public disclosure authorized harmonized...

HARMONIZED GRIEVANCE REDRESS MECHANISM

Managing Road Construction Grievances

JUNE, 2019

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Uganda National Roads AuthorityPlot 3-5 New Port Bell Road,UAP Nakawa Business Park Block C & DP. O. Box 28487Kampala, Uganda

IV V


HoD Head of Department

IEC Information, Education and Communication

IFI International Finance Institution

LC Local Council

LO LandOfficer

M&E Monitoring and Evaluation

MDA Ministry, Department and Agency

MOFPED Ministry of Finance, Planning and Economic Development

MoWT Ministry of Works and Transport

NEMA National Environment Management Authority

NFA National Forestry Authority

NGO Non-governmental Organization

PAPs Project Affected Persons

PCA Public and Corporate Affairs

PMF Programme Management Framework

PMT Project Management Team

RAP Resettlement Action Plan

RBD Roads and Bridges Development

RBIP Roads and Bridges Infrastructure Protection

RDC Resident District Commissioner

RE Resident Engineer

RM Roads Maintenance

SMS Short Message Sending

TMT Top Management Team

TOR Terms of Reference

UNRA Uganda National Roads Authority

ACRONYMS

AIDS AcquiredImmuneDeficiencySyndrome

CAO ChiefAdministrativeOfficer

CBO Community-Based Organization

CCC Contact Care Centre

CCO ClientCareOfficer

CCP Contact Care Personnel

CDO CommunityDevelopmentOfficer

CESP Citizen Engagement Strategy and Plan

C-GMC Community Grievance Management Committee

DAO DistrictAgriculturalOfficer

DESS Department Environmental and Social Safeguards

S-GMC Sub-county Grievance Management Committee

D-GMC District Grievance Management Committee

DLB District Land Board

DLO DistrictLandOfficer

DPC District Police Commander

DS District Surveyor

ED Executive Director

EO EnvironmentOfficer

ESIAs Environmental and Social Impact Assessments

FAQs Frequently Asked Questions

GISO GombololaInternalSecurityOfficer

GMC Grievance Management Committee

GOU Government of Uganda

GRM Grievance Redress Mechanism

HESS Head, Environmental and Social Safeguards

HIV HumanImmuneDeficiencyVirus

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3.1.2 Grievance Management Committees .............................................................................................................................................................................. 22

3.2 Project Level Grievance Management ........................................................................................................................................................................................ 23

3.2.1 Objective of having Project Level GRM ........................................................................................................................................................................ 23

3.2.2 Project Level GRM .............................................................................................................................................................................................................................. 23

3.3 National Level GRM .......................................................................................................................................................................................................................................... 25

4.0 MONITORING, EVALUATION, REPORTING AND COMMUNICATING ON GRM ....................................................................... 28

4.1 GRM Database ....................................................................................................................................................................................................................................................... 28

4.2 Internal and External Monitoring ...................................................................................................................................................................................................... 29

4.3 Reporting ..................................................................................................................................................................................................................................................................... 29

4.4 Communicating the GRM .......................................................................................................................................................................................................................... 30

REFERENCES ........................................................................................................................................................................................................................................................... 31

ANNEXES ..................................................................................................................................................................................................................................................................... 32

LIST OF FIGURES

Figure 1: Schematic Representation of UNRA’s Grievance Redress Mechanism ................................................................................. 11

Figure 2: Schematic Representation of the Grievance Handling Process .................................................................................................... 18

Figure 3: Flow of grievances from communities to CCO at Community level .......................................................................................... 21

Figure 4: Flow of grievances to the Resident Engineer from both communities and CCO ....................................................... 24

Figure 5: Flow of grievances to and from the Central Grievance Data Base ............................................................................................. 26

LIST OF TABLES

Table 1: Examples of Complaints that fall in different categories .......................................................................................................................... 16

Table 2: Ranking of a Grievance ................................................................................................................................................................................................................... 16

LIST OF ANNEXES

Annex 1: Categories of Common Complaints Received by UNRA ......................................................................................................................... 32

Annex 2: Land Acquisition Checklist ...................................................................................................................................................................................................... 36

Annex 3: Response Time in working days ........................................................................................................................................................................................ 37

Annex 4: Roles of different actors in Harmonized GRM ................................................................................................................................................... 39

CONTENTS

ACRONYMS ............................................................................................................................................................................................................................................................................ IV

1 INTRODUCTION ........................................................................................................................................................................................................................................................... 2

1.1 Overview of UNRA’s Mandate .................................................................................................................................................................................................................... 2

1.1.1 The Vision ................................................................................................................................................................................................................................................ 2

1.1.2 Mission ........................................................................................................................................................................................................................................................ 2

1.1.3 Core Values ............................................................................................................................................................................................................................................ 2

1.2 Strategic Objectives ............................................................................................................................................................................................................................................ 2

1.3 Rationale for the harmonized GRM .................................................................................................................................................................................................... 3

1.4 Purpose of the GRM ............................................................................................................................................................................................................................................ 4

1.4.1 SpecificObjectives .................................................................................................................................................................................................................................. 4

1.5 Categories of stakeholders who may submit grievances ......................................................................................................................................... 5

2.0 OVERVIEW OF UNRA’S HARMONIZED GRIEVANCE REDRESS MECHANISM ........................................................................... 8

2.1 Grievances ..................................................................................................................................................................................................................................................................... 8

2.2 Types of Grievances ........................................................................................................................................................................................................................................... 9

2.2.1 Engineering Related Grievances .............................................................................................................................................................................................. 9

2.2.2 Survey Related Grievances ........................................................................................................................................................................................................... 9

2.2.3 Environmental Grievances ............................................................................................................................................................................................................ 9

2.2.4 Social Grievances .................................................................................................................................................................................................................................... 9

2.2.5 Resettlement, Land Acquisition and Compensation Related Grievances ............................................................................... 9

2.3 Grievances Handling ....................................................................................................................................................................................................................................... 10

2.3.1 Responsibilities for Handling Grievances .................................................................................................................................................................. 10

2.3.2 Gender Responsiveness in Grievances Management ................................................................................................................................. 12

2.4 Grievances Management ........................................................................................................................................................................................................................... 12

2.4.1 Receiving Grievances ....................................................................................................................................................................................................................... 13

2.4.2 Completion,Clarification,RegistrationandAcknowledgement ...................................................................................................... 14

2.4.3 Sorting of Grievances ...................................................................................................................................................................................................................... 15

2.4.4 Grievance Processing ...................................................................................................................................................................................................................... 17

2.4.5 Corrective actions, follow-up and Closing a Grievance ............................................................................................................................. 17

3.0 ESTABLISHMENT AND MANAGEMENT OF GRIEVANCE REDRESS MECHANISMS ...................................................... 20

3.1 Community Level Grievance Management ............................................................................................................................................................................ 21

3.1.1 ContactCentresandClientCareOfficers .................................................................................................................................................................... 21

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1.3 Rationale for the harmonized GRM

Similar to what happens the world over, UNRA’s road development and maintenance operations provide economic and social benefits.However, theoperations also result into several environmental and social impacts, which may annoy, irritate or cause discomfort among stakeholders. The negative impacts call for institutionalizing globally-acceptable practices for implementing the mitigation hierarchy (avoids, minimize, restore or compensate for the loss). The impacts may include; casualties, fatalities, damages to sensitive ecosystems, loss of productive lands and assets, the spread of diseases, sexual violence, physical displacement, loss of livelihoods, as well as delayed completion of essential works, cost increases, and unsatisfactory road conditions. UNRA is fully aware of these risks and management is committed to addressing them in compliance with national and international best practices of avoiding, reducing, restoring or offsetting consequences of the negative impacts.

