cez distribution bulgaria ad stakeholder engagement plan ... · 1 introduction 1.1. overview this...

CEZ DISTRIBUTION BULGARIA 1 JUNE 2017

CEZ DISTRIBUTION BULGARIA AD

Stakeholder Engagement Plan

2016-2019 Investment Program

Updated January 2018

Prepared for:

European Bank for Reconstruction and Development

One Exchange Square

London

EC2A 2JN


TABLE OF CONTENTS

CEZ DISTRIBUTION BULGARIA AD ................................................................................................ 1

1 INTRODUCTION......................................................................................................................... 3

2 PUBLIC CONSULTATION REQUIREMENTS AND STAKEHOLDER ENGAGEMENT TO

DATE .................................................................................................................................................. 7

3 IDENTIFIED STAKEHOLDERS AND COMMUNICATION RESPONSIBILITIES ..................... 9

4 STAKEHOLDER ENGAGEMENT PROGRAM ........................................................................ 12

5 GRIEVANCE MECHANISM ..................................................................................................... 18

Annex A: List of Stakeholders and Contact Details

Annex B: Public Grievance Form


1 INTRODUCTION

1.1. Overview

This Stakeholder Engagement Plan (SEP) provides the requirements and applied processes for

stakeholder engagement and public consultation, stakeholder identification and grievance

mechanism planned for CEZ Distribution 2016-2019 Investment Program in Western Bulgaria.

This document is intended for public disclosure and will be made available in Bulgarian

language by CEZ Distribution.

Please do not hesitate to contact us in case of any queries, comments or suggestions that you

may have in relation to this SEP or to company’s operation using below contact details. Thank

you.

regular mail or in person: CEZ Distribution, 159, Tsarigradsko shose Blvd., Sofia, 1784,

Bulgaria;

phone number: +359 700 10 010;

e-mail: [email protected];

webportal: www.cez-rp.bg.

In case specific projects included in the 2016 – 2019 Investment Programme are classified by

the environmental authorities as having potential significant impact on the environment, CEZ

Distribution will produce and disclose to the public the project level ESAPs, NTSs and SEPs.

1.2. Objectives of Stakeholder Engagement Plan (SEP)

The primary objective of the SEP is to map out the strategy for engaging the various stakeholder groups and public in CEZ Distribution’s activities related to the projects included in the 2016-2019 Investment Program. The SEP identifies and describes the key CEZ Distribution stakeholders, summarizes the process of how consultation will work, how feedback or comments will be taken into account and how any grievances will be handled.

1.3. Background of CEZ Distribution operations

CEZ Razpredelenie Bulgaria AD (“CEZ Distribution” or “the Company”) is part of CEZ Group in

Bulgaria (“the Group”), operating in the country starting 2005. CEZ Group comprises the

companies CEZ Bulgaria (the company coordinating CEZ Group’s activity in the country), CEZ

Distribution, CEZ Electro (power supply company) and CEZ Trade (energy trading company).

The Company is the successor of Electrorazpredelenie Stolichno AD, Electrorazpredelenie

Pleven AD and Electrorazpredelenie Sofia Oblast AD as result of a privatization process

finalised on 18 January 2008. Starting 29 January 2008 the name of the Company is CEZ

Razpredelenie Bulgaria AD (CEZ Distribution).

While the assignment relates to CEZ Distribution, references to CEZ Bulgaria are also included

in the present report given the relevant role of this company in providing management services

and support to all companies within the group including CEZ Distribution.

CEZ Bulgaria coordinates and provides management support and consultancy to the Group

companies ensuring a uniform approach to policies and strategies across the Group. Services

provided by CEZ Bulgaria to the Group companies include Communication and Public

Relations, Logistics, Procurement, Financial Services, Human Resources, Legal Support,

Information and Communications Technology, etc.

mailto:[email protected]


CEZ Distribution is a public company listed on the Sofia Stock Exchange. It is majority owned by

CEZ a.s. 67% while the remaining 33% of its stocks are in the hands of minor shareholders. The

company is the legal successor of Elektrorazpredelenie Stolichno.

CEZ Distribution owns all the power distribution assets of CEZ Group in Bulgaria after the 2007

unbundling of the Group’s electricity production and distribution activities in line with EU

requirements. The Company’s activities include operation, maintenance and development of

equipment for electricity distribution between power producers and consumers.

The Company operates the following main facilities:

29 km overhead High-Voltage (HV) (110 kV) transmission lines;

33 km underground HV (110 kV) transmission lines;

17,068 km overhead Medium Voltage (MV) transmission lines;

7,311 km underground MV transmission lines;

22,898 km overhead Low Voltage ( LV) transmission lines;

9,385 km underground LV transmission lines;

26 HV/MV substations;

15,929 MV/LV distribution stations;

19,200 MV/LV transformers;

2,108,145 installed electric meters.

