much larger sample establishes this linkage more reliably and highlights the issue-specific approach that currently stereotypes many of the wider portfolio’s GRMs. 6. GRMs are slow to embrace new technology A large majority of projects with functioning GRMs allowed for complaints to be lodged via phone, mail and/or in-person. SMS (texting) was conspicuously less 8969-GRM Report.pdf 118969-GRM Report.pdf 11 5/12/14 2:56 PM5/12/14 2:56 PM
  • 20. Grievance Redress Mechanisms On Paper and in Practice12 available, despite the relative ubiquity of cellphones in poor countries and the potential savings for users associated with this mode. FCS countries were a notable exception, allowing complaints via SMS more often than the general portfolio. Given the security and infrastructure challenges posed by FCS countries, it is no surprise that SMS emerged as a preferred mode of communication. Generally, projects will benefit by making as many as many uptake channels available as possible, so as to exclude the least amount of potential users. While no uptake channel should take precedence over others as the “best” form of soliciting complaints, SMS is an important part of this mix (given the ubiquity of cellphones amongst the poor) and should be increased accordingly. Many bank teams are under the impression that expensive, built-to-order systems are necessary for taking advantage of this mode technology, but there are free, out- of-the-box tools available.8 8 “The Umpteenth Blog on using SMS Feedback in Projects . . . Now with Support!,” http://blogs .worldbank.org/publicsphere/ umpteenth-blog-using-sms- feedback-projects-now-support 8969-GRM Report.pdf 128969-GRM Report.pdf 12 5/12/14 2:56 PM5/12/14 2:56 PM
  • 21. 13RECOMMENDATIONS RECOMMENDATIONS 1. Environmental and Social Standard 10 should be complemented by a surge of support to grievance redress in projects ESS 10 on Stakeholder Engagement, along with the more prominent role accorded to grievance redress mechanisms throughout the standards, will likely increase the coverage of GRMs in design and their prevalence in practice if OP 4.10 and 4.12 are any indication. ESS 10’s annex on grievance redress will provide a detailed articulation of what constitutes a sound GRM. But in order to ensure not just more “working” GRMs but high-performing, good practice GRMs, a corresponding surge of training, guidance, and support to task teams must be provided. A small but strong offering of training, guidance, and direct support from SDV and OPCS already exists, but these efforts are not sufficient to meet the higher levels of demand that ESS10 will precipitate. While many champions of griev- ance redress are currently scattered throughout the bank, all TTLs will need to understand and be able to communicate the value of GRMs to clients. In order to do this, training must be offered on designing and implementing GRMs on a rolling basis, including in country offices, and an e-learning module on GRMs should be created. Furthermore, guidance on setting up GRMs needs to be tailored specifically to multiple high-risk sectors so as to create a unified, good practice approach to grievance redress and avoid “re-inventing the wheel” with every project. 2. Bank systems and reporting requirements should be revised to provide data on grievance redress The limited data used to create this report was either pulled manually from project documents or obtained via email survey. Needless to say, this is an extremely inefficient method of obtaining information on the bank’s grievance redress mechanisms. 8969-GRM Report.pdf 138969-GRM Report.pdf 13 5/12/14 2:56 PM5/12/14 2:56 PM
  • 22. Grievance Redress Mechanisms On Paper and in Practice14 Simple indicators, such as the number of grievances received and resolved, if made mandatory for projects with GRMs and if fed into internal systems for automated tracking, would enormously improve bank management’s ability to monitor and improve the portfolio vis-à-vis grievance redress. Although OPCS’ Core Sector Indicators include one on grievance redress, it appears that these indicators have not been used thus far. Along with the rollout of the Standardized Operational Risk Tool (SORT) to replace the Operational Risk Assessment Framework (ORAF), the procedures and requirements pertaining to internal reporting should be revised to include mandatory indicators on grievance redress as a means of strengthening risk management. 3. SMS (texting) should be institutionally embraced as a means of receiving complaints SMS remains mostly a curiosity. To move it from just another brown bag lunch topic to a true component of project communications requires the institution to embrace it as a tool. While many projects are using SMS to solicit complaints, it appears that most of them simply allow for complainants to text an individual, for example, the project liaison officer. This approach succeeds in creating another channel, but fails when it comes to logging and tracking responses. Compared to software that runs on a computer, a limited volume of texts can be efficiently handled through a phone. While many SMS gateways exist, the bank provides no formal training on using SMS for project communications, has no partnerships with any SMS gateway software provider, and restricts the use of necessary software on its on computers.9 The bank should provide expanded training on SMS gateways, among other ICT-enabled feedback tools, and partner with a software provider if necessary. The limits placed on experimentation and demonstration of these tools by our IT procedures should be lifted through pre-approval and where appropriate, pre-installation. 