It has been realized that even under the elaborate safeguards systems that UNRA has put in place, the large-scale development projects have often caused unintended or overlooked impacts.

In some situations, the mitigation/compensation measures have not worked as envisaged and this has on several occasions triggered public outcry, community uprisings, and resistance to project activities, which defame the institutional image. Mechanisms to quickly identify and address such issues in line with the overall institutional do-not-harm principle have fallen short of expectations, and it is upon this background that UNRA has set up this harmonized Grievance Redress Mechanism (GRM) to facilitate the handling of grievances.

UNRA’s GRM shall handle problems in an efficient, transparent, timely and cost-effectivemanner and provide a cordial environment for the participation of all stakeholders, including affected parties. In this regard, the UNRA GRM is expected to generatebenefitstoprojectaffectedpersons(PAPs)and the public through the following ways:

i. Providing a forum for redressing grievances and disputes at all levels;

ii. Creating effective communication between UNRA and affected parties;

iii. Building productive relationships among all stakeholders, including affected parties;

iv. Allowing affected parties to discuss, negotiate and participate in the decision-making process; and

1 INTRODUCTION

1.1 Overview of UNRA’s Mandate

The Uganda National Roads Authority (UNRA) was established by an Act of Parliament; the Uganda National Authority Act, No. 15 of 2006 with the mandate to develop and maintain the national road network, and advise Government on general roads policy issues.

1.1.1 The VisionGreat Roads, Great User

Experience: 20,000 kms of first-classroads by 2025.

1.1.2 MissionTo efficiently develop and

maintain a safe and sustainable national road network for the economic development of Uganda.

1.1.3 Core ValuesIn the implementation of its

mandate, UNRA committed to upholding fivecorevaluesatalltimes,whichare:Safety, Integrity, Teamwork, Excellence, and Customer-Centric (SITEC).

1.2 Strategic Objectives

Tofulfillitsmandateandrealizethe Vision and Mission, UNRA has prioritized eight strategic objectives, among which, four are core to the Grievance Redress Mechanism.

i ii iii iv

To increase stakeholder satisfaction.

To improve accountability;

To enhance communication; and

To improve organizational culture.

They include:

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v. Mitigating or preventing adverse impacts of the project on communities and availing appropriate corrective or preventive actions.

1.4 Purpose of the GRM

The purpose of the GRM is to provide a clear commitment of the level of social performance in the planning and implementation of all UNRA’s activities while contributing to the four strategic objectives highlighted above, which focus on the realization of the Mission and Vision; while upholding the Core Values at all times

Specific Objectivesi. To provide to UNRA stakeholders at different

levels with a clear mechanism of channeling grievances;

ii. To operationalize the policy statement on Grievance Management in the UNRA Environment and Social Safeguards policy,

iii. To establish and maintain collaborative lines of communication across organizational and institutional boundaries throughout project planning, implementation, and maintenance;

iv. To provide an environment that fosters free and honest exchange of information, views, and ideas;

v. To provide an accessible, transparent and efficient complaint procedure for UNRAstakeholders; and

vi. To provide and define clear roles andresponsibilities of the various parties involved in handling and resolving grievances.

To achieve the objectives, this GRM has been developed to facilitate harmonization of related activities in UNRA so that an effective system is in place to provide timely and efficient two-waycommunication. It is expected that the GRM will provide benefits to stakeholders and increase thelikelihood of resolving minor disputes quickly and

fairly through a process that will satisfy all parties involved.

The mechanism is also expected to facilitate identification and resolution of issues at the firsttier before they are elevated to either second tier or to the judicial system. In that regard, UNRA endeavours to provide a grievance mechanism that involves an appropriate level of management and address concerns promptly through a predictable and transparent process that provides feedback to those concerned, without any retribution. It should be noted that the mechanism does not in any way try to hinder access to other judicial or administrative processes, which are available under the law or through recognized arbitration procedures.

1.5 Categories of stakeholders who may submit grievances

All grievances should be submitted through established communication channels and GMCs.

The following categories of stakeholders may submit grievances.

Individuals

Group of individuals Organization(s)

Project workers

Common interest groups

Enterprises, companies, service providers

National and international NGOs1

1 NGOs working in Uganda, whether national, local or international must be registered at the Ministry of Internal Affairs. Once registered, they are free to participate in activities within their mandate. This includes participatoin in social and development programmes that affect the communities, especially the marginalized, vulnerable and/or voiceless ones. As such, they can submit a complaintdirectlyorindirectlyastheydeemfittotheGRM.

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2.2 Types of Grievances

2.2.1 Engineering Related GrievancesGrievances under this

category arise either at the planning or implementation stage. The major issues related to engineering are to do with

road alignment, culvert locations, cost overruns, and the location of access roads or route options. Grievances which are design-related should be escalated to the Head design for assessment and preparing an appropriate response to a stakeholder or group of stakeholders. An engagement with the aggrieved parties may be arranged for the respective technical engineer to provide clarification. In casean engineering-related grievance arises during the implementation or maintenance phase, the grievance should be escalated to the respective Project Manager, Regional Manager or Station Manager for assessment.

2.2.2 Survey Related GrievancesGrievances may arise at

the design stage, such as where some communities feel they were not offered enough information about the objectives of the

exercise.. In such situations, the Head of Survey and Documentation should be notified to prepare anappropriate response. An engagement with the aggrieved parties to clarify issues may be arranged too.

2.2.3 Environmental GrievancesEnvironmental-related

grievances may arise at any stage of the project management cycle as a result of disturbance of natural ecosystems, inadequate

management of project impacts, inadequate restoration of sites or failure to consult, sensitize and disclose potential project impacts to affected communities. When these kinds of impacts arise, the

Head of Environment and Social Safeguards should benotifiedtoassessthegrievance.Heorsheshouldeither implement appropriate mitigation measures or prepare an appropriate response to stakeholders.

2.2.4 Social GrievancesSimilar to the environment,

social-related grievances may arise at any stage of the project management cycle as a result of inadequate consultation,

sensitization, and or disruption of social setups by migrant workers. There are also situations when social grievances arise out of unrealistic expectations. When these kinds of impacts arise, the Head of Environment and Social Safeguards shouldbenotified toassess thegrievanceandtakeappropriate remedial measures.

2.2.5 Resettlement, Land Acquisition, and Compensation Related Grievances

Currently, most grievances logged into the UNRA database are related to this process. The grievances are mainly caused by inadequate consultation and

sensitization; delayed release of compensation packages or delayed return of land titles to Project Affected Persons. The process involves a lot of interaction with people during the preparation of (a) the Resettlement Action Plan (RAP), (b) land and assetinventories,(c)landvaluationsandverifications,(d)disbursementandduringafinallandtake.

Given the sensitivity of land ownership in Uganda, it is a common occurrence that grievances erupt during the preparation of the RAP and its implementation stages. Land acquisition and compensation grievances will be escalated to the Head Land Acquisition for assessment and resolution. For social grievances related to the land acquisition process, support may be sought from the Head Environmental and Social Safeguards (HESS).