To address the increased pressure for energy efficiency, the Company initiated a programme of

gradual implementation of new technology on the existing worn grid infrastructure. The 2016-

2019 Investment Programme subject to EBRD financing represents a continuation of this

currently ongoing modernization plan initiated in the previous years.

The 2016 -2019 Investment Programme comprises numerous projects including low and

medium voltage transmission lines (overhead and underground), underground high-voltage

transmission lines, substations upgrades, electrometers and switch changes, electrical

switchboards overhaul, relocation of electrical switchboards, equipment investments, buildings

repairing/ maintenance, implementation of environmental measures, connection of new

consumers to the network. The investment programme does not include any projects related to

above-ground high voltage (110 kV) transmission lines.

CEZ Distribution has the obligation to acquire part of the facilities it operates, in the

frame of a mandatory buyout. This buyout is considered as part of 2016-2019

Investment Programme. While the cost associated with the Investment Programme

(including the mandatory buyouts) was incorporated into the household energy

distribution tariff, this did not result in a significant affordability impact.

1.4. General Social Context

CEZ Distribution is headquartered in Sofia and provides power supply in ten regions in Western

Bulgaria: Sofia City, Sofia District, Pernik, Kyustendil, Blagoevgrad, Pleven, Lovech, Vratsa,

Montana and Vidin regions.


Those ten regions cover an area of about 39,084 km

2 and have an overall population of more

than 2 million inhabitants living in 1,560 villages and towns including the Bulgarian capital Sofia. CEZ Distribution Bulgaria employs 2,611 staff (February 2016 data), of which 21% are women.

2605 persons are full-time employees while 6 are working part time.

Wage levels in the Company are determined by the specific requirements and responsibilities

for the position and are not in correlation with the gender of employee. The average wages

within CEZ Distribution are higher than the medium salary in Bulgaria (of approximately EUR

450 /month) and at the same level with average salaries within the sector.

CEZ is a socially responsible company that works actively and openly with local and central

authorities, experts, consumer organizations, key opinion leaders and is deeply involved in

communities’ social programs within all the ten regions. The company’s CSR activities include

environment protection, rehabilitation of kindergartens, schools, children’s playgrounds and

parks, support for local communities, support for projects for improving of urban environment,

volunteer labour, donations, sponsorship for sport competitions, exhibitions, and other

sponsorship activities.

CEZ Distribution Bulgaria ranks among the 5% of all companies in the World, following the

Investors in People standards for people management. (https://www.investorsinpeople.com/).

Moreover, it is the first company in Bulgaria accredited on June 6, 2014 with Investors in People

Bronze award (bronze medal).


The Company operates under the following principles of external communication:

Strict compliance with legal and regulatory provisions

Transparency

Publicity of the information concerning CEZ activities in Bulgaria

Active dialogue with all stakeholders

Clear, concise and timely communication

The Company operates under the following principles of internal communication:

Every CEZ employee has two roles – a client of internal communication and a source of external communication. Effective internal communication will bring long-term reputation benefits to CEZ group of companies in Bulgaria;

CEZ management should ensure that employees understand and share the company mission, vision and will work for its goals;

At each stage of the communication it should be clear – what is the problem, how it will be resolved and who is responsible;

The responsibilities in the internal communication require different expertise and thus a clear terms should be drawn to allow the PR and HR department to collaborate effectively for the best results;

Effective communication channels and messages are crucial for the staining of trust between CEZ management and employees.


2. PUBLIC CONSULTATION REQUIREMENTS AND STAKEHOLDER ENGAGEMENT TO

DATE

2.1. Bulgarian legal requirements for public consultation

The Bulgarian legislation states that the public should be informed about the projects which

have a potential significant impact on environment, to have the opportunity to comment on the

information provided to it during the development/discussion of the project. Such projects are

subject to the full procedures for Environmental Impact Assessment (EIA) and the related public

consultation procedures.

The EIA process in the Republic of Bulgaria is controlled at the national level by Chapter 6 of

the Environmental Protection Act (EPA) and Ordinance on the conditions and order for carrying

out an EIA. These above legislative documents are transposing the EU EIA Directive

(85/337/EEC, amended and supplemented with Directive 97/11/EC, Directive 2003/35/EC, and

Directive 2009/31/EC - collectively codified by Directive 2011/92/EU and Directive 2014/52/EU).

Projects subject to mandatory EIA procedure are listed in Annex 1 of the EPA, while projects

listed in Annex 2 of the EPA are subject to EIA screening (i.e. authorities judge whether the

specific project has to pass an EIA procedure or not). According Annex 1 of the EPA, only

overhead power lines with voltage equal or exceeding 220 kV and with length equal or

exceeding 15 km are subject to obligatory EIA procedure. The investment programme of CEZ

Distribution does not include such projects and the Company confirmed that they have never

had such projects.

