stakeholder engagement plan -...

REPUBLIC OF INDONESIA MINISTRY OF RELIGIOUS AFFAIRS

DIRECTORATE GENERAL OF ISLAMIC EDUCATION

REALIZING EDUCATION’S PROMISE: SUPPORT TO INDONESIA’S MINISTRY OF RELIGIOUS AFFAIRS FOR IMPROVED QUALITY OF

EDUCATION (P168076)

STAKEHOLDER ENGAGEMENT PLAN May 2019

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1

ABBREVIATIONS AND ACRONYMS

ADB Asian Development Bank

AMAN Aliansi Masyarakat Adat Nusantara (Indigenous Peoples' Alliance of the Archipelago)

CPF Country Partnership Framework

CSO Civil Society Organization

ECOP Environmental Code of Practice

ESCP Environmental and Social Commitment Plan

ESF Environmental and Social Framework

GRM Grievance Redress Mechanism

IAIN Institut Agama Islam Negeri (State Islamic Institute)

ICT Information and Communication Technology

IP Indigenous People

KAT Kelompok Adat Terpencil (Remote Adat Group)

KKG Kelompok Kerja Guru (Peer Working Group for Primary Teachers)

LMP Labor Management Procedure

MGMP Musyawarah Guru Mata Pelajaran (Peer Working Group for Jr and Sr Secondary Teachers, Subject-based)

MHA Masyarakat Hukum Adat (Customary Law Communities)

MoRA Ministry of Religious Affairs

NES National Education Standards

NGO Non-governmental organization

PAP Project Affected Persons

PIU Project Implementing Unit

SEP Stakeholder Engagement Plan

SOP Standard Operating Procedure

TPS

Tempat Pembuangan Sementara (Temporary Collection Facility)

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April 2019

1. INTRODUCTION AND PROJECT DESCRIPTION

Indonesia’s Country Partnership Framework (CPF) with the World Bank (2016–2020)

highlights the importance of equality of opportunity, getting reform priorities right, refocusing

public administration on better implementation, and building in more accountability and

transparency at the local government level to ensure better service delivery. There is a strong

focus on the importance of working in support of education, though this was originally

conceived in a context of decentralization, while the Ministry of Religious Affairs (MoRA) is a

centralized ministry. Engagement Area 4 of the CPF, Delivery of Local Services and

Infrastructure, includes Pillar 2 which specifically refers to an education project to ensure

universal access to education services that meet minimum quality standards.1

To fully realize Indonesia’s human capital potential, all students must have access to learning;

this is education’s promise. The Project aims to improve the MoRA’s ability to manage the

organization of education and improve teaching practices in the classroom. With the aim of

strengthening education services under MoRA, specific investments are proposed for roughly

50,000 primary and secondary formal education institutions nationwide under MoRA through

the following components:

• Component 1 - Nationwide implementation of electronic performance-based

budgeting system

• Component 2 - Implementation of a national, census-based student assessment in

4th grade.

• Component 3 - Continuous professional development for teachers and education

personnel

• Component 4 - Strengthen systems to support quality improvement

The Project activities are not expected to have significant impact on environmental and social

aspect. An assessment of the environmental and social impacts of each component can be

seen in section IV.

MoRA has prepared a Stakeholder Engagement Plan (SEP) and will implement it to ensure

that stakeholder engagement is conducted on the basis of timely, relevant, understandable,

and accessible information, in a culturally appropriate format. MoRA will ensure that both the

format and location of the consultations are inclusive and accessible. The SEP includes a

grievance redress mechanism (GRM) which will allow stakeholders, beneficiaries, and

employees working on the Project to raise potential concerns about the Project.

1 http://documents.worldbank.org/curated/en/195141467986374707/pdf/99172-REVISED-World-Bank-Indonesia-

Country-Partnership-Framework-2016-2020.pdf; page 32

http://documents.worldbank.org/curated/en/195141467986374707/pdf/99172-REVISED-World-Bank-Indonesia-Country-Partnership-Framework-2016-2020.pdf

http://documents.worldbank.org/curated/en/195141467986374707/pdf/99172-REVISED-World-Bank-Indonesia-Country-Partnership-Framework-2016-2020.pdf

3

The first draft SEP was disclosed on March 15, 2019, and is available at:

https://madrasah2.kemenag.go.id/read/20190315/293/draft-ecop-escp-dan-sep-mora-

kementerian-agama-tahun-2019. The draft SEP will be updated after the public consultations

and, as necessary, throughout the Project life cycle (preparation and implementation). During

first year of project implementation, the Project will conduct two consultations with

beneficiaries, particularly those who may be identified as IPs, vulnerable or disadvantaged

groups living below poverty line. First public consultation was held at MoRA office on April

23, 2019. The consultation was attended by 25 participants from the elements: Ministry of

Finance, Ministry of Environment and Forestry, Dinas Lingkungan Hidup, DKI Jakarta

Province, MoRA, CSOs: representative of Muhammadiyah and Ma’arif Nadhlatul Ulama. The

summary of the consultation, the list of attendees and the photos can be found in Annex 1.