2 OVERVIEW OF UNRA’s HARMONIZED GRIEVANCE REDRESS MECHANISM

2.1 Grievances

With respect to this guideline, a grievance is either a real or perceived wrong or hardship suffered by an individual or a group of individuals as a result of interfacing with UNRA’s activities in the project management cycle2. A grievance differs from a concern, feedback, suggestion or question.

In line with international best practices, therefore, UNRA has developed mechanisms to clarify the nature of each grievance submitted in order to avoid clogging up the system with issues that may not constitute grievances. A grievance also includes information disclosed by a whistle-blower who reasonably believes

that the information that he/she has tends to show (a) that a corrupt, criminal or other unlawful act has been committed, is being committed or is likely to be committed; (b) that a public officer or employee ofUNRA has failed, refused or neglected to comply with any legal obligation to which thatofficeroremployeeissubject;(c)thata miscarriage of justice has occurred, is occurring or is likely to occur in respect of a road project. In this case, this complaint will be treated confidentially under theWhistleblowers Protection Act 2010. Even in cases where protecting the privacy/anonymity of grievances are key, UNRA will ensure that they are able to disclose how they are resolving grievances while protecting privacy of complainant.

2 The GRM also includes reporting of incidents. An incident is an accident or negative event resulting from failure to comply with UNRA and funding partner’s safeguard policies, or conditions that occur because of unexpected or unforeseen events during project implementation. Examples of incidents include: fatalities, serious accidents and injuries; social impacts from labor influx; sexual exploitation and abuse (SEA) or other forms of gender-based violence (GBV); major environmental contamination;

loss of biodiversity or critical habitat; loss of physical cultural resources; and loss of access to community resources. UNRA has an Environment and Social Safeguards Policy and Safety Management System for detailed handling of incidents that are in tandem with the Occupational Safety and Health Act 2006. Serious incidents reported to the GMC should be reported to UNRA within 24 hours and subsequently to the World Bankwithinthesametimelineinordertofulfillinternalreportingrequirements..

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Figure 1: Schematic Representation of UNRA’s Grievance Redress Mechanism

2.3. Grievances Handling

Any UNRA staff involved in implementing an activity which contributes to the realization of the organizational Mission, Vision and overall mandate, is responsible for providing responses to any technical grievance which may arise as a result of executing specialist activities in line with established reporting and response timelines (as stipulated in Annex 4). The response may be given to an aggrieved party

directly by the technical staff or the feedback may be channeled through the Public and Corporate Affairs (PCA) department, which has the overall responsibility of managing public relations, communicating to masses and safeguarding the institutional image. It is expected that staff who are not technical in a given areashallnotofferadefinitiveresponsetogrievancesof a technical nature.

.

2.3.1 Responsibilities for Handling GrievancesGrievances may arise at any stage during

the implementation of a project. The likely grievance categories are in Annex 1. The responsibility for assessing a grievance and providing appropriate responses to stakeholders lies with the specialist staff whose action or inaction may have triggered

the grievance. The specialist areas in UNRA from which grievances may arise (Annex 1) include, but are not limited to, those represented in Figure 1. The roles of different actors in handling grievances as schematically shown the figure below aresummarized in Annex 5.

Individual

Technical StaffPCA Department

Group / Organisation

Grievance reportedAddressed by PCA Department

Addressed by technical Staff

Failed case is referred to PCA department

UNRA Board (High supervision, political issues etc)

UNRA TMT (overall supervision, guidance and endorsement)

Client Care Centers, Stations & GMCS

Receive grievance via Email, mail, SMS, Calls, meetings etc.

Grievance Officer

• Sorting• Investigation• Processing• Decision

making• Action• Reporting

Contractors

Resident Engineers

UNRA Land Acquisition

UNRA Engineering

UNRA Project Manager

UNRA Procurement

DESS

PCA

Local Government

DRM

DRIP

Participatory Monitoring on processes, outcomes, and overall satisfaction

Stakeholders (Communities, individauls, NGOs etc.)

Incoming Grievances• Verificationofinformation• Clarification&Registration

Processed Grievances• Disclose response• Discuss with aggrieved• Obtain and report feedback

from aggrieved person

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Steps in handling/administration of grievances under the UNRA harmonized GRM include the following;

2.3.2 Gender Responsiveness in Grievances ManagementMen and women may not only communicate

their grievances differently but may also have different types of grievances. Gender differences should be taken into consideration when handling grievances. It is always important to note that women and men might report different issues and UNRA staff responsible for handling the complaints should avoid subjective judgments that may lead to trivializing some complaints on the basis of gender. In situations where women or men may feel uncomfortable discussing a grievance with a person of the opposite sex,theresponsibleofficershouldprovidetheoptionof holding discussions with someone of the same sex, both at the time of registering the complaint as well as during the review process.

2.4 Grievances Management

UNRA has established this harmonized GRM for dealing with grievances which may arise from time to time during the implementation of its mandate. It is, however, important to note that the grievance redress mechanisms for UNRA staff will be separate from these public grievance mechanisms. While it is also important to note that several important grievance management principles may apply to handle both public/communities’ and workers’ grievances, UNRA is keen to ensure that the grievance mechanisms established at different levels are appropriate for the scope and allow for effective resolution of issues in a timelyandefficientmanner.

Receiving grievances;

Completion, clarification,

registration, and acknowledgment;

Sorting of grievances (verify,

investigate and act);

Processing and feedback;

Corrective actions;

follow-up and closing.

i ii iii iv v

2.4.1 Receiving Grievances A grievance can be submitted either

in writing or verbally. It can be submitted at the UNRA headquarters, UNRA officesin Kyambogo, which have a dedicated contact center that operates the toll-free hotlines, UNRA’s stations and contractors’ offices.

Community-based Grievance Management Committees, which are established along all active project roads may also be used for logging grievances. Grievances may, in addition, be submitted through any of the

following channels:

i Email: ([email protected]);

ii Letter to the Executive Director; Plot 3-5 New Port Bell Road, UAP Nakawa Business Park, and P.O. Box 28487 Kampala.

iii Fax (041-4-232807)

iv Suggestion Box;

v Walk-intoHQ,ProjectOfficeoranyofthe23stations;

vi

Via telephonea) Toll-free line: (0800-100-812)b) Customer/Client Care Hotline (041-4-318111)c) Text-message to one of the aboved) Call in Radio and TV programmes

vii Media (print and electronic);

viii

Social media; a) Twitter (@unra.ug)b) Facebook (UNRA page); and

ix Through meetings, conferences and workshops

x Through the GMCs, set up along road projects.

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Who submits a grievance?A grievance can be submitted by individuals,

groups, communities and organizations that are affected by UNRA’s project activities . The choice of channel for submission is based on the aggrieved person’s convenience in terms of cost and privacy.

While the GRM is operated in English, the people in charge of receiving and discussing grievances with the affected people will make all efforts to translate and/or write down incoming grievances submitted in local languages. They will also discuss the findings and proposed actionsusing the preferred language of the complainant. And involving the nearest Grievance Management Committee where applicable may be of importance in dealing with language barriers.

