grm p1 final[1]
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HOW-TO NOTESFeedback Matters:
Designing Effective Grievance Redress
Mechanisms for Bank-Financed Projects
Part 1: The Theory of Grievance Redress
DEALING WITH GOVERNANCE AND CORRUPTION RISKS IN PROJECT LENDIN
http://dfg
http://gacinprojec
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This note was prepared by David Post and Sanjay Agarwal o the World Bank’s Social Development Department
(SDV) as part o the eort by the Social Sustainability and Saeguards Practice Group, the Demand or Good
Governance Team, and the GAC in Projects team to provide guidance on ways to improve governance and
accountability in Bank operations. The authors are grateul to peer reviewers Steve Burgess and George
Soraya o the World Bank or their invaluable insights and comments. The authors would also like to thank Luiz
Alcoorado, Ivor Beazley, Elena Correa, Maninder S. Gill, Hélène Grandvoinnet, Elisabeth Huybens, Asmeen
Khan, Charles E. Di Leva, Albert Ninio, Ernesto Sanchez-Triana, Susan Wong, and other members o the Social
Sustainability and Saeguards Practice Group or additional comments.
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Feedback Matters Prt 1: T Tr Gr Rr 1
PaRT 1:The TheoRy
o GRievanceRedRess
T t Rm trt: wr tr gr trut r,
t pt w t t pl, t gr um utblt r wrk
t mt pru w pbl: t ur t r.
—Ml armtrg
As the World Bank’s governance and anticorruption (GAC) agenda moves orward,
grievance redress1 mechanisms (GRMs) are likely to play an increasingly prominent
role in Bank-supported projects (see Box 1). Well-designed and -implemented GRMs
can help project management signifcantly enhance operational efciency in a variety
o ways, including generating public awareness about the project and its objectives;
deterring raud and corruption; mitigating risk; providing project sta with practical
suggestions/eedback that allows them to be more accountable, transparent, and
responsive to benefciaries; assessing the eectiveness o internal organizational
processes; and increasing stakeholder involvement in the project. For task teams
more specifcally, an eective GRM can help catch problems beore they become more
serious or widespread, thereby preserving the project’s unds and its reputation.
This note aims to provide project teams with a better understanding o GRMs so
that they can help borrowers design GRMs that eectively collect and respond to
stakeholders’ inquiries, suggestions, concerns, and complaints.2 This Part 1 presents
the theory behind grievance redress; a companion note, Part 2, outlines a process
1. The terms grievance redress and complaints handling are used interchangeably throughout this note.
2. This note does not discuss employee grievance procedures or external non-project grievance redress mecha-
nisms (such as ministry-level grievance redress mechanisms, ormal judicial systems, or ombudsmen).
GRM r rgl rgz rtl tl r prmtg trpr
utblt Bk-f prt. T Qult aur Grup (QaG) r-
tl l Gac Bmrkg Lrg Rw tt t rp-
Bk-upprt prt t t Gac g. T rw u tt
GRM wr lu l 28 prt rw prjt. Mrr, m t
GRM wr tr rqur t mt wrtt rr gr r blg t
t gr pr wrtt bk. T QaG rprt lu tt
GRM r t mt uru m- gr tl t
tt “ mplt lg mm r t grw t t trumt r
Gac mtgt t wll mr rul g grtr ttt urg bt
prprt upr.” a t fg mtrt, tr mu rm r
Bk-upprt prjt t mpr prrm t rtl r.
Source: Qult aur Grup (2009)
box 1
T imprt GRM:
e rm Rt
QaG Rw
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2 How-to Notes
or designing an eective GRM. Both parts draw on examples rom World Bank-
supported projects.3
Grievance redress systems can be designed to unction at the project, sector, and
country levels; this note ocuses primarily on the project level. The GRM rame-
work presented here is equally applicable to both basic grievance redress systems
and those that are oriented to advanced inormation technology. In applying this
ramework, project managers must take into account the project’s unique operat-
ing context: or example, the size o the project management unit (PMU), types o
services delivered, benefciaries’ needs, and technical, fnancial, and human resource
constraints.