The Project will do next consultation and involve interest groups such as non-governmental

organizations/civil society organizations (NGO/CSOs), representatives of teachers,

pengawas, principals, indigenous people (IP), and local communities during the

implementation of the Project.

2. SOCIAL ASSESSMENT

Social assessment aims to help MoRA understand key social issues and determine social

impacts on different stakeholders. Throughout the Project preparation and implementation, it

will use periodic consultations and outreach to determine needs and priorities of key

stakeholders to obtain their views on the design and proposed implementation mechanisms

of the Project, and to build capacity and involvement. Social assessment under the Project

will be a continuous process and will help make the Project responsive to social development

concerns that may arise during implementation. In particular, social assessment will aim to

assist MoRA in reaching the vulnerable and the poor and ensure that the Project objectives

are acceptable to the intended beneficiaries.

The World Bank will finance a package amount at an average of US$50 million per year or

1.43 percent of MoRA’s annual education budget. The Project will be for 5 years, with the

closing date currently set for December 31, 2024.

The Project activities will take place nationwide in 34 provinces. The Project activities are

related to improvement of (i) the planning and budgeting system, (ii) the student assessment

system, (iii) teacher competency, and (iv) the education data system. These activities are not

expected to result in any direct negative social impacts. However, many schools under MoRA

are located in remote areas of Indonesia, and communities in those remote areas are often

deemed as vulnerable groups. Their vulnerability can be seen in various ways, such as the

level of their income, which is often below the poverty line, and the lack of access to quality

education.

Under Component 1 (sub-component 1.4) will also an inclusion activity for medium

rehabilitation and repair works to support learning needs. Medium rehabilitation is defined as

repair of a portion of the non-structural components and/or repair of a portion of the roof,

ceiling, and/or floor of classrooms, libraries and laboratories. This civil works will do at existing

https://madrasah2.kemenag.go.id/read/20190315/293/draft-ecop-escp-dan-sep-mora-kementerian-agama-tahun-2019

https://madrasah2.kemenag.go.id/read/20190315/293/draft-ecop-escp-dan-sep-mora-kementerian-agama-tahun-2019

4

buidling and on existing land. Major physical rehabilitation and infrastructure works including

structural repairs to beams and coloumns will be explicitly excluded in the Project.

Project activities under Component 2 on the student assessment system and Component 3

on teacher competency improvement will likely cover schools where the vulnerable groups as

well as IPs may be present. Even though there are no negative impacts expected as per the

World Bank’s ESS7 (more information on Environmental and Social Framework [ESF] is

available in Section 2.1), the standard is still relevant to the Project since IPs may get direct

or indirect benefits from the Project activities.

Therefore, engagement and consultations by the MoRA PIU at the central level with

representatives of IP communities, school committee (representatives of student parents,

school/madrasah and local leader) for Project activities will be crucial. This central-level

consultation will take place at least as part of the mid-term review and as part of the project

completion process. Additional consultations may take place as needed and as informed by

Project monitoring.

2.1 INDIGENOUS PEOPLES

There is no universally accepted definition of IPs. In different countries, IPs may be referred

to by terms such as ‘Indigenous ethnic minorities’, ‘aboriginals’, ‘hill tribes’, ‘minority

nationalities’, ‘scheduled tribes’, or ‘tribal groups’. In ESS7,2 the term ‘Indigenous

Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities’ is

used in a generic sense to refer exclusively to a distinct social and cultural group possessing

the following characteristics in varying degrees:

(a) Self-identification as members of a distinct indigenous cultural group and recognition

of this identity by others; and

(b) Collective attachment to geographically distinct habitats, ancestral territories, or areas

of seasonal use or occupation, as well as to the natural resources in these areas; and

(c) Customary cultural, economic, social, or political institutions that are distinct or

separate from those of the mainstream society or culture; and

(d) A distinct language or dialect, often different from the official language or languages of

the country or region in which they reside.