Minimum requirements for submitting a grievance: While there is no formal minimum requirement for submitting a grievance, to enable effective review and management, UNRA expects any stakeholder who submits a complaint to include the following information:

i. Name(s) of the complainant(s); ii. Information on whether the identity of the

complainant should be kept confidential orcan be disclosed to relevant individuals/structures during the investigation process;

iii. Contact details (geographical location, telephone number, e-mail ...);

iv. Details of the grievance; what happened exactly; the place where it happened; the parties involved; the time or date when it happened; the circumstances under which it happened; as well as the result of the problem. It is also important to understand whether the incident was a one-off or whether it is recurrent (refer to the standard community grievance reporting template in Annex 5).

Submission of incomplete information about a grievance may result in delay or failure to process the complaint. In situations where a stakeholder submits a grievance with incomplete and unclear details, the respective UNRA staff who receives the grievance should follow up and obtain all the necessary information. Whenever possible, grievances should be submitted along with supporting documents (such as photos, maps, statement of witnesses, etc.) This eases the investigation and resolution of the grievance. More guidance on submission of grievances can be got from the Sample Grievance Form in Annex 5. Paper copies of the grievance form and the community reporting template can also be accessed through Grievance Management Committees, stations, and projectofficesaswellasfromtheUNRAWebpage.

2.4.2 Completion, Clarification, Registration and Acknowledgement All grievances received should be registered

and logged. The complainant should receive an acknowledgment of receipt of the grievance within a prescribed and reasonable timeframe, preferably in writing.

UNRA ensures that submitting, registering and logging a grievance

should not incur any cost to the complainant. UNRA further allows for flexibility and ensures that grievances are not dismissed on grounds of an administrative formality and/or procedure.

Complaints should be reviewed as soon as they are received and prioritized for resolution. Regardless of the response and resolution timeframes, there are complaints which have been categorized to require immediate attention, such as those involving loss of life and any form of child abuse or violence against children. Based on experience, many grievances received in UNRA can be addressed andfixedpromptly..

Documenting grievances: Keeping a record of those who lodged grievances helps UNRA to know who and where the vulnerable and most affected persons by UNRA activities are. Data such as gender, age and location is also recorded, which assists in understanding the grievances better. Most importantly, UNRA recognizes that those who register grievances must be protected and, therefore, handles grievances with the highest level of confidentiality;complainants are free to remain anonymous and should feel free to give as little personal information as they wish.

A central database has been established to enhance logging, management, and monitoring of grievances. However, at the project level, where the establishment of specific databases has nothappened, documentation of grievances in log books keeps a good record and track of issues.

2.4.3 Sorting of GrievancesCategorizing grievances:

Having received and registered a complaint, the next step is to establish the eligibility of the complaint. The following criteria should be used to assess and verify eligibility:

i. The issue is within UNRA’s mandate and falls within the scope of the GRM

ii. Thecomplainantisanonymousoridentifiablewith a name and contact details provided;

iii. The complainant is affected by a UNRA project or any other UNRA activity.

iv. The grievance is clear; v. The complaint has a direct relationship to

UNRA’s project or activity; andvi. All the mandatory preliminary information is

available.

The purpose of this step is to ensure that the issue being raised is relevant to UNRA. If the grievance is not eligible, the complainant will immediately be given the reasons. On the other hand, a decision

on eligibility is only meant to trigger an initial assessment and response. It is not an admission that the organization has caused an impact, or a commitment to provide the complainant with any specificformofredress.Theassessmentatthisstepwill also enhance decision-making as to whether the complaint should be directed to a different entity. Complaints alleging economic impact as a result of corrupt practices may require immediate referral to UNRA’s investigation department, or to an external anti-corruption office for purposes of avoiding apotential conflict of interest.

As a result of the assessment, the grievance will be assigned to one of the four categories in Table 1, such as, Category 0: Complaints that are not related to a UNRA project, project workers or any UNRA activity; (b) Category 1: Queries, comments, and suggestions; (c) Category2: Complaints and concerns, which are not criminal in nature or do not require the involvement of police, (d) Category 3: Complaints and concerns that involve allegations that require investigation or intervention by the police or other law enforcement authorities.

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2.4.4 Grievance Processing Investigation and Feedback (Tier One):

Complaints that are straightforward can often be resolved on first contact. If this is

not the case then the complaint may require investigation. The investigation includes the gathering of documents, proof,

and facts, as well as clarifying background information in order to verify

the circumstances surrounding the grievance.

In general, Category 0 grievances will involve verificationthatthestakeholderissatisfiedwiththeresponse. If the grievance involves another project or an institutional issue, the complainant should be referred there accordingly. Category 1 grievances will involve confirming receipt of the positivefeedback and informing the relevant technical staff in UNRA. Regarding category 2 grievances, verification, investigation, negotiation, mediation orarbitration, coordination with appropriate authorities, making decisions, proposing resolutions, as well as the implementation of agreed actions, will involve a thorough assessment and getting back to the complainant for more information in case it is required. A grievance which falls in category 3 should be logged and escalated to police without any delay. If grievances include more than one issue, the Grievance Officerwillmake sure that all issues arereviewed and addressed at the same time to avoid any delays.

Arbitration and Legal Redress (Tier Two): Anycomplainantwhomaynotbesatisfiedwiththeoutcome of the UNRA investigation, he/she may resort to arbitration. Where arbitration also fails, either of the two parties may opt for court. UNRA will not in anyway interfere with a matter in courts oflawbeforethefinaljudgmentispassed.Itisalsoimportant to note that even in situations where a grievance may be delegated to another party (such as a Contractor or Resident Engineer) UNRA retains

the ultimate responsibility of ensuring that resolution of the grievance has been to acceptable standards through established procedures.

2.4.5 Corrective actions, follow-up and Closing a GrievanceCorrective actions and follow-up: If a

grievance is resolved, the complainant will be informed of the outcome. If a grievance is not resolved and is escalated for consideration and resolution at another level, appropriate information will be provided to the complainant, including the date when the case will be passed to a higher level and the date by which the outcome is expected.

Closing a grievance: UNRA will consider a grievance closed only after an amicable resolution has been reached between the two parties (the complainant and UNRA). In certain situations, however, UNRA may “close” a grievance under special circumstances even if the complainant is not satisfied with the outcome. Such situations, inwhich UNRA closes a grievance before a stakeholder is satisfied with the outcome, may arise if thecomplainant cannot substantiate the grievance or if there is an obvious speculative or fraudulent attempt. In such situations, all steps (Figure 2) and efforts are taken to investigate the complaint before reaching a conclusion. This information will be documented and communicated to the complainant without putting the lives of those who provided the information in danger.

It is, however, important to note that all UNRA staff involved in handling grievances should not dismiss any grievance based on a hasty review and close off an investigation before the complainant hasbeennotifiedandgivenanopportunitytoprovideadditional information. Consequently, a decision to close such grievances requires the endorsement of thesupervisingofficer.

Table 1: Examples of Complaints that fall in different categories

Examples of Complaints

Category 0: complaints that are not related to the project or project workers.

• Electricity poles falling in someone’s compound as of routine maintenance by the power company

• Interrupted water supply due to routine maintenance by the national water corporation

Category 1: Queries, comments, and suggestions.

• Appreciation for improving the condition of road X• Request for grading the road to a nearby school or health

facility

Category 2: Complaints and concerns which are not criminal and may not require a police investigation

• Concerns and complaints about land acquisition or livelihood restoration, environmental damages, nuisance impacts such as noise or dust, waste management, risks to public safety

Category 3: Complaints and concerns, which are criminal in nature and require investigation by the police

• Any grievance which involves loss of life, child abuse, rape,defilement,childsacrifice,sexualharassmentoranyviolence against children.