In any case, Bulgarian legislation requires the project developer to officially notify the

municipalities and Regional Environment and Water Inspectorates on the territories of which the

project will be developed.

Generally, the main organisational form of determining the public opinion is public hearings.

Public hearings are organized by the project developer, are announced in newspapers in local

languages with 30 days in advance and announce availability of the EIA Report, the modalities

to review the documents and submit the comments and the details on public hearing (location,

date, hour etc.).

Participants of public hearings include interested public, public and non-governmental

organisations and associations, local executive and representative bodies, governmental bodies

authorised to make relevant decisions, mass media. During the hearings, any participant has

the right to express his or her opinion, address questions related to the project. The results of

public hearings shall be recorded in the Minutes of Public hearing which will be attached to the

permitting documentation and considered by authorities in the process of decision making.

In addition to the public hearings, various public announcements should be posted at

appropriate locations like the company website, on Regional Environment and Water

Inspectorate website, website of the municipality, announcements board at the municipal

building or in newspapers.

2.2. Stakeholder actions undertaken to date by CEZ Distribution

All of the 2016-2019 Investment Programme’s projects developed by CEZ Distribution to date

were considered by the environmental authorities to not pose a potential significant impact on

the environment. Hence, the projects are subject only to short EIA procedures for which public

hearings are not required. The projects were disclosed to the public mainly through public

announcements in media and announcements board at the mayoralty.


To date and in relation to the projects part of the 2016-2019 Investment Program, CEZ did not

receive any officials comments related to environmental or social issues as a result of such

announcements.

Data on scheduled maintenance activities, extension of networks, rehabilitation of facilities etc.

are regularly announced by the company using personal meetings, letters, publications in

printed media, radio, TV or other available channels.


3. IDENTIFIED STAKEHOLDERS AND COMMUNICATION RESPONSIBILITIES

Stakeholder engagement is coordinated at Group level by the Public Relations and Customer

Care Departments of CEZ Bulgaria.

External stakeholders for the 2016-2019 Investment Programme were identified in line with CEZ

Bulgaria Communication Strategy and the communication plans. They were mapped among

groups and individuals that will potentially be impacted by or can have influence on the

investment programme.

Company’s stakeholder groups as identified by CEZ Bulgaria include:

1. State institutions, administrative bodies, Energy regulator, National ombudsman, local

and regional authorities;

2. Land users and local communities

3. General Public / NGOs / independent experts, opinion leaders;

Group of Stakeholders Stakeholders

1. State institutions,

administrative bodies and local

authorities

- National /central authorities (e.g: Government,

Ministry of Energy, Ministry of Economy, Ministry of

Environment and Waters, Ministry of Interior, relevant

Parliamentary committees, state Energy Regulator

(KEVR), National Ombudsman, Commission for

protection of competition, Commission for protection

of consumers, etc)

- Local authorities (e.g: Mayors, Municipal Councils,

District Governors, Regional Environment and Water

Inspectorates etc.)

2. Land users and population of

the villages;

- Villages and localities inhabitants impacted by

implementation of the 2016-2019 Investment Program

3. General Public, independent

experts, opinion leaders;

- Energy and economy experts;

- Local opinion leaders;

- General public;

4. Media - National media – newspapers, TV, radio, websites;

- Local media;

- Social media;

5. Clients, Consumer

Organizations

- Households (including people having issues with

paying the bills);

- business clients;

- Consumer organizations;

- Civic organizations;

6. Business Organizations - Business organizations and associations;

- Branch organizations;

7. Internal Stakeholders

- Company staff ;

- Contractors and contractors’ staff;


4. Media;

5. Clients and Consumer organizations (including people having issues with paying the

bills);

6. Business/ branch organizations;

7. Internal Stakeholders (employees, contractors, major equipment suppliers);

8. Other companies within the CEZ Group;

9. Vulnerable people.

Dear Reader/Stakeholder:

If you are not included on the below stakeholder list and wish to receive information about the

2016-2019 Investment Programme, please contact our company by using the contact details

specified in Section 1 of this SEP.

The main stakeholders identified so far are detailed in Table 3.1. below. The list will be updated

and modified in the course of the 2016 Investment Programme development to reflect any

changes in the investment programme’s stakeholders (e.g. add new stakeholders).

Table 3-1 Identified Groups of stakeholders

Under point 5 above: A particular interest is for the people with issues in paying the electricity

bills, mainly located in Botevgrad, Dupnitsa, Ihtiman and Samakov. In those localities, installing

the electricity meters at up to 7 meters height was considered in the past a standard safety

measure of CEZ Distribution even before the privatization and, in the Company’s view, was

aimed to reducing the thefts of electricity in risky regions thus lowering the losses of the

Company and preventing unfortunate incidents endangering human life and health.