The ramework may be used either to design a new GRM or to improve the unction-
ing o an existing one. Box 2 provides a checklist that teams can use to assess theadequacy o existing GRMs.
3. Though it is preerable to draw on both notes when designing a GRM, parts 1 and 2 can also be used
separately.
T llwg qut wll lp tm wtr t GRM t wt
prjt utg up t t ull pttl. i t wr t t qut
n, tm ul r mprg t prjt’ GRM.
• d t prjt lr, rml, trprt trl mm (.g.,
gr rr ut, gr rr mmtt, gt gr
rr fr) rul r rg gr?
• d prjt fl rpbl r gr rr t utrt t tk r
m rml t?• ar fl rpbl r gr rr blg t tk t ll gr-
?
• d prjt-t ppl l tt t lg gr wtut r
rtlt?
• ar prjt bfr wr tr rgt t fl gr t gr-
rr pr grl?
• ar tr trl pr pl t rr, trk, mtr t gr
t t tk tm?
• d t GRM pr tml bk (wrtt r trw) t t pttr
t tk?
• i tr ppl pr pl tt GRM ur t r ttf wt w tr gr b rl?
box 2
ag t aqu
Prjt’ GRM
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Feedback Matters Prt 1: T Tr Gr Rr 3
T rmwrk
Figure 1
Gr Rr
Mm:
a rmwrk
BUILDING BLOCKS OF GRMs
Organizational
commitmentAnalysisProcessesPeoplePrinciples
Use M&E data to identify problems and improve
operational processes and performance
GRM VALUE CHAIN
Uptake(locations and
channels)
Monitor and
evaluate
Verify,investigate,
and act
Acknowledgeand
follow up
Sortand
process
Providefeedback
5 Assign GR tasks
and train staff
4Develop and
publicize
GR policies
2Estimate users and
assess available
resources for GRM
1Survey existing
formal and informal
GRMs
3Develop standard
operating
procedures/flowcharts
6Stimulate
external demand
for GRM
STEPS IN DESIGNING AN EFFECTIVE GRM
Eective GRMs typically have common building blocks and characteristics: multiple
grievance uptake locations and multiple channels or receiving grievances; fxed ser-
vice standards or grievance resolution; clear processing guidelines; and an eectiveand timely grievance response system to inorm complainants o the action taken.4
The design o eective GRMs should take into account the building blocks, the value
chain, and the steps involved in designing a GRM (Figure 1).
4. At the outset it is important to note that while GRMs can curtail corrupt practices, they are also useul or col-
lecting other types o data. For example, out o 2,300 grievances received by the Kecamatan Development Pro-
gram’s complaints handling unit, 40% were related to corruption while the other 60% were queries, comments,
or grievances related to the project’s general perormance.
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4 How-to Notes
Bulg Blk et GRM
Organizational
commitmentAnalysisProcessesPeoplePrinciples
Figure 2
Bulg Blk
et GRM
The structure that GRMs take is likely to vary rom project to project, depending on
the services delivered, the size o the PMU, and the needs o benefciaries. For ex-
ample, some projects may successully use a centralized grievance redress system,while others may decentralize or outsource the unction. Or there may be separate
units or dierent unctions, such as dedicated units or handling grievances rom
members o parliament or grievances about a particular program area. Whatever the
model, eective GRMs typically build on fve core building blocks (see Figure 2).
onznl cmmmn
The project’s management and sta recognize and value the grievance process as
a means o strengthening public administration, improving public relations, and en-
hancing accountability and transparency. Grievance redress is integrated into the
project’s core activities. Management makes the GRM part o the project’s “DNA”
by integrating grievance redress unctions into project stas’ job descriptions and
regularly reviewing grievances data and trends at project management meetings. 5
Management also ensures that the GRM is properly staed and resourced.
