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Grievance Redress Framework

1.0 About the Project
Export Competitiveness for Jobs (EC4J) is a six-year project (July 2017 to June 2023), which aims to support Government of Bangladesh’s export diversification targets. The project is designed to enhance growth and competitiveness of selected sectors beyond Ready-Made Garments (RMG), and to create more and better job opportunities. The project will focus on four priority sectors in which Bangladesh has a demonstrated comparative advantage or sectors that provide essential inputs in export-oriented manufacturing value chains. These sectors are: (1) leather and leather goods; (2) footwear (leather & non-leather); (3) light engineering and (4) plastics. To attain the objectives of the project it has been divided into four components – 1) market access support program; 2) productivity enhancement program; 3) Public Investment Facility for Infrastructure Constraints (PIFIC) and 4) project implementation, monitoring and evaluation. It is being financed by the IDA of the World Bank Group and implemented by Ministry of Commerce (MoC) of the Government of the People’s Republic of Bangladesh.

PIFIC will finance small-scale construction activities and procurement of equipment which may cause environmental impact because of construction and existing equipment disposal. The project will also finance technology up-gradation and production process to improve the ESQ standards for the development of the leather, footwear, plastics, and light engineering sectors, which may cause adverse side effects on environment due to improper operation. However, the project is classified as Category B. OP/BP 4.01- Environmental Assessment ascertained that the activities involved are not expected to cause any significant negative or irreversible changes in the environment during the implementation or operation stage, if adequate measures are followed. The project will partly address negative environmental impacts from the leather, footwear, plastics and light engineering sectors. It will only support activities which can be managed through the implementation of an Environmental Management Plan (EMP). Project has also triggered OP4.12 and OP 4.10, though there may not be any land acquisition or tribal people may not be affected. Any stakeholders including community people, labors, affected person have the right to place grievance to project authority.

Grievance mechanisms are an integral part of stakeholder engagement process. EC4J has established a multi-level process for addressing grievances from project-affected people, labors and other relevant stakeholders.

According to the requirement of World Bank Safeguard policy and for the smooth implementation of the EC4J project, MoC has establish a two level grievance mechanism to receive and facilitate resolution of affected people, communities and other stakeholders who raise concerns and grievances about the MoC’s environmental and social performance. The grievance mechanism is an important part of stakeholder engagement process and the process scaled to address concerns promptly, use an understandable and transparent process that is culturally appropriate and readily accessible to all segments of the affected people, and do so at no cost to PAP’s and without retribution. The mechanism is alsoimpeding access to judicial and administrative remedies. The MoC will inform the stakeholders about the mechanism in the course of its community engagement process.

Key principles and steps for establishing and maintaining an effective project-level grievance mechanism are illustrated in Figure 1.

Figure 1. Basic Design Elements of a Project-Level Grievance Mechanism

For the smooth implementation of the GRM, PIU has formed a two level GRC to resolve any complains within 30 working days. First level GRC is local level comprised of 2 members. second level GRC is PIU level comprising of 7 members.

3. Examples of possible Grievances:
Any complaints received by local level or PIU level, must be solved by GRC. Some of the common issues are given below:

Project Land Acquisition under PIFIC: Overall impact on land acquisition, resettlement will be minimal. Project will try to avoid acquiring any private land in this project as most of the intervention will be on government khash land or already acquired land. In that case, there is possibility of the presence of squatters on empty government khash land or public land. This Component has direct link and related procurement activities may affect the community or individual household due to the establishment of the TCs. The construction work under the PIFIC can cause construction related social impact and possibly include some land acquisition. The PIFIC will upgrade access roads and associated facilities and the project will also make use unused public land wherever possible. The project will use private land only if absolutely necessary for off-site infrastructure.

Besides, there will be a number of interventions in the area of skill enhancement, technology transfer, and ESQ services for selected enterprise which may affect people or community and it has a likely chance to create discrepancies, which may require to redress properly and transparently.

Working condition of the labors and labor influx may cause grievances. All the internal and external labors including the community people have the right to complain to the GRC and PIU representative will provide all the supports to place the grievances.

As cross sectional issue gender sensitivity with mainstreaming gender has been included in the project. Moreover, a study revealed that footwear and plastics sub-sectors employ large numbers of women in different capacities. According to the report, the level of technical knowhow and access to information is relatively low. They have lack of workplace safety, affordable and safe means of transport, and ancillary infrastructure such as childcare and rest rooms. The project will support gender sensitization and awareness raising at factories and training institutes. Though there will be routine Gender Sensitivity Survey/Gender Audit, however carrying out all these gender sensitization and gender mainstreaming activities may cause issues of grievance.

4.0 Implementation of Grievance Redress Mechanism (GRM)
It is always better to resolve the issue at the local level where a concern or grievance is created. Therefore, bottom up and component specific grievance mechanism are likely alternative dispute resolution (ADR) at the point of occurrence often worthwhile in terms of social and resettlement management. WB has specific clauses/guidelines requiring the borrower/client to set up and maintain a grievance redress mechanism at the project level, which aims to solve grievance at the local level. The GRM of the EC4J Project has a Grievance Redress Committee (GRC) to resolve grievance related to compensation, relocation, mitigation and prevention of grievance aspects. All affected persons of this project have full and free access to GRC.

5.0 Grievance Redress Committee (GRC)
PIU has formed a two level GRC to resolve any complains within 30 days. First level GRC is local level and second level GRC is PIU level. First level GRC is comprises if 2 members where one member is from the firm/industry and second member is from the community who is a knowledgeable and respected person. GRC at PIU level is comprised of seven members. Project director will chair the committee. DPD-2 is the member secretary and other members will be social management specialist, environment management specialist, procurement specialist, one knowledgeable and respected person from the community preferably University teacher. The seventh member of PIU will also represent at local level.