Prioritization of grievances: If the initial assessment establishes the eligibility of the complaint to be pursuable, further assessment is carried out on the risk and imminence. Assessing the authenticity of a complaint is based on imminent risk and implications to the institutional and UNRA partners’ image. Both impact and urgency are measured/classified in terms of being high, medium or low.

Thus, based on the assessment of risk and urgency, thepriorityindexisidentifiedasbelongingtolevel1,2, 3, 4 or 5 as shown in Table 2. Priority 1 is critical and is accorded immediate attention as it is deemed to most likely lead to loss of project funds, life, etc. On the other hand, priority 5 is the least important.

Table 2: Ranking of a Grievance

RISK

URGENCY

High Medium Low

High 1 (Critical) 2 3

Medium 2 3 4

Low 3 4 5 (Lowest Risk)

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Figure 2: Schematic Representation of the Grievance Handling Process

Receipt and registration

Resolution

NoYes

Yes

Closure and sign off

Closure and sign off

Parties resort to arbitration

Arbitrator review

Arbitrator resolution

Resort to courtNoBothpartiessatisfied

Internal review and assessment

Parties satisfied

Tier One - Internal to UNRA

Tier Two - External to UNRA

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3.1 Community Level Grievance Management

3.1.1 Contact Centers and Client Care OfficersFor purposes of managing the corporate

image, UNRA allocates the responsibility for communicating with stakeholders at all levels with the UNRA Public and Corporate Communication Department. UNRA will establish contact centers along project roads depending on the scale, length of the project and the total number of the affected population.Thiswillactasthefirstpointof logginggrievances for a community member who may not wish to use either the established Grievance Management Committees (GMCs) or the Sociologists that are tasked to engage with all stakeholders on road projects.

The contact center may take different forms, which may include but not limited to:

i. Physical contact centres, ii. Temporary hubs in remote areas.iii. Roving or mobile contact centers to service

rural clients on a regular schedule. This initiative seeks to take services closer to places where clients can access them easily.

The client care office operates the toll-freelines, social media, general email account, and incoming mails addressed to the ED and/or without a clearly designated recipient. They also review all newspaper and media publications and organize public engagements. In each of the contact centers, atleasttwofull-timeclientcareofficerswillbetrainedto receive, clarify, document and register grievances as well as inform stakeholders about the availability of UNRA’s grievance redress mechanism. While the grievancesmaybereceivedbytheclientcareofficers,assessing the content and preparing the appropriate feedback should be done by the respective technical officers to ensure accuracy and consistency ofmessages given to stakeholders.

For smaller projects, such as town roads, UNRAmay just assign a client care officer (Figure3), to whom grievances should be channeled for escalation to technical officers. Once the grievancehas been received and acknowledged, the grievance should be channeled to the Resident Engineer or the Project Manager for resolution, depending on the scope and level of risk to the institution. All grievances should also be logged in the central database by the designatedofficers.

3 ESTABLISHMENT AND MANAGEMENT OF GRIEVANCE REDRESS MECHANISMS

Experience has shown that grievances start emerging early in the life of UNRA’s projects, and it is, therefore, important that a grievance mechanism should start as early as at the feasibility stage, and continue all through the design, survey, RAP and ESIA processes.

During these early stages, the GRM is mainly composed of UNRA study teams, and later on transitions into a community mechanism, which is established to handle grievances during land acquisition, construction and the defects liability period. For effective handling of grievances related to land acquisition, the grievance mechanism

should be constituted before the census of affected properties and at the very least before disclosure of entitlements.

Contractors should establish the Workers’ the Grievance Mechanism3 before mobilization and at the very latest before the commencement of works.

Figure 3: An illustration of reporting a grievance at Community level

3 The modalities for establishing a Workers Council is being put in place; the council will have representation of workers and through it the grievances from workers and staff will be handled.

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Community Expectations of the GRM

1. Acknowledgment of receipt of complaints 2. An honest response to their questions/concerns about project and sub-project

activities 3. An apology where necessary 4. Compensation where appropriate and in line with national policies and guidelines5. Modificationoftheconductthatcausedthegrievances6. Some other appropriate remedy 7. Grievances prevention / reduction on any project under UNRA

3.1.2 Grievance Management Committees The Department of Environment and Social

Safeguards, in coordination with other relevant departments, is not only responsible for coordinating preparation and update of the GRM but also has the overall responsibility for formation, mobilization, sensitization, facilitation, training and monitoring the functionality of the Community Grievance Management Committees (GMCs).

GMCs are formed for complex and/or sensitive road development projects. They are not governmental structures but established by communities and are essential points of contact for UNRA on grievances voiced by community members. Consequently, membership in GMCs is voluntary and its services are conducted without expectations of a monthly remuneration from UNRA. Any resident withinthevicinityoftheprojectroadqualifiestobea member of the GMC. GMCs generally consist of six members: Three Project Affected People (at least one being a woman), one opinion leader (such as an elder, a religious or clan leader), LC-1 chairperson (as an ex-officiomember) and one local NGO/CBO leader (asan observer). To ease access, GMCs cover all villages along the project road, ensuring that no complainant should travel for more than 3km to reach the nearest GMC member. This means that in densely populated

areas, one GMC might cover more than one village and LC1 chairperson. In such cases, all LC1 chairpersons are ex-officiomembers of the GMC and the overallnumber of members, therefore, increases. Effort is always made to ensure that GMCs are headquartered in rural growth or trading centers.

Additionally, UNRA is dedicated to strengthening the role of women in project areas, and, therefore, endeavours to enhance the number of women in GMCs to constitute half of its members. However, as most LC1 chairpersons and opinion leaders are men and their selection lies outside the mandate of UNRA, the desire to implement this affirmative action may not always succeed.In situations where efforts to attract women to the committees fail, such efforts should be properly recorded and archived. To motivate GMC members, UNRA recommends that the chairpersonship may berotational.Also,UNRAcouldprovideacertificateof recognition at the successful end of the term of office,andoractiveGMCmembersmayberequestedto mentor new GMC members.

The GMCs are trained by UNRA on best practices in grievance management and supported by UNRA’s sociologists, who visit them at least once a month to collect new complaints and provide

feedback on processed grievances. GMCs who may not wish to communicate through the sociologists for the RE or those who may be deployed by UNRA are free to channel their grievances directly to the Resident Engineers or to UNRA.

Depending on the complexity and need, a project may have three types of GMCs, namely community GMC, sub-county GMC, and district GMC4.

In general, as stated earlier above, the memberships ofaGMCareofthreetypes:member,ex-officioandobserver. Representation by individual members varies at the district, sub-county and community level. Furthermore, it is not uncommon that from time to time some members of the community GMC, especially the PAPs who might have received their compensation, to lose interest in the GMC, thus necessitating replacements and fresh training.

3.2 Project Level Grievance Management

3.2.1 Objective of having a Project Level GRMUNRA requires that a project-level mechanism

for managing grievances be established for each of its road projects, regardless of the source of funding or development partners.