Pnpl6
Eective GRMs usually embody six core principles.
• Fairness. Grievances are treated confdentially, assessed impartially, and handled
transparently.
• Objectiveness and independence. The GRM operates independently o all
interested parties in order to guarantee air, objective, and impartial treatment
to each case. GRM ofcials have adequate means and powers to investigate
grievances (e.g., interview witnesses, access records).
• Simplicity and accessibility. Procedures to fle grievances and seek action are
simple enough that project benefciaries can easily understand them. Project
benefciaries have a range o contact options including, at a minimum, a telephone
number (preerably toll-ree), an e-mail address, and a postal address. The GRMis accessible to all stakeholders, irrespective o the remoteness o the area they
live in, the language they speak, and their level o education or income. The GRM
does not use complex processes that create conusion or anxiety (such as only
5. In large projects, this can also be done by having a dedicated GR unit headed by (or reporting directly to) a
senior project unctionary.
6. Adapted rom Kalahi-CIDSS Project (2003).
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Feedback Matters Prt 1: T Tr Gr Rr 5
accepting grievances on ofcial-looking standard orms or through grievance
boxes in government ofces).
•
Responsiveness and efciency. The GRM is designed to be responsive to theneeds o all complainants. Accordingly, ofcials handling grievances are trained to
take eective action upon, and respond quickly to, grievances and suggestions.
• Speed and proportionality. All grievances, simple or complex, are addressed
and resolved as quickly as possible. The action taken on the grievance or
suggestion is swit, decisive, and constructive.
• Participatory and social inclusion. A wide range o project-aected people—
community members, members o vulnerable groups, project implementers, civil
society, and the media—are encouraged to bring grievances and comments to
the attention o project authorities. Special attention is given to ensure that poor
people and marginalized groups, including those with special needs, are able to
access the GRM.
Ppl
Dedicated and passionate grievance redress personnel are essential to the success
o a GRM. The project provides training to the sta working on grievance redress so
that they can eectively carry out their roles. Generally speaking, sound recruitment
practices, continuous training and learning opportunities, and systematic review and
eedback regarding sta members’ perormance are important to the success o
GRMs. In large decentralized projects a special Grievance Redress Unit (including
feld units with dedicated personnel) may be required.
P
Grievance redress processes play an important role in project activities. Project man-
agement and sta outline and publicize the six stages o the “value chain,” discussed
in the next section.
anly
Project management regularly analyzes reports and other monitoring and evaluation
data on grievances. Grievance-related data provide management with insights into
the eectiveness o the PMU’s programs and are used to identiy problem areas,
improve internal processes, enhance service delivery, and reduce the incidence o
grievances in the uture.
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6 How-to Notes
T GRM vlu c
i’ ntl cmmut empwrmt Prgrm (nceP) w rt
mplt uptk lt, u mplt bk mmut rtrt,
p, -ml, txt mg (sMs), prjt wbt, prjt t, t w m,
rprt rm t iptr Br dlpmt Prrm. T sMs uptk
pt pr prtulrl t, lggg rg r 250 mplt
pr mt. i ttmt t t t, nceP’ GRM lgg rl 16,000
mplt, wt rlut rt r 99%.
box 3
i:
it Uptk
The grievance redress process, shown in Figure 3 as a value chain, comprises six
steps. It is important to consider all o these steps in detail when designing a GRM.
up
Uptake reers to the methods by which the project will collect grievances. Taking
into account technology, unding, and capacity constraints, the project should havemultiple uptake locations (at the community, village, district, provincial/regional, and
PMU levels, etc.) and multiple uptake channels (mail, e-mail, telephone, project web-
site, project sta, text messaging/SMS, strategically placed complaints boxes, etc).