9 For example, FrontlineSMS, an out-of-the-box SMS gateway, can- not run using its recommended modem without a staff member contacting the Office of Information Security and receiving a revision to the software to be applied by their local IT. Hurdles like these are many and they discourage experi- mentation, demonstration and ulti- mately deployment. 8969-GRM Report.pdf 148969-GRM Report.pdf 14 5/12/14 2:56 PM5/12/14 2:56 PM
  • 23. 15CONCLUSION CONCLUSION The inclusion of grievance redress mechanisms in projects is on the rise, but more effort is needed to make their prevalence meaningful. The bank is not lacking in good examples and concomitant champions, but this has been true for some time now. As reorganization along global practices begins and the reforms announced throughout last year are made binding, a sustained push on the grievance redress front should be made to assert, protect and expand their importance and inclusion in the new environment. OPCS is prepared to make this push. Regarding ESS10 and the demand it will pre- cipitate, OPSOR will be ramping up in multiple areas. The roll-out of a corporate grievance redress function to receive and triage complaints, and provide support if needed, is close to launch. With it, a network of formal, regional GRM champions will be assembled. By creating a corporate window for complaints that sits below the Inspection Panel and offers support to task teams in dealing with complaints, OPSOR will strengthen the capacity of GRMs across the portfolio and use its bank-wide reach to encourage the sharing of good practices. OPSOR is also planning to offer training on grievance redress on a rolling, rather than episodic, basis through a blended learning program (e-learning and face to face). Finally, in order to target support where it is needed most, OPSOR will assemble packages of sector-specific case studies and guidance for multiple high-risk global practices. To improve bank systems and reporting on GRMs, OPSOR is currently coordinating with Results, Openness and Effectiveness in OPCS to include the data gleaned from this report as the baseline GRM data in the corporate scorecard. As the bank moves to global practices, OPSOR will work with OPSRE to ensure that their Core Sector Indicator on grievance redress is mainstreamed and made a reporting requirement. To promote SMS, OPSOR already provides training on-demand, in partnership with SDV, to task teams and clients who request it. 8969-GRM Report.pdf 158969-GRM Report.pdf 15 5/12/14 2:56 PM5/12/14 2:56 PM
  • 24. Grievance Redress Mechanisms On Paper and in Practice16 All of these things are a good start, but none of them will succeed through the efforts of OPSOR alone. And while we will continue to work with our partners in OPCS and SDV along these lines, the promotion of grievance redress mechanisms must ultimately be a bank-wide effort. Please contact the Dispute Resolution & Prevention team at disputeresolution@worldbank.org to learn more, share ideas and help move this issue forward. Available GRM Guidance for Staff As mentioned, internal guidance on GRM principles, best practices, and implementation is available from OPCS and SDV. Items 1–4 from OPCS can be found at the friendly-url “disputeresolution” and items 5–7 from SDV can be found at the friendly-url “dfggdb.” Item 8 can be found on the International Finance Corporation’s Compliance Advisor Ombudsman website. 1. Global Review of Grievance Redress Mechanisms in World Bank Projects: A desk review of GRMs in the fiscal year 2011 portfolio as they are designed before Board approval 2. The World Bank’s Approach to Grievance Redress in Projects: A practical frame- work that can be used by clients and project teams to (i) assess anticipated grievances,(ii) review the credibility and capacity of existing grievance systems, and (iii) build or strengthen grievance redress capacity. 3. Evaluating a Grievance Redress Mechanism: A two-page checklist of questions to evaluate existing grievance redress mechanisms. 4. Grievance Redress Mechanisms: Frequently Asked Questions. 5. GAC How-to Notes: Feedback Matters: Designing Effective Grievance Redress Mech- anisms for Bank-financed Projects, Part 1 & 2. 6. Using Demand-Side Governance Approaches to Identify and Manage Risks in Projects. 7. Beneficiary Feedback and Third Party Monitoring in Bank-Financed Projects. 8. IFC CAO: A Guide to Designing and Implementing Grievance Mechanisms for Development Projects. 8969-GRM Report.pdf 168969-GRM Report.pdf 16 5/12/14 2:56 PM5/12/14 2:56 PM
  • 25. 8969-GRM Report.pdf 178969-GRM Report.pdf 17 5/12/14 2:56 PM5/12/14 2:56 PM
  • 26. Grievance Redress Mechanisms On Paper and in Practice