In Indonesian, the term ‘Indigenous Peoples’ is often associated with Masyarakat Hukum Adat

(or MHA - Customary Law Communities) which is a common terminology used in Indonesian

laws and regulations to describe groups of people with similar characteristics as those of IPs

specified above. Ascertaining whether a particular group is considered as IP for the purpose

of this principle may require technical judgment from a social expert.

2 EES7 is the World Bank’s ESF relating to the policy for addressing impacts on IPs as result of an

activity/project funded by the World Bank. ESF is available at http://www.worldbank.org/en/projects-

operations/environmental-and-social-framework

http://www.worldbank.org/en/projects-operations/environmental-and-social-framework

http://www.worldbank.org/en/projects-operations/environmental-and-social-framework

5

MoRA does not have a database of the location of schools under its responsibility3 but location

of IPs in Indonesia is issued by the Ministry of Social Affairs in 2017–2019. The Ministry of

Environment and Forestry also issues a list of community forests belonging to IP. The

recognition by the state through the Decision of the Constitution Court (Mahkamah Konstitusi)

dated May 16, 2013, that state forest does not include customary forest requires further

consideration.

List of IP locations based on the three resource documents can be accessed through MoRA

website and is available at http:// …….

3. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT

ACTIVITIES

MoRA had a loan with Asian Development Bank (ADB) during December 2006 to February

2014 for the Madrasah Education Development Project. The project was implemented in three

provinces and 27 districts, with 500 madrasahs selected for upgrading—453 were private

madrasahs and 47 were public madrasahs. SEP was not available for the project because in

2006 it was not yet an ADB requirement.

During 2011–2015, MoRA collaborated with IAIN Sunan Ampel Surabaya to implement

curriculum development and selected lecturers were given their Doctorate and Master’s

degrees. This was part of the activities of the project for the Development and Quality

Improvement of the Institute for Islamic Studies (IAIN) Sunan Ampel Surabaya and also

supported the quality and relevance of the higher education institutions through activities such

as curriculum development and acquisition of equipment. However, SEP was not available for

the project.

3 Formal schools under MoRA include Buddhist schools, Hindu schools, Christian schools, and Kong Hucu

schools as well as Islamic schools (madrasahs). These schools follow the same curriculum as other schools in

Indonesia but spend additional hours on religious subjects in the national curriculum.

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4. ASSESSMENT OF POTENTIAL ENVIRONMENTAL AND SOCIAL

IMPACTS

Component Activity (based on the

readiness criteria)

Potential Environmental and

Social Impact

Inclusion in Environmental

and Social Commitment Plan

(ESCP)

Component 1

Nationwide

implementation of

electronic

performance-

based budgeting

system

▪ Support the

measurement of the

achievement of the NES

for MoRA schools

▪ Support and provide

technical assistance to

the districts and

provinces to analyse and

report data based on the

e-RKAM

▪ Support medium

rehabilitation & repairs

works for learning needs

on existing building and

on existing land

▪ Provide training for

implementation of

Component 1

▪ Hire individual specialist

consultant as e-RKAM

expert

▪ Hire event organizer for

organizing training

▪ Hire contractor for civil

works

▪ Minor environmental impact

▪ No social impact

▪ Need to hire consultants to

support operations of

Component 1

▪ Develop Labor

Management Procedure

(LMP) as guidance for the

Project Implementing Unit

(PIU) to recruit and select

the workers (consultants &

contractors)

▪ Develop SEP for

consultation with

stakeholders on the design

of the Project and

environmental & social risk

management

▪ Develop ECOP for medium

rehabilitation & repairs

works.

Component 2

Implementation of

a national, census-

based student

assessment in 4th

grade

▪ Assess student learning

in grade 4 using a

census- and paper-based

approach or, where

possible, a computer-

based test


implementation of

Component 2


consultant as learning

assessment expert


organizing training

▪ No environmental impact

▪ May be direct or indirect social

impact

▪ Yearly monitoring. The Project

can identify benefits for IP from

the results of yearly monitoring.

Need to review the overlap of

IP locations with school location

that conducts learning

assessment for 4th grade

students. However, field studies

are needed to check whether

the IPs in the list meet the

characteristics of ESS7 or they

belong to other groups, for

example, disadvantaged

students from poor families that

need further attention.