The process by which the project level GRM (Figure 4) is designed should be integrated into the overall approach, including describing concrete actions in the Environmental and Social Management Plan (ESMP) for all road projects that are listed in the Third Schedule of National Environment Act, Cap 153, “Section 3(a&b). The section requires that road projects should undertake a full Environmental Impact Assessment (EIA) before implementation.

3.2.2 Project Level GRMThus, at the project-level, there is always a

GRM that is locally-based with a formalized way for the project proponents and implementers to accept, assess, and resolve community complaints related to project activities and impacts. It will offer a package of widely-understood and effective procedures for solving problems that are culturally appropriate, in combination with specially trained personnel. This aims to help parties reach speedy, efficient,acceptable and amicable resolutions with dignity, justice,andfinality.

The objective of the project level GRM is to provide a systematic process by which aggrieved parties can be assured that a complaint or concern will be addressed and resolved within a reasonable timeframe and that the complainant will be informed of the ultimate outcome.

4 When a quick resolution of a grievance cannot be made at the Community GMC level, the CCO will forward it to the Sub country GMC or directly to the District GMC. When the GMC cannot resolve the same, the grievance is escalated to the RE, UNRA station, UNRA ferry, weigh bridge Managers or Headquarters as may be appropriate.

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Resident Engineer: Experience from managing several road projects indicates that Resident Engineers receive several grievances from community members, regarding the different project activities. For grievances, which fall within the

contractor’s obligations, the RE is required to record in the logbook, and immediately issue an instruction for corrective action and also notify UNRA’s project manager for appropriate monitoring. In situations where the RE may receive a grievance, which involves defilement,childabuse,rape,oranyformofviolenceagainst children or sexual harassment, such a grievance should be escalated to the Project Manager and to the nearest police within twelve (12) hours of receiving it. The RE will assign the sociologist on the supervising team to track grievances and at all times include a section on grievance management in the monthly progress report.

UNRA Project Manager: The Project Manager has the overall responsibility for the day to day running of the project; including grievance management and overseeing the functions of the Project Management team. For proper

logging, escalation, tracking, reporting and following up on all project specific grievances, aswell as forpurposes of complying with international good practice, it is recommended that the project manager will assign one of the project team members the functionsofaGrievanceOfficer.Ontheotherhand,itis the responsibility of the project manager to swiftly escalate any grievances that cannot be resolved at the project level or may pose a big reputational risk to the institution of the Executive Director.

UNRA Station Offices: Station offices willfrom time to time complement the headquarters’ effort on grievance management. The station managers will receive grievances on UNRA activities within their area of jurisdiction and do one

of the four options depending on the category of grievance:

i. Resolve the grievance;ii. Refer to the Regional Manager iii. Escalate to a Project Manager; and oriv. RefertotherespectiveofficeatUNRAHQ

UNRA Ferry or Weigh Bridge Managers: When ferry or weigh bridge managers receive grievances about UNRA activities within their area of jurisdiction, they may:i. Resolve the grievance;ii. Refer to the Station

Manager to handle the grievanceiii. Escalate to a Project Manager; and oriv. RefertotherespectiveofficeatUNRAHQ

3.3 National Level GRM

UNRA Headquarters: At the national level, the overall management of the corporate GRM rests within the office of the Executive Director,specifically with the Head ofCorporate Strategy and the Head Public and Corporate Affairs.

The Head PCA maintains the Corporate Grievance Management Portal, which generates corporate reports. The Head Corporate Strategy Management will also continually monitor and evaluate the functionality of the harmonized GRM and regularly report to TMT regarding its functionality. The Head Public and Corporate Affairs will continuously keep the public informed of the availability of GRM in UNRA.

Directorate of Legal Services: This directorate is responsible for dealing with legal matters related to UNRA with respect to grievances about contracts as well as claims that require legal

resolution. Because all litigations related to UNRA are handled by the Directorate, any grievances that need legal redress will also be dealt with by the Directorate.

Handling a project based grievance

Figure 4: Steps in the management of project based grievance

Contractor: The contractual responsibilities of a project contractor include; appointing a sociologist and a health and safety professional responsible for engaging with local communities and addressing grievances arising from the work

of the contractor. In that perspective, the contractor’s sociologist works closely with the GMCs in agreeing to and implementing actions to resolve grievances. The contractor will further notify the resident engineer and UNRA’s grievance officer immediately of anygrievances that require investigation or intervention by the police or other relevant authorities.

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Figure 5: Flow of grievances to and from the Central Grievance Data Base

General Public Project Grievance Officer

UNRA Station | Ferry Station

Weigh Bridge | Grievance

PCACentral Grievance

Data Base

Head Cooperate Strategy

TMT

Monitors and evaluates performance of the GRM

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wellastoUNRAStaffinthefieldthroughanandroidmobile application and through the web/internet application. UNRA stations are mainly recording grievances in log books. The overall management of the corporate grievance database rests within the officeoftheExecutiveDirector,specifically,withtheHead Corporate Strategy and the Head Public and Corporate Affairs (PCA).

The Head PCA will assign an officer tomaintain the Corporate Grievance Management Portal, which generates corporate reports and also keeps the public informed about the available GRM in UNRA. The Head PCA may from time to time publicize the resolution status of specific grievances, whichmay be of particular interest to the general public.

4.2 Internal and External Monitoring

For its operations, UNRA requires periodic internal and external monitoring of the grievance management procedures as part of its monitoring activities. Indicators that cover process, output, outcome and impact levels for monitoring and evaluation of the performance of the GRM have been approved. The GRM will, therefore, be frequently monitored to assess its performance and hence determine its effectiveness in resolving grievances using the following parameters.

i. Total number and type of grievances received;ii. Channels through which grievances were

received;iii. Number and percentage of complaints that

have been resolved/unresolved; iv. Number and percentage of complaints that

have gone to mediation;v. Resolution timelines for the resolved

grievances;vi. Status of unresolved grievances;vii. Customer feedback on GRM;

viii. Turnaround time;ix. Percentageofcomplainantssatisfiedwiththe

response and grievance redress process;x. Percentageofprojectbeneficiariesthathave

access to the GRM;;In addition to the formal monitoring and

evaluation, DESS will control and assure the quality of the GRM Process on Road Project and extract lessons learned through their regular compliance review missions. This will be done through:

i. Review of logging, tracking and documentation systems, including acknowledgment of receipts and resolution agreements;

ii. Checking that deadlines and timeframes committed to in the mechanism are generally met;

iii. Checking that potentially affected persons and the public are generally aware of the avenues available to channel grievances;

iv. Checking for any variations in time spent and the number of open and closed grievances;

v. Checking how resolution responsibility is assigned;

vi. Checking public/community satisfaction with the process (timeliness, fairness, accessibility, predictability, etc.); and

vii. Confirming that “resolved” grievances areclosed following satisfactory due process.

4.3 Reporting

The Head Corporate Strategy will assign an M&EOfficertocontinuouslymonitor

grievance management at the corporate level to develop indicators, monitor and evaluate the GRM at agreed intervals.