Currently, dealing with this issue is part of the long-term communication policy on the CEZ

Distribution. Recently, a strategic management decision was adopted to find technical solutions

in risky regions in order to reduce theft without the need to install electricity meters at height.

In addition, the Company, with the support of local non-governmental organizations performs

periodic training to the relevant community leaders (including, but not limited to Roma people)

on the best practice to reduce the bills and to save electricity.

Under point 9 above: To date, the Company has not initiated any official identification of the

stakeholders under the “vulnerable people” group.

A recent definition was released by the Ministry of Energy in May 2016. According to this

definition, “Vulnerable customers are households whose members are persons who because of

their age, health or income are at risk of social exclusion in relation to the supply and

consumption of electricity and who are benefiting from measures of social protection to ensure

their necessary electricity supplies”.

- Major equipment suppliers;

8. Other companies within the

CEZ Group

-CEZ Bulgaria;

- CEZ Electro; - CEZ Trade Bulgaria;

9. Vulnerable people - to be determined


CEZ expects also the results of a World Bank Report prepared at the request of the Bulgarian

Government for the Energy sector, aiming to implement a new support mechanism for

vulnerable customers with significantly expanded scope.

These definitions will be further considered by the Company in development and

implementation of the plans and strategies.

In Bulgaria, the last statistics on vulnerable people were produced 2007. In general, under the

vulnerable people group are pensioners, families with many children, low income families,

Roma people, unemployed people, widows, orphans, people with disabilities and chronical

diseases etc.

During the last years, the government analysed various proposals for providing support to

vulnerable people for paying the electricity bills, with allocations varying on consumption and

income. However, to date, none of the proposals was selected and implemented by the state

authorities.

CEZ’s companies in Bulgaria have implemented measures to alleviate all the clients regardless

of their age, income or social group. These measures include various options for rescheduling

of financial obligations towards CEZ. In order to benefit of these measures, the clients have to

contact CEZ’s centers and submit an application form.

Although the current bills for electricity are below the ones in 2013 and salaries increased (e.g.

minimum salary from 158 EUR/month in 2013 to 215 EUR/month in June 2016), the affordability

for the consumers is still an issue to be carefully handled by the Bulgarian state and by all the

distribution companies.

CEZ Distribution does also not expect significant impact of their 2016-2019 Investment Program

on the total price of energy distribution to be applied in the following regulatory period.

Information disclosure

CEZ companies have a long-term communication program about investments in the grid which

include regular press-releases (on monthly basis), publications of price proposals during their

submission to the Energy and Water Regulatory Committee, publication of the new prices when

they are adopted, interviews with CEZ representatives and 3rd

parties.

Main messages:

CEZ is a socially responsible company that has always strictly adhered to the legal and regulatory provisions in execution of its basic commitments to clients and society.

We are always ready to provide journalists and citizens the needed information related to CEZ's activities in Bulgaria.

CEZ is a transparent and open company. The opportunities for contacts with us are publicly available

Keeping open and direct communication helps us to achieve our strategic goal of delivering reliable power and modern home and business services according to the European standards.

Each investment project aims to improve service quality and expand the number of services we offer.

CEZ is investing each lev it receives on the Bulgarian market in the grid.

The client is in the focus of the activities of CEZ in Bulgaria.


4. STAKEHOLDER ENGAGEMENT PROGRAM

The Company has identified specific project information that is to be disclosed to the majority of the

stakeholders groups, as well as the proper means of communication with each of them.

The analysis of these groups has been performed by the Company based on specific criteria and

resulted in defining the engagement actions to be performed through different specific approaches

including newsletters, periodical updates, newspaper articles, announcements on community boards,

brochures, meetings etc.

The Company has developed the following procedures for establishing clear internal and external

communication:

At the beginning of each year regular meetings of top management of CEZ Distribution with local authorities take place. They are organized with the active cooperation of the regional and municipal organizations in the ten regional centers of the area serviced by CEZ. During the meetings, the participant discuss the company's investment plans and other issues of interest for the local population.Usually these meetings are attended by CEZ Distribution CEO, COO, Regional Asset Manager and the Director of Customer Service. Meetings with local authotities are an important communication channel for CEZ

In addition, regular meetings and consultations are held between the representatives of municipalities and CEZ Distribution’s Regional asset managers.

Several mobile offices are organized in different villages in Western Bulgaria every year – tipically where there is no customer service center of CEZ or in a case of emergency. The goal is faster and more effective communication and better customer service.