▪ Develop SEP for

consultation with


of the Project and


management, including

representatives from IP

communities, school

committee, NGO/CSOs

▪ Social impact assessment

at mid-term review and

completion of the Project.

Initial screening to identify

overlap of IP locations with

school locations that

conduct learning

assessment for grade 4

students

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▪ Need to hire labor to support

operations of Component 2

▪ Develop LMP as guidance

for PIU to recruit and select

the workers (consultants)

Component 3

Policy and

continuous

professional

development for

teachers, school

directors, and

supervisors

▪ Strengthen and expand

access to peer working

groups for teachers,

school directors, and

supervisors

▪ Develop, pilot, and roll

out face-to-face in-

service training sessions

for educational personnel

▪ Design and develop key

in-service training

courses, resources, and

materials in identified

areas

▪ Strengthen capacity of

key educational

personnel


implementation of

Component 3


consultant as teacher

capacity building expert


organizing training

▪ No environmental impact

▪ No direct but may be indirect

social impact and need for

yearly monitoring. Project can

identify indirect benefits for IP

from the results of yearly

monitoring. However, field

studies are needed to see (i)

whether the IPs in the list meet

the characteristics of ESS7 or

they if they belong to another

group that needs further

attention; and (ii) whether the

specific training methods

received by teachers in the

remote area can provide benefit

that can be applied in the class

or there are other benefits for IP

students.

▪ Need to hire labor to support

operations of Component 3.

▪ Develop SEP for

consultations with

stakeholders regarding the

design of the Project and



representatives of IP

communities, NGO/CSO

▪ Social impact assessment

at mid-term review and

completion of the Project.

Initial screening to identify

an overlap of IP locations

with school location for

teachers from the remote

area receiving training.



the workers (consultants).

Component 4

Strengthen

systems to support

quality

improvement

▪ Strengthen MoRA data

systems

▪ Provide grants to under-

performing MoRA to

encourage improved use

of finances to achieve the

NES

▪ Provide technical

assistance for additional

systems - strengthening

activities within MoRA


implementation of

Component 3


consultant as

management expert for

schools under MoRA


organizing training

▪ There are likely some activities

related to procurement of

information and communication

technology (ICT) software and

hardware for central, regional,

district, and provider levels,

however the Project is not

expected to generate

significantly more e-waste than

would be the case in absence

of the Project

▪ Need midyear and yearly

monitoring to evaluate

performance of e-waste

management

▪ No social impact



the workers (consultants).

▪ Develop Environmental

Code of Practice (ECOP)

as guidance for PIU in

managing e-waste properly

▪ Train PIUs on the

implementation of ECOP for

e-waste management

▪ Develop SEP in

consultation with


of the Project and



representatives of interest

groups on e-waste

management.

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5. STAKEHOLDER IDENTIFICATION

To define a communication process with the stakeholders, several groups that may be

interested and/or affected by the Project implementation have been identified. There are

a number of groups of people and social groups who are interested in the Project on

different levels. In particular for this Project, these may be identified as people, social

groups, and organizations who will directly or indirectly benefit from the Project. This

includes Cluster Working Groups for Teachers and Principals, Subject Matter Teacher

Consultative Group, Group for Principals, School Committee, Representatives of IP, and

so on.

Agencies who may influence and make decisions on implementation of the Project and/or

may have an interest in the Project include governmental entities such as MoRA (at

provincial and district/city level), Ministry of Finance, Bappenas, and Ministry of

Environment and Forestry.

The main groups of stakeholders identified so far are listed in the table below. The list can

be updated and modified during the Project implementation.

Level of Stakeholder Interest/Involvement in the Project

Stakeholders who may directly or indirectly

benefit from the Project Role

MoRA - Carry out the Project activities to improve (i) planning and

budgeting system, (ii) student assessment system, (iii) teacher

competency, and (iv) education data system.

- Monitor on a regular basis and provide semester and annual

implementation report of the Project

- Prepare a Project Manual for ECOP/SPPL to handle unused

equipment (if any) by recycling, trade in to the vendors, or to

dispose them properly as per Indonesian regulations on e-

waste

- Monitor progress of e-waste management and report about it in

the semester report (as part of the midyear implementation

report)

- Prepare a ECOP/SPPL for medium rehabilitation and repair

works of classrooms, librarries, laboratories.

Ministry of Environment and Forestry Issue permit for licensed company eligible for disposing or

recycling e-waste

Ministry of Finance - Provide approval for annual planning and budget

- Part of Steering Committee will monitor the performance and

accountability of the Project

- Provide verification whether e-waste can be abolished from the

list of state-owned assets by means of recycling or disposing e-

waste or trade in to the vendors.