Provisions for generating different types of reports have

also been incorporated into the UNRA grievance management software. Hence, using these resources from the software and other M&E activities will be

4 MONITORING, EVALUATION, REPORTING AND COMMUNICATING ON GRM

4.1 GRM Database

Having realized that the GRM will generate an enormous amount of grievances, an application has been

developed to enhance data entry, quality assurance, processing, analyzing and reporting. The application is

based on the GRM log template in Annexes 2. The application is simple and easy to input data, providing information on the nature of grievance, resolution status, and timelines. Provisions for generating different types of reports have been incorporated into the software. The application is available to the general public through an application on Google Play Store called Speed Up, as

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4.4 Communicating the GRM

The existence of the UNRA GRM will be communicated to the general public through a variety of channels including but not limited to the following;

i. Print media including newspapers and IEC materialsii. UNRA websiteiii. Social mediaiv. Radio talk shows, mentions, and announcementsv. Printing and distribution of T-shirts

REFERENCES

• African Development Bank Group (2015) Safeguards and Sustainability Series: Integrated Safeguard System Guidance Materials.

• European Bank of Reconstruction and Development (2012) Grievance Management Guidance Note.• The World Bank (2017) The World Bank’s Approach to Grievance Redress in Project: Dispute Resolution and

Prevention. Anonymous as on 29th September 2017, http//: www.worldbank.org• The World Bank (2018). Environment and Social Incident Response Toolkit for World Bank Staff. November

2018.• Uganda National Roads Authority (2016) Environment and Social Safeguards Policy • Uganda National Roads Authority (2017) Corporate Strategy• Government of Uganda (2010), the Whistleblowers Protection Act 2010

the responsibility of the Head Corporate Strategy to regularly report to the Executive Director and TMT regarding the functionality of the GRM. The Management Team will use the consolidated report to identify systematic, recurring and single incident problems and trends, and to help eliminate the underlying causes of such complaints. In particular, management’s receipt and discussion of the consolidated report will help in the following area:

i. Ensure GRM’s continuing suitability, adequacy, effectiveness, and efficiency aswell as potential changes required;

ii. Identify and address instances of non-conformity with UNRA management principles;

iii. Identify and correct process and service deficiencies;

iv. Assess opportunities for improvement and the need for changes to the GRM and services offered; and

v. Use the key lessons learned from the grievance process for improving the GRM

In publicizing the GRM, the focus will be on providing Information to the general public regarding the available channels through which grievances can be communicated to UNRA. Leaflets, website links, postersinadministrativeofficesandpublicplaces,orcomplaint boxes at strategic locations will all be used

to disseminate the GRM. It is the overall responsibility of PCA to inform the public about the availability of this GRM. As part of the GRM dissemination strategy, UNRA has developed a training manual, which will form the basis for training UNRA staff as well as community members involved in handling grievances.

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Service Request Issues1. Request for prioritization of roads 2. Request to borrow or hire organization machinery or

equipment 3. Request to include road sections previously not in the

contract

Occupational Health and Safety Issues1. Protective gear 2. HIV/AIDS services

Other issues 1. Procurement 2. Ferry complaints 3. Overloaded vehicles 4. Road littering

UNRA Grievance Log

Ref NO: ..............................................................................................................(Tobeassignedbythereceivingoffice)

1Name (The Complainant should feel free to remain anonymous)

Name/s of complainants ……………………………………………………………………….......………....………………………………….

Gender Male ………...….........………… Female ………...….........…………

Age of complainant ………...….........………… years.

Other Names ………………………………………………………………………………………………………….........................….........……………….

I wish my identity not to be disclosed Yes ………...…........…… No ………..........…………

My identity should not be disclosed without my consent

Yes ………...….........………… No ………...….........…………

2

Contact InformationSpecify how you would like to be contacted and provide details

Contact me by:

Telephone ………………………………………………..............….………. email ………………………....…………………….........…....……….

Post (P. O Box) ………………………………………………..............….……….

Physically address (Specify) …………………………………………………......…………………...................……………….......

....………………….............………………….............………………….............………………….............………………….............………………….....…....……….

3Language (Specify all possible languages in which you can be contacted)

……………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………....................………………..

ANNEXES

Annex 1: Categories of Common Complaints Received by UNRA

Land-related issues 1. Non-payment of compensation money 2. Underpayment of compensation money 3. Over-Valuation and Undervaluation of same or

similar property 4. The omission of the affected property 5. Road Reserve queries 6. Return of Title 7. Delayed payment 8. Disputes of land ownership 9. Injurious affections e.g. cracks in buildings, house

left either hanging or below the road culvert locations 10. Boundary queries between PAPs 11. Registration of ghost PAPs 12. Forgery of documents (e.g. Land titles, death

certificate)13. Obtaining money by false pretence 14. Impersonation

Environmental issues 1. Storm water 2. Stone blasting 3. Dust 4. Noise 5. Uncovered borrow areas 6. Encroachment on natural

resources 7. Waste Disposal 8. Hipping Soil Spoils in private

property or swamps

Road Safety issues 1. Accidents 2. Potholes/cracks 3. Narrow road sections 4. Dangerous bends 5. Drainage issues 6. Humps 7. Signage 8. Blackspots 9. Markings 10. Cutting of pavement by utility companies e.g. NWSC,

Telecom 11. Stationary and abandoned vehicles 12. Floodlights 13. Reflective ribbons 14. Barricades

Social Issues 1. Disruption of other existing public

services e.g. hospitals, schools, Water and electricity supply

2. Historical sites 3. Cultural sites 4. Unwanted pregnancies 5. HIV/AIDS issues 6. Child labour 7. Family breakages 8. Rape / sexual and Gender-Based

Violence

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Resolution signatures

Name of complainant ………………………………………………………...........……………..……….…… Signature ……………………………………………............……………… Date ……………………...........….…………

Second Party (UNRA / Contractor etc) ………………………………………….…… Signature ……………………………………………..........…….……… Date …………………….............…………

GMC Chairperson Name ………………………………………………………...........……………….…… Signature …………………………………………….............……………… Date ……………………..............…………

GMC Secretary Name ………………………………………………………............…………………………… Signature ……………………………………………......………….....…… Date …………………............……..………

4 Description of grievance

What is the issue …………………………………………………………………………………..…………………………………………………………………

Where did it happen ………………………………………………………………………………………………………..…………………………………

When did it happen …………………………………………………………………………………………………………….………………………………

How did it happen …………………………………………………………………………………………………………………………………………………

Who caused it ………………………………………………………………………………………………………………………...........…………………………

What was the impact/outcome ……………………………………………………………......………………………………………

5 Frequency of incident

One-off ……………......................…………… Yes …………….....................…………… No ……………....................…………….

If yes describe ……………………………………………………………………………………………………………………………………………......…………………

………………………………………………………………………………………………………………………………………………………………………………………....………………

If No, specify ………………………………………………………………………………………………………………………………………………………………………

…………………………………………………………………………………………………………………………………………………………………………………………………………

6What would you like to happen in order to resolve the grievance

……………………………………………………………………………………………………………………………………………………………………………...…………………………………

…………………………………………………………………………………………………………………………………………………………………………………………………………………

…………………………………………………………………………………………………………………………………………………………………………………………...…………..