In order to improve customer services CEZ has created two unique for Bulgaria bodies: Consumer Council and Energy Ombudsman. The Consumer Council is an advisory body with the participation of CEZ experts as well as external experts and consumer organizations. It has 12 members.The Council holds several meetings yearly in order to analyze existing business practices of CEZ in Bulgaria and recommend their improvement. The Energy Ombudsman has a team of two people. It examines hundreds of alerts every year and makes suggestions for changes in order to optimize business practices and achieve greater customer satisfaction. In addition, the Energy Ombudsman regularly organizes mobile offices during which he meets clients who are unable to arrive to visit him in the head-quarter. The two organizations have their own channels for communication with clients and stakeholders, which are available on the CEZ Distribution website (www.chez-rp.bg).

For each stakeholder group the anticipated information disclosure needs and means of communication

are summarised in the table 4-1 below.

http://www.chez-rp.bg/

http://www.chez-rp.bg/


Information Disclosed or

Engagement Actions

Form(s) of communication Location and

Dates

Target Stakeholders Responsibilities

EIAs outcomes and mitigation

measures considered, in line with

national regulations, only in case

projects within the 2016-2019

Investment Program require EIAs

or AAs (Appropriate Assessments)

Public hearings

Posters, public announcements at local offices of CEZ Distribution and on CEZ Distribution website, according with the requirements of the national regulations.

Community

center the

relevant villages

Local population;

Administrative Bodies

and Authorities

Landowners/farmers in

the project area that may

be directly impacted;

General Public / NGOs /

Independent experts

Mass media

CEZ Distribution in

collaboration with

Environmental

regulatory authority

and EIA/AA

producer

Non-technical summary (NTS)

Environmental and Social Action

Plan (ESAP), Stakeholder

Engagement Plan (SEP),

Grievance Mechanism (*High

level or for each project with

significant impact on local

population and/or environment)

Upload on company website at

http://www.cez-rp.bg

http://www.cez-

rp.bg/en/contacts/map/

In printed/hard copy form at CEZ

Distribution Customer Services

centres (location and schedule here:

http://www.cez-

rp.bg/en/contacts/map/)

Initial

disclosure:

2016

Updated

versions: as

needed, on on-

going and

project basis

General Public and Local

population;

CEZ Distribution

Specific Projects information prior starting any rehabilitation/construction works (leaflets, posters) relevant for local public, in line with national regulations.

Information panels in affected villages for each of the Project in the Investment Programme with significant impact on local population and/or environment, information disclosed on company website, according with the requirements of the national regulations Meetings with local authorities or

Information

panels

Disclosed

information

updated as

needed on on-

going basis

Local population

Landowners /farmers in

the projects area

CEZ Distribution

and its

construction

contractors

http://www.cez-rp.bg/

http://www.cez-rp.bg/en/contacts/map/






Engagement Actions


Dates


their representatives

Individual meetings with clients

Letters

Announcements

Leaflets and trainings on energy

savings for reducing the electricity

bills and on risks of unauthorized

electrical works on human health

Communication with local

communities with issues in paying

electricity bills (including but not

limited to roma people) through

different organizations /NGOs or as

suggested by the local

administration

Individual meetings with clients

(roadshow of the Energy

Ombudsman, mobile offices)

Meetings with local authorities and

key opinion leaders

Ongoing

basis/as

needed/feasible

People with issues in

paying bills

CEZ Distribution

with support from

local NGOs and

local authorities

Providing the local population

(clients) (especially in areas with

vulnerable people) with

information and guideline on main

investment projects, tips for

energy savings in order to reduce

the electricity bills and

state/company support, if

applicable



Meetings with local authorities or

their representatives

In printed/hard copy form at CEZ

Distribution Customer Services

centers (location and schedule here:

http://www.cez-

rp.bg/en/contacts/map/

Ongoing basis Vulnerable / low income

people

CEZ Distribution

with support of

local

authorities/mayoral

ties






Engagement Actions


Dates


Media articles and intevires

Press-releases

Antitheft of electricity and

equipment measures (e.g.

investments in grid to reduce

losses and ensure quality of

supply; protection of human life;

equitability principles in paying the

bills for real consumption)

Media publications: articles (press-

releases), interviews; articles by

opinion-makers; reports in main and

local media;

Media workshops / letters/ meetings

with institutions and local

authorities

Press-releases



and facebook

Ongoing basis/as

needed/feasible

Clients; State Institutions;

Local authorities; Media;

Parliament; Regulators;

Opinion leaders; Other

utility companies

CEZ Distribution

Liberalization of the market for LV

end-users. Message: CEZ

Distribution remains the operator

of the grid regardless of choice of

end-suppliers. The tariffs of grid

services continue to be regulated.