Since the cost and complexity o GRMs increase with the number o potential uptake
locations, teams should choose uptake locations strategically based on the goals o
the project (see Box 3).
sn n Pn
Various types o grievances typically require dierent ollow-up actions—or example,
some grievances can be resolved by means o a simple explanation or apology,
while others may require more extensive investigations. Thereore, grievances need
to be categorized, assigned priority, and routed to the appropriate entity (see Box4). Moreover, standardized internal processes need to be established to guide how
grievances are logged. For example, in Indonesia’s NCEP, complaints that cannot be
resolved at one level o the system are reassigned to actors at higher levels (Figure
4). Higher levels o the project are also responsible or monitoring the complaints-
handling perormance at lower levels. Grievances can be logged either manually or,
i resources allow, by using a computer-based system that will allow the project to
identiy trends in the data across time and geographic locations.
Figure 3
T GRM vlu cUptake
(locations and
channels)
Monitor
and
evaluate
Verify,
investigate,
and act
Acknowledge
andfollow up
Sort
andprocess
Provide
feedback
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Feedback Matters Prt 1: T Tr Gr Rr 7
anlmn n Fll-p
When a complaint is made, the GRM should acknowledge its receipt in a communi-
cation that outlines the grievance process; provides contact details and, i possible,
the name o the contact person who is responsible or handling the grievance; andnotes how long it is likely to take to resolve the grievance. Complainants should
then receive periodic updates on the status o their grievances. The GRM needs to
establish clearly defned timetables or acknowledgment and ollow-up activities. To
enhance accountability, these timetables should be disseminated widely to various
stakeholders, including communities, civil society, and the media.
s prjt r w rg mplt, rgg rm llgt r-
rupt t mpl uggt qur, t mprtt t urtl tgrz
rt tp. i t Kl-cidss Prjt t Plpp, t GRM g
t rp t ur tp mplt: () mmt, uggt, r qur; (b)
mplt rltg t prrm prjt blgt; () mplt rr-
rg t lt lw /r rrupt; () mplt gt prjt t r
mmut mmbr l prjt mgmt.
box 4
ctgrzg cmplt
Figure 4
lw Gr
Rr
i’ nceP
Complaints/problems
Relevant actor at complainants level
Cross check/clarification
True False
Complaint handling
facilitation
Actors at
higher levels
Resolved Unresolved
Dissemination of complainthandling result to the community
Handling line
Monitoring line
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8 How-to Notes
Vfn, invn, n an
This step involves gathering inormation about the grievance to determine its validity,
and resolving the grievance. The merit o grievances should be judged objectively
against clearly defned standards. Grievances that are straightorward (such as que-
ries and suggestions) can oten be resolved quickly by contacting the complainant.
Grievances that cannot be resolved at one level o the system should be reerred to a
higher level and/or an outside entity or verifcation and urther investigation according
to a clearly defned timetable. Project sta should ensure that investigators are neu-
tral and do not have any stake in the outcome o the investigation. Potential actions
include responding to a query or comment, providing users with a status update, im-
posing sanctions, or reerring the grievance to another level o the system or urther
action. Generally speaking, the project should take some action on every grievance.
Mnn n evln
Monitoring and evaluation are critical to the success o any GRM. Monitoring reers
to the process o tracking grievances and assessing the extent to which progress is
being made to resolve them. Projects that serve a large number o citizens or bene-
fciaries—such as community-driven development, rural roads, water and sanitation,
health, education, or social protection projects—are likely to receive a large number
o grievances and should ideally have an electronic system or entering, tracking, and
monitoring grievances (see Box 5).
The project monitoring and evaluation inormation system should also include indica-
tors to measure grievance monitoring and resolution. These grievance redress indica-
tors can also be incorporated into project results rameworks (see Box 6).