National Planning Body (Bappenas) - Provide approval for annual planning and budget

- Part of Steering Committee will monitor the performance and

accountability of the Project

Dinas Lingkungan Hidup dan Kebersihan

Kabupaten/Kota

Provide Temporary Collection Facility (Tempat Pembuangan

Sementara/TPS)

2

Stakeholders who may directly or indirectly

benefit from the Project Role

Regional office of MoRA at provincial level

(Kanwil Kemenag Provinsi)

- Host the implementation of Component 3 for teachers from

remote areas

- Conduct field supervision of implementation

- Prepare quarterly, midyear, and annual designated activity

reports and send to PIU

- Involve in public consultation of the SEP

MoRA office at district/city level (Kantor

Kemenag Kabupaten/Kota)

- Conduct field supervision of implementation

- Prepare the quarterly, midyear, and annual designated activity

reports and send to PIU


Provincial government (People’s Welfare

Division under Secretariat of Governor Office)

Involve in public consultation of the SEP

District/city government (People’s Welfare

Division under Secretariat of Bupati/Mayor

Office)


School Committee (representatives of student

parents, madrasah, and local leader)


Representatives of teachers from remote

areas


- Involve in monitoring and evaluation

Representatives of IP communities - Involve in public consultation of the SEP

Representatives of KKG - Involve in public consultation of the SEP

Representatives of MGMP - Involve in public consultation of the SEP

Representatives of Pengawas Group - Involve in public consultation of the SEP

Representatives of Kepala Sekolah Group - Involve in public consultation of the SEP

NGO/CSO in Jakarta and city level - Involve in public consultation of the SEP

6. COMMUNICATION METHODS WITH STAKEHOLDERS

A variety of methods of communication with the stakeholders will be carried out at three

levels: Jakarta, province/district/city, and at the school or village level. The purpose of

using various methods with each stakeholder group is to ensure easy, transparent, direct,

open, and interactive communication with all stakeholders and to get feedback during the

Project preparation and implementation phases. For the remote stakeholders, it may be

necessary to provide for separate meeting or additional documents such as summary

documents and reports that should be placed in the public domain, such as meetings,

official correspondence, or MoRA office at district/city.

3

The methods used may vary according to the target groups, for example,

• Regular meetings within government institutions (at central and

province/district/city level)

• Interviews with representatives of IP communities and relevant organizations

• Public meetings (at province, district/city, village), workshop, and/or focus group

on specific topics

• Survey, questionnaire

Engagement and consultations with workers will also be considered. To operate the four

components optimally, the Project requires workers. It is expected that all workers are

from the Indonesian labor force. The requirement for workers will be outlined in the LMP

as guidance for the PIU to recruit and select the workers.

In view of environmental and social impacts, the Project activities under Component 1,

sub-component 1.4 will involve civil works or construction. This is medium rehabilitation

and repair works of classrooms and other learning support rooms such as libraries and

laboratories. The type of construction is simple construction works and not a multi-year

project. All the civil works will be conducted on existing building and land. Therefore it

could not have an adverse impact to the social but may minor impact to the environment.

The Project Operation Manual will include simple guidance on how to monitor the activity

of medium rehabilitation and repair works.

Under Component 4 Improve Education Data Management System, there will be some

activities related to procurement of ICT software and hardware for central, regional,

district, and provider levels. The Project is not expected to generate significantly more e-

waste than would be the case in absence of the Project. In addition, most of the ICT

procurement is planned to be virtual (such as the purchase of a small number of servers

which may be virtual, for example, Amazon or MS Cloud in the case of cloud servers). The

Project Operations manual will include some simple technical guidelines (ECOP) on how

to handle the unused equipment (if any) by recycling, trade in to the vendors, or to dispose

them properly as per Indonesia regulations on e-waste. In addition, energy efficiency could

also be introduced during procurement and use of equipment (energy-saving PCs, and so

on). Lastly, training program for ECOP implementation and procurement for PIU staff at

the provincial and district MoRA offices who are responsible for the procurement and

disposal of electronic equipment and for the purchase of energy-saving equipment. This

will be part of the Project Operations Manual and training and development plan at

provincial/district level.