CEZ has the necessary know-how

to operate on an open market with

all participants on it.




local media;


with: institutions and local

authorities

Press-releases



and facebook

Ongoing basis/as

needed/feasible

Clients: households and

business on LV;

State institutions;

Local authorities;

Opinion leaders;

Experts;

CEZ Distribution

Improvement in quality of energy

supply. Message: We are

investing every lev in the grid to

ensure quality. We are a hard-

working, professional and




local media;

Ongoing basis/as

needed/feasible

Clients; State institutions;


State Regulator; Opinion

leaders; Business and

Branch organizations;

CEZ Distribution





Engagement Actions


Dates


customer oriented company. We

are open and transparent. We are

improving each segment of our

work processes in order to serve

customers better


with institutions and local authorities



and facebook

Customer organizations

Disruptions by excavation works.

Message: We are a responsible

company abiding to the laws. We

are calling the rules to be

respected in order to minimize the

inconvenience for our clients. We

are a trustful partner in providing

service to the population.




local media;

Meetings with branch organizations



and facebook

Ongoing basis/as

needed/feasible

Clients; Media;

Regulator;

Ministry of Energy;

Ministry of Construction;

Construction Chamber;

Opinion leaders;

Construction companies

CEZ Distribution

Preparation for the winter season.

Message: We conduct a voluntary

inspection of power equipment to

prepare it for the increased

consumption during the winter

season. We invest a maximum

within our resources to replace or

prepare equipment

Media publications: articles,

interviews; news reports in main and

local media;

Exclusive TV Report; News

conference, media workshop,



and facebook

Yearly, on Q3 Clients; Institutions;


State Regulator; Opinion

leaders; Consumer

organizations

CEZ Distribution

Simplification of procedure for

connecting new clients to the grid.

Message: We are a hard-working,

professional and customer

oriented company.

We are improving each segment

of our work processes in order to

serve customers better.

Media publications: articles,

interviews; news reports in central

and regional media;

Meetings with local authorities

Meetings with branch organizations



and facebook.

Ongoing basis/as

needed/feasible

Clients: business and

domestic;

Institutions; Regulator;

Construction Chamber;

Construction

companies;

Business and Consumer

organizations

CEZ Distribution







Engagement Actions


Dates


Buyouts of facilities built by 3rd

parties

Direct communication

Interviews and articles

Press-releases

Regular meetings with local

authorities

Ongoing-basis Investors and

construction companies

CEZ Distribution

*High level ESAP, NTS and SEP refers to current documents produced by ERM as part of the 2016 ESDD for the 2016-2019 Investment Program.

Similar with these general documents, CEZ Distribution will produce ESAPs, NTSs and SEPs for each of the major (with impact on socio-

economic and environment) project in the 2016-2019 Investment Program.


5. GRIEVANCE MECHANISM

Reporting Grievances

CEZ Distribution has implemented an Internal Grievance Procedure (called Directive

No.78/2011) allowing for appropriate stakeholder grievance management. The Directive

addresses the process of receiving, recording, investigation, resolution, reporting and

response to grievances and is interconnected with other specific procedures implemented at

the Company.

A grievance is an actual or perceived problem or other issue related to a project of the

investment programme that might give grounds for complaint by a member of the public or

other stakeholders. As a general policy, the Company will work pro-actively towards the

prevention of grievances through the implementation of impact mitigation measures and

community liaison activities that enable CEZ Distribution to anticipate and address potential

issues before they become grievances

Nevertheless, should grievances emerge, the Company is committed to addressing these in a

timely and effective manner in accordance with the national legislation, international best

practice and the Company's Internal Grievance Procedure.

A Public Grievance Form (provided in Annex B) should be completed by anyone wishing to

lodge a grievance in written form. The form comprises fields for (i) the name and contact

details of the person lodging the grievance (for the purposes of enabling communication on

grievance process and its resolution) including preferred means of communication, (ii)

description of the grievance/incident, (iii) the date when the grievance/incident occurred, (iv)

grievance resolution outcome expected by the person lodging the grievance, (v) grievance

categorization and (vi) indication on the expected resolution time as per the Company

procedure.

This Form is to be made available in Bulgarian language at Company’s Customer Services

Centres in all the ten regions in Western Bulgaria and on the website.

All grievances submitted to the Clients Servicing Centres have to comply with the following

requirements:

To be written in Bulgarian;

To include the name and address of the person lodging the grievance;

To be signed by the person lodging the grievance;

To include clear description of the grievance/request;

To include details on the specific case as well as evidences if available;

Place of electricity consumption if the grievance is related to a specific object of electricity consumption.

Grievances that do not comply with the above requirements are also accepted and registered

(e.g. anonymous), but their resolution may take longer time. In case a grievance includes a

phone number as contact details, the CEZ employees will call and request additional details

on the case in order to clarify the circumstances described in the grievance.

All grievances are registered in the Clients Information System (CIS) - SAP business

operations and customer relations software system - and receive unique reference numbers.

Responsibilities are defined for each process stage.