Pakistan’s Punjab Rural Water Supply and Sanitation Project has developed a
credible mechanism to handle comments, suggestions, and grievances. The
mechanism includes a “monitoring system” database to monitor adherence to
the standards listed in the Procurement Manual. The database is designed as
an online instrument (with restricted access) that allows recording and retrieval
o all cases received, responses sent, dates o actions taken, and response
times.
box 5
Pkt:
crtg
Mtrg dtb
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Feedback Matters Prt 1: T Tr Gr Rr 9
Evaluation involves analyzing grievance data and using it to make policy and/orprocess changes to minimize similar grievances in the uture. Thereore, reports on
grievances data and trends (e.g., average time to resolve grievances, percentage o
complainants satisfed with action taken, number o grievances resolved at frst point
o contact)7 should be submitted regularly. Senior project management should moni-
tor grievance resolution data and grievance trends in their progress review meetings
and should randomly call complainants rom dierent areas and groups to get eed-
back on whether the GRM is unctioning eectively (see Box 7).
7. Reports to management also typically include such inormation as the number o grievances about a particular
issue, spikes in grievances, geographical spread o grievances, and characteristics o the complainants.
T mt mm gr rr mtrg tr tt prjt r-
prt tr rult rmwrk r t llwg:
• numbr mplt/ gr rgtr
• Prtg gr rl
• Prtg gr rr wt tpult tm pr
• Tm rqur t rl mplt (ggrgt b rt tp gr-
)
• Prtg mplt tf wt rp gr rr
pr
• Prtg prjt bfr tt t t GRM
box 6
Gr Rr
Mtrg itr
nceP t mmbr put mtrg lut t rtl t wbt
tt t PMU Wrl Bk t “rl-tm” t but t GRM. T
wb-b mgmt rmt tm t t u mplt
rmt, tl t , mt t prblm, pttl llw-
up t, w t gr w rl. Tu t tb t
rtul “ lbrr” pt gr, lg wt t bk rwr pr
t gr. hg t t rl-tm t llw prjt mgmt
t mr l t prblm r, qukl lz uggt mmt
but t prjt’ prrm, trtg t rllt rur
upgr pr t prtl f.
box 7
Rl-Tm Mtrg
elut
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10 How-to Notes
T r trut t GRM, t Rurl cmptt Prjt hur u
umbr mm t pr bk but gr rr, u
mtg gr rgtr publg gr r p
ull; prg t Bk wt mul rprt gr rr;
rtg rgl-ll tklr ultt mm t pr upt
t prjt’ prrm gr rr.
box 8
hur:
Prg Uul
bk
Pv F
The fnal step—inorming GRM users and the public at large about the results o in-
vestigations and the actions taken—enhances the visibility o the GRM among bene-
fciaries and increases users’ trust in the system (making it more likely that they will
lodge grievances). Projects can provide eedback by contacting the complainant
directly (i his or her identity is known) and/or posting the results o cases in high-
profle locations and conveying the results through radio broadcasts and other media
(see Box 8). The project should also inorm GRM users about their right to an appeal
i they are dissatisfed with the decision, speciying both internal and external (e.g.,
judicial review, ombudsman, line ministry) review options.
clu As the GAC agenda moves orward, GRMs are likely to be an increasingly impor-
tant component o Bank-supported projects. The eectiveness o GRMs rests on
three interconnected actors: ensuring a clear organizational commitment to griev-ance redress, creating well-designed internal processes or addressing grievances,
and tailoring the GRM to the unique operating environment. In addition to addressing
and resolving grievances, GRMs should be designed to serve as a conduit or solicit-
ing inquiries, inviting suggestions, and increasing community participation. (Figure 5
shows some o the most important “dos and don’ts” that project teams should keep
in mind while designing the processes encompassed in the GRM value chain.) To the
extent that projects are able to achieve success on these dimensions, GRMs can
provide operations with a wide range o benefts, such as curbing corruption, collect-
ing inormation that can be used to improve operational processes and perormance,
empowering vulnerable populations, and enhancing the project’s legitimacy among
stakeholders. Thus eective grievance redress systems represent a step towardgreater accountability and, ultimately, better project outcomes.