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7. RESOURCES AND RESPONSIBILITIES FOR IMPLEMENTING

STAKEHOLDERS ENGAGEMENT ACTIVITIES

The Project will establish the PIU with a Project Director under the responsibility of the

Directorate General for Islamic Education, MoRA. This PIU will engage and cooperate with

stakeholders to build and maintain a constructive coordination/relationship with them. All

members of the PIU are representatives within MoRA.

Implementation of the SEP will be covered by MoRA funds under the control of the Project

Director.

The main task of the PIU Central is to be responsible for the overall project

implementation, resolution of problems with the Project, and collaborating with the

Steering Committee.

The PIU Central will work with the PIU Province for achieving communication with the

MoRA office at the district/city level and other stakeholders and will use these to:

• Provide updates and keep stakeholders/public informed on progress of the

Project.

• Inform relevant stakeholders about grievance mechanism and procedures as

detailed within this SEP and receive any grievances and complaints from public

in accordance with the grievance procedure discussed in Chapter 8.

• Consult with interest groups and ensure that consultations are inclusive and

accessible both in format and location according to the characteristics of these

group. As necessary, representatives of IP communities will be adjusted to the

location where the schools under MoRA are located.

Annex 1 provides a list of KAT4 based on the list of IPs in 2017–2019 published by the

Ministry of Social Affairs and the location of Hutan Rakyat belonging to IPs issued by

Ministry of Environment and Forest and the list of IP according to AMAN.5

All individual meetings will be undertaken by the PIU and all outcomes agreed through the

individual meetings will be recorded and documented by the PIU in the Project Office in

Jakarta. The objective of such meetings is to review, agree, and implement the monitoring

and evaluation related Project activities.

4 The Ministry of Social Affairs uses the term/characteristic IP as KAT= Kelompok Adat Terpencil (Remote

Adat Group). 5 AMAN = Aliansi Masyarakat Adat Nusantara (Indigenous Peoples' Alliance of the Archipelago). AMAN is

an Indonesian indigenous peoples' human right and advocacy organization founded in 1999.

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8. PUBLIC DISCLOSURE

Documentation and information on updates from the Project activities and the result of

consultation with stakeholders will be disclosed by PIU in some places:

• MoRA website → https://kemenag.go.id. A web page for the Project will be

created at the start of the Project.

• Project Office/PIU Office, Direktorat Jenderal Pendidikan Islam, Gedung

Kementrian Agama, Lt 6, Jl. Lapangan Banteng Barat No 3-4, Jakarta Pusat.

9. GRIEVANCE REDRESS MECHANISM

Transparency and accountability are the core elements of the Support to Indonesia's

Ministry of Religious Affairs for Improved Quality of Education Project. For this purpose,

the Project will include a GRM. The goal of the GRM is to strengthen accountability to

beneficiaries and to provide channels for Project stakeholders to provide feedback and/or

express grievances related to Project-supported activities. The GRM is a mechanism that

allows for the identification and resolution of issues affecting the Project. By increasing

transparency and accountability, the GRM aims to reduce the risk of the Project

inadvertently affecting citizens/beneficiaries and serves as an important feedback and

learning mechanism that can help improve Project impact.

The mechanism focuses not only on receiving and recording complaints but also on

resolving them. While feedback should be handled at the level closest to the complaint, all

complaints should be registered and follow the basic procedures set out in this chapter.

GRM is a process for receiving, evaluating, and addressing Project-related complaints

from citizens and affected communities at the level of the Project.

The design of the Project-level GRM will build upon the existing system of handling

complaints. The design of the GRM is described below.

9.1. DEFINITION OF GRM

For the purposes of these operational guidelines, GRM is a process for receiving,

evaluating, and addressing Project-related complaints from citizens and affected

communities at the level of the Project. The terms ‘grievance ‘and ‘complaint’ are used

interchangeably.

9.2. GRM SCOPE AND USE

Scope: GRM will be available for Project stakeholders and other interested parties to

submit questions, comments, suggestions and/or complaints, or provide any form of

feedback on all Project-funded activities.

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GRM’s users: Project beneficiaries, project-affected people (that is, those who will be

and/or are likely to be directly or indirectly affected, positively or negatively, by the Project),

as well as the broader citizenry can use the GRM for the above purposes (see Scope).

GRM’s management: The GRM will be managed by MoRA’s PIU, under the direct

responsibility of the Project Director

Submission of complaints: Complaints can be submitted at any time throughout Project

implementation.