In case the grievance is submitted in other format, the CEZ employee receiving the appeal will

fill in all the data in the designated Grievance form and will assure its registration in the CEZ

grievance system CIS.

The Grievance Procedure will be advertised on company website at http://www.cez-rp.bg and

on printed / hard copy forms at CEZ Distribution Customer Services Centres.

How to Register a Grievance?

There are several ways that a grievance will be able to be registered:

By sending a completed Grievance Form to our headquarter at 159 Tsarigradsko Shose Blvd. Sofia 1784;

By sending a completed Grievance Form to one of our offices: (Addresses and schedule here: http://www.cez-rp.bg/en/contacts/map);

By sending an email to the following address: [email protected]; [email protected]; [email protected]

By calling our company at: 0700 10 010 (hotline) or by sending a fax to (02) 8959 667;

In addition to the above mentioned requirements, the grievances submitted to the dedicated

email address ([email protected]) should include information on the preferred means of

communication.

Confidentiality

Some grievances may be raised in confidence under this procedure. Grievances will not be

disclosed without the consent of the stakeholder.

Grievance Procedure

CEZ Distribution handles grievances received in line with the Directive No.78/2011

implemented at the Company. Directive No.78/2011 includes a separate section related to

grievances received from governmental institutions.

The procedure addresses the process of receiving, recording, investigation, resolution,

reporting and response to grievances received and is interconnected with other specific

procedures implemented at the Company. Responsibilities are appropriately defined for each

process stage. The procedure also provides for continuous improvement based on feedback

from all involved in handling the grievance process.

The current Grievance Procedure is very general and mainly customers oriented. This is to be

revised to specify that covers also environmental, social, land use, biodiversity, cultural

heritage and other non-customers related topics and situations.

Four process streams are defined for handling the grievances, pending on how the grievance

is received: (i) by email or by fax, (ii) by regular mail or in person/verbal, (iii) through the call

centre/hotline or (iv) through the client relations centre.

In all cases, once received, a grievance is registered, managed and tracked using the SAP

business operations (Clients Information System (CIS) used and operated by the Company.

Along with the filling in of the relevant information in the CIS, the responsible

department/person for the specific grievance is defined. The grievance is then forwarded to

that department/authorized person for resolution which will distribute it to appropriate

responsible. Employees of Customer Service Department are in charge with the monitoring of

the process of answering the grievance and the deadline to communicate the resolution to the


http://www.cez-rp.bg/en/contacts/map)






appellant. Once the person in charge with solving the grievance prepares the answer, this is

forwarded to the authorized his immediate superior manager for review and

approval/signature. Based on the approved statement, the employees of Customer Service

Department prepare an answer to the person lodging the grievance. There are additional

steps in the grievance resolving process for the cases when there are clients’ claims for

compensations for damages, complaints related to poor quality of the supplied electricity or in

other cases on higher difficulty.

The term for answering to the written grievance is of 21 days, with the exception of the

grievances received from authorities when the deadlines are shorter (2 to 7 days, depending

on applicable legislation).

Recording Phase Resolution Phase Monitoring Phase

Grievance

recording

and

allocation

Classification Analysis and

resolution

Response to

grievance

Reporting and

evaluation

Grievance

receipt

(through five

possible

streams

Grievance

allocation to

the relevant

grievance

administrator

and

recording in

SAP system

Grievance

classification

by grievance

administrator

Assignment

of resolution

deadline (with

consideration

of legal

requirements

when

applicable)

Grievance

allocation to

relevant

employee or

Company

department

for analysis

and

resolution

Grievance

analysis and

resolution

Preparation

and

provision of

response to

grievant

Grievance

closure

Periodic monitoring

based on key

performance indicators

(KPI) when applicable,

reporting, continue

process improvement

In period 2010-2016, there were 60,900 grievances registered by the Company, focused

almost exclusively on the issues directly connected to distribution of the electricity (meters

functioning, damages to the powerlines, quality of electricity, licenses, quality of services, theft

of electricity, facilities for purchase electricity, overcharged recuperation, invoicing etc). There

was no information available whether any of those grievances was also sent to court of justice

for resolution.

Workers’ Grievances

The grievance mechanisms regarding working conditions and attitude of employees are in

compliance to current legislation in Republic of Bulgaria (Labor Code, Law for protection of

discrimination, labour safety conditions regulations, etc.) and internal rules and procedures.

The steps in the formal process are the following:

submission of the complaint to HR department, leadership of the company, to the line manager and the Ethic hotline on CEZ Distribution website (section Contacts)


Assignment of an independent Commission for Investigation of the complaint;

Review of the complaint and its grounds and priority;

Meetings, evidence collection, interviews with involved employees (including employee who has submitted the complaint)

Preparation and submittal of the proposed resolution to the management board of the Company with final conclusions and opinion of the Commission for Investigation.