Signature: ……………............................................................................................…………… Sent By: ……………............................................................................................……………

Date: ……………..........................................................................................................……………

Grievance resolution status

Issue Type Issue Description Action Taken Issue Status

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Annex 3: Response Time in working days

CATEGORY ISSUE TIME (working days)

Land

Non-payment of compensation money 14 days

Underpayment of compensation money 14 days

Undervaluation on the property 90 days

The omission of the affected property 14 days

Road reserve queries 7 days

Return of title 120 days

Delayed payment 14 days

Disputes over land ownership 14 days

Injurious affections 7 days

Boundaries queries between PAPs 7 days

Registration of ghost PAPs 15 days

Forgery of documents 15 days

Obtaining money by false pretence 7 days

Impersonation 7 days

Environmental issues

Storm water 7 days

Stone blasting 15 days

Dust 7 days

Noise 7 days

Uncovered burrow areas 15 days

Encroachment on natural resources 7 days

Waste disposal 7 days

Soil heaps on private property 7days

Social issues

Disruption of other existing public services e.g. hospitals 7 days

Historical sites 15 days

Cultural sites 15 days

Unwanted pregnancies 15 days

HIV issues 15 days

Child Labour 15 days

Family breakages 15 days

Annex 2: Land Acquisition Checklist

No. Complaint type Documents to request for

1 Non-payment

1. CopyofVerificationformOR Name, assessment number (that is the number beginning with KHMK01)

and amount of money Check batches – if payment was received, request for a copy of the

bank statement to verify (check payment dates against statement). If payment bounced, a forward complaint to accounts and copy land acquisition

*also crosscheck with items in No. 4 below*

2Not valued/not surveyed

1. Formal Complaint letter including neighbours on the left and right2. Visit with the Consultant and get comments

3 Undervalued1. Formal complaint letter2. Visit with the Consultant and get comments

4A land dispute between parties

1. Proof of land ownership (sales agreement or title)2. Court ruling (where applicable)3. Recommendation from CAO (where land belongs to the community/

government)

5. Notverified

1. Register name, village 2. Establish which valuation report they are in (Original/ Supplementary 1

or Supplementary 2). 3. Establish if the report they are captured in is being implemented or was

approved by CGV4. Get comments from the Consultant

6. Injurious affection1. Photographs showing damage2. Formal complaint letter

7. Extra land take 1. A formal letter indicating what was initially taken and the additional land

Note; Understanding the compensation process will also help one to quickly offer a solution to a PAP’s complaint. Below is a small illustration of the flow of activities;

Sensitization – Surveying – Valuation (Assessment) – Report preparation – Report Approval – Report implementation(VerificationofPAPS)–SubmissionofbatchestoUNRA–Review of batches in UNRA – Submission of batches to Accounts – Receipt of payment status from accounts

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Annex 4: Roles of different actors in Harmonized GRM

DESIGNATION ROLE REPORTING

Individuals including whistle-blowers

• Submit grievances -

GMC Secretary

• Receives grievance from complainant and record them in a logbook.

• Acknowledge receipt of written complaints • Arrange for GMC meetings to consider the grievances • Write minutes and circulate them to the members of

GMC and other stake holders. • Provide feedback information on the status of resolution

to the complainant

Report to GMC and responsible parties

GMC• Meet regularly to review and sort the road project related

grievances and where possible consider their solutions • Facilitate and mediate resolution of grievance

Report to Project manager

LG• LocalcouncilChairpersonisanex-officiomemberofthe

GMCLocal government Council

ClientCareOfficer

• Receive grievances• Operates the toll-free lines, social media, general email

account, and incoming mails addressed to the ED and/or without a clearly designated recipient.

Channel grievance to resident engineer or project manager

Contractor

• Appoint a sociologist and a health and safety professional responsible for engaging with local communities and addressing grievances arising from the work of the contractor

• Notify the resident engineer and UNRA’s grievance officerimmediatelyofanygrievancesthatrequireinvestigation or intervention by the police or other relevant authorities

Report to the Project Manager and Executive Director

Occupational Health & safety

Protective gear 30 days

HIV services 15 days

Road safety issues, accidents 2 days

Potholes 15 days

Narrow road sections 15 days

Dangerous bends 15 days

Drainage issues 7 days

Humps 15 days

Signage 15 days

Black spots 60 days

Markings 60 days

Cutting of pavement by utility companies 15 days

Street lights 7 days

Reflective ribbons 7 days

Barricades 5 days

Contractor issues

Equipment breakdowns 15 days

Delays at work zones 15 days

Late payments 21 days

Foreign exchange issues 7 days

Service Requests

Requests for prioritization of roads 7 days

Request to borrow or hire organization machinery or equipment

7 days

Request to include road sections previously not in the contract

7 days

Request for access roads 7 days

Information requests on all our services 7 days

Procurement 90 days

Ferry complaints 7 days

Overloaded vehicles 7 days

Road littering 7 days

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GrievanceOfficer

• Manage grievances, including proper logging, escalation, tracking, reporting and following up on all project specificgrievances

• Support investigation of a grievance as may be necessary

• Ensure remedial actions are taken by the contractor• Close the grievance for complaints satisfactorily

resolved

Report to respective UNRA Project Manager

UNRA Station Office

• Receive grievances on UNRA activities within their area of jurisdiction and: resolve the grievance; refer to the Regional Manager; escalate to a Project Manager; and/or refertotherespectiveofficeatUNRAHQ

Report to the Executive Director

UNRA Ferry or Weigh Bridge Manager

• Same as above Report to the Executive Director

UNRA Headquarters - Department of Environmental and Social Safeguard

• Control and assure the quality of the GRM process on Road Projects and extract lessons learned through their regular compliance review missions

Report to the Executive Director and TMT

UNRA Headquarters – Head Corporate Strategy

• AssignaMonitoringandEvaluationOfficertocontinuously monitor grievance management at the corporate level

• Continually monitor and evaluate the functionality of the harmonized GRM and regularly report to TMT regarding its functionality


UNRA Headquarters – Head Public and Corporate Affairs

• Generates corporate reports• AssignanofficertomaintaintheCorporateGrievance

Management Portal, which generates corporate reports and also keeps the public informed about the available GRM in UNRA.

• The Head PCA may from time to time publicize the resolutionstatusofspecificgrievances,whichmaybeofparticular interest to the general public


Resident Engineer

• Receive grievances from community members, regarding the different project activities and record in the logbook, and immediately issue an instruction for corrective action and also notify UNRA’s project manager for appropriate monitoring

• Assign the sociologist on the supervising team to track grievances and at all times include a section on grievance management in the monthly progress report

• Review grievance response and submit to project manager for Approval

• Submits approved solutions to Sociologist for presentation of response to complainant

Report to Project Manager

Contractor sociologist

• Work closely with the GMCs in agreeing to and implementing actions to resolve grievances

• Receive grievances, especially where there is no client careoffice

• Submit response to RE for review• Presents the approved response to complainant

Report to Contractor

UNRA Project Manager

• Assign one of the project team members the functions ofaGrievanceOfficer.

• Ensure proper logging, escalation, tracking, reporting and followinguponallprojectspecificgrievances

• Swiftly escalate any grievances that cannot be resolved at the project level or may pose a big reputational risk to the institution to the Executive Director

• Review grievance response to see if more action is required

• Notify UNRA HQs immediately of any grievances that require investigation or intervention by the police or other relevant authorities

• Escalate the grievance to Director / ED as may be required

• Returns approved grievance solutions to RE for further communication to complainant

Report to the Executive Director

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UNRA Headquarters - Directorate of Legal Services

• Dealing with legal matters related to UNRA with respect to grievances about contracts as well as claims that require legal resolution.


UNRA TMT• Overall supervision, guidance and endorsement of GRM

functionalityUNRA Board

UNRA Board• High level supervision and handling of political

complaints