9.3. PROCEDURES

Channels to make complaints

MoRA will establish the following channels through which citizens/beneficiaries/Project

Affected Persons (PAPs) can make complaints regarding project-funded activities:

(a) Social media: Twitter, Facebook (will be ready before the Project starts)

(b) By Email: Project’s email addresses (will be ready before the Project starts)

(c) By writing to the Project/PIU Office: Direktorat Jenderal Pendidikan Islam,

Gedung Kementrian Agama, Lt 6, Jl. Lapangan Banteng Barat No 3-4, Jakarta

Pusat.

(d) Hotline number: This will be ready before the Project starts (can be text - WA or

SMS)

The Project shall ensure flexibility in the channels available for complaints, as well as

ensure access to the contact information for individuals who make complaints.

Confidentiality and conflict of interest

Complaints may be made anonymously, and confidentiality will be ensured in all instances,

including when the person making the complaint is known. For this reason, multiple

channels to make a complaint have been established and conflicts of interest will be

avoided.

Receipt and recording of complaints

The person receiving the complaint will complete a grievance form (see Annex 2) and will

record the complaint in the Register of Complaints, which the GRM manager oversees.

The complaint is to be submitted immediately in the tracking system for sorting and

redirecting to the appropriate department responsible for investigating and addressing the

complaint, or to the staff if the complaint is related to a specific Project activity. The Project

Director is responsible for determining who to direct the complaint to, whether a complaint

requires an investigation (or not), and the timeframe to respond to it.

When determining who will be the investigating officer, the Project Coordinator should

ensure that there is no conflict of interest, that is, all persons involved in the investigation

7

process should not have any material, personal, or professional interest in the outcome

and no personal or professional connection with complainants or witnesses.

Once the investigation process has been established, the person responsible for

managing the GRM records and enters this data into the Register of Complaints.

The number and type of suggestions and questions should also be recorded and reported

so that they can be analyzed to improve Project communications.

Review of received complaints or/and inquiries

The complaint shall be examined within 10 working days of its receipt. The person

responsible for investigating the complaint will gather facts to generate a clear picture of

the circumstances surrounding the grievance. The investigation/follow-up can include site

visits, review of documents, and a meeting with those who can resolve the issue.

The results of investigation and the proposed response to the complainant will be

presented for consideration to the Project Coordinator, who will decide the course of

action. Once a decision has been made and the complainant informed, the investigating

specialist describes the actions to be taken in the grievance form (see Annex 2), along

with the details of the investigation and the findings and submits the response to the

Project Director for signing.

Response to complainant

The complainant will be informed about the results of verification via letter, email, or by

post, as received. The response shall be based on the materials of the investigation and,

if appropriate, shall contain references to the national legislation.

The deadline for investigating the complaint may be extended by 10–30 working days by

the Project Coordinator, and the complainant is to be informed about this fact, whether:

(a) additional consultations are needed to provide response to the complaint;

(b) the complaint refers to a complex volume of information and it is necessary to

study additional materials for the response.

9.4. AWARENESS BUILDING

Information provided in an accessible format

Information about the GRM will be available on the https://kemenag.go.id website and will

be included in communications with stakeholders.

9.5 STAFFING AND CAPACITY BUILDING

Tasks and responsibilities of the PIU team on the GRM

The Project Director will allocate responsibilities to the PIU staff. These will be documented

in the Project Operations Manual, and kept updated.

https://kemenag.go.id/

8

• Overall management of the GRM system

• Developing and maintaining awareness-building

• Collection of complaints

• Recording complaints

• Notification to the complainant on the receipt and timeline to review a complaint

• Sorting/categorization of complaints

• Thorough examination of the issues, including the causal link between Project

activities and alleged damage/harm/nuisance

• Decision making based on such examination

• Processing appeals or continuous communication with complainants with the

purpose to resolve issues amicably

• Publishing responses to complaints, unless otherwise requested by complainants

due to privacy or other concerns

• Organization and implementation of information materials and awareness

campaigns

• Reporting and feedback on GRM results.

9.6 TRANSPARENCY, MONITORING, AND REPORTING

Transparency

Policies, procedures, and regular updates on the GRM system, the complaints made and

resolved, will be available on https://kemenag.go.id web page. They will be updated on a

midyear basis.

Regular internal monitoring and reporting

The PIU will assess quarterly the functioning of the GRM to:

• Provide a monthly/quarterly snapshot of GRM results, including any suggestions

and questions, to the Project team and the management.

• Review the status of complaints to track which are not yet resolved and suggest

any needed remedial action.