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Feedback Matters Prt 1: T Tr Gr Rr 11
Figure 5
GRM vlu c
d d’t
DO STAGE DON’T
• Create accessible uptake locationsand channels
• Maintain log books at various levels
to record all complaints, inquiries,
and suggestions received.
• Publicize uptake options/contact
information on communication
materials, in offices, etc.
• Clearly outline who is responsible for
handling different types of complaints
• Establish clear timetables for the
complaints-handling process
• Assign each complaint a unique ID
number
• Inform users about steps in the
complaints-handling process• Try to resolve the complaint at the
first point of contact
• Stick to agreed timetables for
responding to users
• Objectively evaluate the complaint’s
merit on the basis of facts
• Ensure that investigators are neutral
• Take action that is proportional to the
comment or complaint
• Signal importance of complaints-
handling putting topic as agenda
item for management meetings
• Establish a tracking system to record,
classify, and assess complaints
• Analyze grievance redress data andmake improvements
• Contact users to explain how their
complaint was resolved and how
they can appeal
• Publicize results of investigations to
enhance visibility of and increase
trust in the GRM
Uptake
Sort and
process
Acknowledge
and
follow up
Verify,
investigate,
and act
Monitor
and
evaluate
Provide
feedback
• Create barriers to complaining by making uptake processes time-
consuming or complicated
• Forget to take measures to ensure
that vulnerable groups are able to
access the GRM
• Leave any ambiguity about how
complaints are supposed to be routed
• Develop a GRM that does not
differentiate between different types
of complaints
• Divulge complainant’s identity to
others• T reat GRM users as if their complaint
is an inconvenience
• Expect users to prove they are right;
this is the purpose of an investigation
• Forget to update users on the status
of their complaint
• Appoint investigators that are biased
• Miss the opportunity to integrate the
GRM into the project’s management
information system
• View the resolution of complaints as
an end in itself—it is just a first step in
improving processes
• Neglect to follow up with users; this
undermines trust in the GRM
• Keep complaint results private; this
undermines transparency
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12 How-to Notes
Rr Rur
Asian Development Bank (2009). Handling Complaints Efciently. Manila: Asian Development Bank.
Commonwealth Ombudsman (2009). Better Practice Guide to Complaint Handling. Canberra: Common-
wealth o Australia.Kalahi-CIDSS Project (2003). “Guide to the Kalahi-CIDSS Complaints Handling System.” World Bank.
National Community Empowerment Project-Urban (2008). “Complaint Handling Unit.” PowerPoint pre-
sentation, July 2008.
World Bank Department o Institutional Integrity (2007). “Complaint Handling Systems.” PowerPoint pre-
sentation, Washington, DC.
World Bank Department o Institutional Integrity (2008). “Leveraging Complaints Handling in Projects.”
PowerPoint presentation, April 16, 2008, Washington, DC.
World Bank Quality Assurance Group (2009). Governance and Anticorruption in Lending Operations:
A Benchmarking and Learning Review. Washington, DC: World Bank.
atl GRMRur
The Social Development Department has compiled a comprehensive set o resources that task teams can
draw upon in developing a GRM:
Grievance Redress Mechanism Sel-Assessment Tool
GRM PAD Speak —a document that summarizes what various project PADs say about GRMs
Grievance Redress Indicators: a database o indicators on grievance redress used by dierent projects
Guide to the Kalahi–CIDSS Project Grievance Redress System
Checklist o Activities or Integrating Grievance Redress into World Bank Projects
Better Practice Guide to Complaints Handling
Inormation Typically Included on a Complaints Handling Form
Introduction to ISO 10002 (and Extended Version o Australia ISO 10002 with annexes)
Helping Local People Understand the Complaints Handling Mechanism
Tips or Making a Complaint
Ways to Present Complaints Data
The resources listed above are available online on the Social Development Department’s website at:
http://connect.worldbank.org/explore/SDV/DFGG/deault.aspx.
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