If any complaint is submitted at local level, member from local GRC will record and solve the grievance. If it is not solved locally, GRC will transfer the issue at PIU. The entire process will be managed within 30 working days. Any stakeholders have the right to complain either offline or online. GRC decisions are based on majority and it is disclosed and available for review by the stakeholders. If any disputant is unhappy or un-satisfied with the outcome of the GRC, he/she may file cases in the court. Maximum duration of disclosing the result of any application is 30 working days from the date of submission the complaint through online complaint box. If any application is sent through a postal or directly to the Complaint Box at the Project Office, then Focal Point will receive the grievance and notify the claimed person by an auto generated text message with a track number. So that s/he can have access to tracking the status on the website. In this case the day will be counted from the date when his or her complaint is recorded at the online depository system.

6.0 Grievance Redress Focal Point
The main responsibilities of the local focal point and PIU level focal point are given below:
1. Receipt of Grievance and record it with the website.
2. He/she will try to solve the grievance on spot. If it is not possible a tentative hearing date will be disclosed.
3. Based on the gravity of the grievance, hearing will be either at local level or at the office of PIU.
4. All the updated process and results will be disclosed to the project website.

Convener/chair of the GRC is responsible to handle the entire mechanism in a timely manner. He/She will keep liaison with the other members of the committee.

The information and facilitation counter is designated as Focal Point for receiving the grievances/complaints from the citizens who are adversely affected due to the implementation of the project and its services. Any stakeholders can raise grievances directly to the websites, over phone or through mail. The Focal Point is responsible for receiving the grievances, issuing the acknowledgement receipt simultaneously and maintains the record in the format as Particulars of Citizen/Client, Particulars of the Grievance, Date of Receipt, Name, Address, Landline/ Mobile/Email, Whether Acknowledgement given at the time of receipt, Subject of the grievance, Brief description, Date of Acknowledgement. The following formats will be used:

Sl Date and description of Grievance Grievance prone areas identified Root cause Identified Action Required to Improve System Planned date and Authority Responsible for Taking Action Action Taken date

Figure: 01 Key Steps for GRM Operation Phase
S-1 S-2 S-3 S-4 S-5 S-6
1-2 days 3-4 days 5-14 days 15-17 days 18-28 days 29-30

7.0 Communication to complainant
At the time of acknowledgement, the complainant needs to be provided with the following information:
a. Grievance tracking number to facilitate monitoring and reminders by the plaintiff.
b. Expected time of redress (Prescribed maximum time limit for completion of redress is 30 days).
c. If not addressed within expected time, what actions can be taken by the complainant. The complainant can track his or her complaint in the website of the project if it is submitted online. If otherwise like any complaint is submitted through a prescribed form of Complaint/ Grievance Submission Form in offline or postal in that case s/he will be given a tracking number for that particular complaint. By that track number s/he will have access to know the status of complaint through visiting the Project website at the GRS section.

If the grievance is not redressed within the expected time, the complainant should be provided with the following information from the Focal Point:
a. Information on reasons for delay
b. Updated expected time of redress
c. If not addressed within expected time, actions can be taken by the complainant. Again at the time of final redress, the complainant will be provided with the following information from the Grievance Redress Focal Point:
a. Action taken for redress b. If not satisfied with the redress action, avenues for pursuing the matter further A suggested flow chart for Grievance Redress Mechanism is given below:

Figure: 02 An overview of the GRM of EC4

8.0 Analysis and Prevention
A certain number of grievance complaints will be analyzed, why they are receiving particular types of grievances more frequently than others. Such grievance prone areas need to be identified and analyzed for bringing about necessary changes proactively. A Review Meeting will be held quarterly gathering certain number of complaints with a view to reevaluate the given decision. Member/s of the GRC can make sudden visit with randomly selected cases for on the spot checking and evaluating the resolved or redressed issues or any case that the complainant has dissatisfaction.

Furthermore, this project is also covered by the World Bank Grievance Redress Services, since it is financed by IDA. Therefore, communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to existing project-level grievance mechanisms or the WB’s Grievance Redress Services(GRS). For information on how to submit complaints to the World Bank’s corporate Grievance Redress Services (GRS) please visit http://www.worldbank.org/en/projects-operations/products-and-services/grievance-redress-services. For information on how to submit complaints to the World Bank Inspection Panel, please visit www.inspectionpanel.org

Finally, Grievance Redress Mechanisms (GRMs) are organizational systems. National government or Non-Governmental agencies develop this mechanism with adequate resources to receive and address concerns about the impact of their policies, programs and operations on external stakeholders. GRMs act as recourse for situations in which, despite proactive stakeholder engagement, some stakeholders have a concern about a project or program’s potential impacts on them. GRMs are intended to complement, not replace, formal legal channels for managing grievances. These mechanisms are not intended to replace the judiciary or other forms of legal recourse. This GRC also be recognized that not all complaints can be handled through a GRM. For instance, grievances that allege corruption, and/or major and systematic violations of rights are normally referred to administrative or judicial bodies for formal investigation, rather than to GRM for collaborative problem solving.

For convenient of the stakeholder’s available contact and options for communication and access to GRS are given below:

1. Land Phone: 0241030085
2. Website: www.ec4j.gov.bd
3. Email: grs@ec4j.gov.bd
4. PIU Address: 6th Floor, SEL Rose N Dale Building, House-116 Kazi Nazrul Islam Avenue, Dhaka-1000.