Feedback to the employee who has submitted the complaint.

Taking follow-up measures (if applicable)

If preferred by the complainant /if considered more feasible / in case of sensitive issues, it is

also an option to address the grievances by having informal discussion and escalation of

working issues with the line manager and HR department. In addition, three psychologists

were recently hired by CEZ as part of the newly opened unit Internal Assessment Centre. The

scope of this unit is evaluation and development of the managerial positions and employees.

Although their role is mainly related to organizational psychology as opposed to addressing

conflicts, in sensitive cases, the psychologists may also provide support and expertise upon

need.

The period of time for providing a resolution depends on its complexity, but will be done in a

reasonable period of time (in case no detailed investigations are needed, up to 30 days).

In 2015 there were four written grievances registered by the CEZ employees. These refer to

complaints on the line managers, bonuses system, discrimination and sexual harassment and

all were solved internally, without escalating the case to the court and without any complains

or risks on violation of the human rights.


Annex A

Stakeholder List and Contact Details


Name Contact details Responsibility / Involvement

in the project/project area (if

applicable)

State institutions, administrative bodies, regulator, national ombudsman, local and

regional authorities

KEVR Sofia 1000, 8-10

Dondukov Blvd.

Ministry of Energy Sofia, 8 Triaditsa Str

Parliamentary

committees

Sofia, 1 Knyaz

Alexander I Square

National Ombudsman Sofia 1202, 22 George

W. Street

Commission for

protection of

competition

Sofia 1000, 18 Vitosha

Blvd

Commission for

protection of

consumers

Sofia 1000, Slaveykov

Square 4 A

Governor of Sofia-town Sofia 1000, Alabin 22

Governor of Sofia

Governor of Pleven 1 Vazrazhdane Square,

fl. 4, Pleven 5800

Governor of Lovech 43 Targovska Str.,

Lovech 5500

Governor of Vidin 6 Dunavska str., Town

of Vidin 3700

Governor of Montana Jeravitsa Square,

Montana 3400

Governor of Vratsa 1 Demokratsia Blvd.,

Vratsa 3000

Governor of Kustendil Kyustendil 2500, 44

Demokratsiya Street,

Governor of

Blagoevgrad

Georgi. Izmirliev

Square 9, Blagoevgrad

2700

Governor of Pernik Pernik 2300, 1B Ivan

Rilski Str

Independent experts/opinion leaders /NGOs


Institute for Energy

Management

Sofia, 1000, Lege 5,

floor 1

Bulgarian Energy and

Mining Forum

1000 Sofia,Bulgaria

4 Trapezitsa Str., 4-th

floor

Media

Newspaper Group

Bulgaria

Sofia 1124,

Tsarigradsko Shose 47

Newspaper Stroitel Mladost, 6, Mihail

Tenev Str., Sofia 1784

Consumer Organizations

Federation of

consumers

Sofia 1303, 35

Sanchefano Stambolov

Str

National Association

Active Consumers

Sofia 1000, 26 Vrabcha

Str

Independent Union of

consumers

Sofia 1000, Klokotnitsa

Str. 33-35 B

Business / Branch Organizations

Association of Industrial

Capital in Bulgaria

1527 Sofia, 15 Trakia

Street, floor

Bulgarian Construction

Chamber

Mladost, 6, Mihail

Tenev Str., Sofia 1784

Confederation of

employers and

industrialists in Bulgaria

Sofia 1463, 8 Khan

Asparuh Str

Bulgarian Industrial

Association

1000 Sofia, 16-20,

Alabin Str.

Bulgarian federation of

the industrial energy

consumers

Sofia 1700, 1

Universitetski park Str.

[email protected]

Other companies within the CEZ Group

CEZ Electro Bulgaria Sofia 1784,

Tsarigradsko Shose

159

CEZ Trade Sofia 1000, Pozitano

Square 2A


Annex B

Public Grievance Form


PUBLIC GRIEVANCE FORM

Reference No:

Full Name

Contact Information

Please mark how you wish to

be contacted (mail, telephone,

e-mail).

By Post: Please provide mailing address: ______________________________________________________________________________________________________________________________________________________________________________

By Telephone: _______________________________________________

By E-mail _______________________________________________

Preferred Language for

communication Bulgarian

Other, please specify: ___________________

Description of Incident or Grievance: What happened? Where did it happen? Who did it happen to?

What is the result of the problem?

Date of Incident/Grievance

One time incident/grievance (date _______________)

Happened more than once (how many times? _____)

On-going (currently experiencing problem)

What would you like to see happen to resolve the problem?

Signature: _______________________________

Date: ______________________________

Please return this form to: Customer Service Department

We will register your complaint and provide an answer within up to 21 calendar days.

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