During quarterly PIU meetings, the Project team shall discuss and review the effectiveness

and use of the GRM and gather suggestions on how to improve it.

Reporting in midyear and annual progress reports submitted to the World Bank

In the midyear and annual Project implementation reports submitted to the Bank, MoRA

shall include a GRM section, which provides updated information on the following:

https://kemenag.go.id/

9

• Status of establishment of the GRM (procedures, staffing, awareness building, and

so on);

• Quantitative data on the number of complaints received, the number that were

relevant, and the number resolved;

• Qualitative data on the type of complaints and answers provided, issues that are

unresolved;

• Time taken to resolve complaints;

• Number of grievances resolved at the lowest level, raised to higher levels;

• Any particular issues faced with the procedures/staffing or use;

• Factors that may be affecting the use of the GRM/beneficiary feedback system;

• Any corrective measures adopted.

10. MONITORING AND REPORTING

Midyear and annual progress report on the Project activities will be available at the Project

office and available on the MoRA web page: https://kemenag.go.id. The specific web page

for the Project will be established before the Project starts.

10

Annex 1: The Summary of Public Consultation on April 23, 2019

Summary of Public Consultation

Madrasah Education Quality Reform Project

23 April 2019, Jakarta

No Time Venue Participants Key issue raised during the

consultation

How the issues will be addressed

in the SEP, ECOP, LMP & Soc

Impact Assessment

1 23 April

2019, jam

09.00 –

11.00

Ditjend PendIs

Room, MoRA

Office

Attended by 25

participants from the

elements:

• Ministry of Finance

• Ministry of Environment

and Forestry

• DKI Jakarta Province (Environmental Services)

• Coordinating Ministry of Human and Cultural Development

• MoRA (relevant Directorates)

• CSOs: Muhammadiyah and Maarif Nahdlatul Ulama (NU)

• The World Bank

Remarks from Director General of Pendidikan Islam:

- Indonesia in the future is highly dependent on quality human resources,

therefore the quality of education must continue to be improved.

- Ministry of Religion already knows its weaknesses and weaknesses in managing

education. One reason is limited budget.

- MoRA conducts an exit strategy to address quality education funding through

collaboration with the World Bank.

- Positive support has been provided by Bappenas and the Ministry of Finance

and is currently awaiting administrative requirements from Bappenas and the

Ministry of Finance to immediately negotiate with the World Bank.

11


consultation



Impact Assessment

The consultation was open

by Director General of

Pendidikan Islam. The

consultation moderated

and closed by Director of

KKSK

Madrasah schools under Muhammadiyah

also have limited facilities and

infrastructure, and even many madrasahs

are poor in education facilities in

accordance with quality standards. Does

the Project pay attention to this?

The project does not specifically build

facilities and infrastructure.

Component 1 indirectly provides

development of facilities &

infrastructure. Each school through e-

RKAM must conduct a self-assessment

to plan the use of BOS.

Teachers should not only be given

knowledge of teaching materials but also

learning related to the care of the

surrounding environment, especially for

those who live in remote areas, coastal

such as getting children to wash their

hands before eating, getting children to

brush their teeth in the morning.

Good input and will be considered in

developing learning modules.

Need also to encourage “sekolah ramah anak”/ children friendly school- At the moment some awareness have been made for teachers

12


consultation



Impact Assessment

Maarif NU welcomed the plan to improve

the quality of madrasah education. What

is the model of cooperation in managing

e-waste?

The Project will do public campaign

through distributing poster E-COP and

location of Drop Point

The Project will provide capacity

building for PIUs, districts/cities,

schools in managing e-waste.

Electronic waste is specific waste which is

categorized as B3 waste and requires a

Drop Box. For the DKI area, Dropping

Points have been provided for

transportation by licensed companies.

The Project has been taking care

about e-waste through E-COP.

DKI Jakarta has provided Drop Box in

some schools and universities. Need

information the estimation volume of

each location from Component 4 in

Jakarta area. This is to anticipate the Drop

Box capacity when it is full, e-waste will

be taken by a licensed company.

Good information and very useful. The

Project through PIU will follow up and

need data the location of Dropping

Points in Jakarta Province from Dinas

LH under DKI Jakarta.

So far education data in DG Pendis is very

difficult to be accessed by the public,

including by government agencies. The

existing EMIS, Simpatika applications are

updated. It is highly expected that

through Component 4 the existing

Through Component 4 the Project will

make improvements to data and

applications. Existing systems (such as

EMIS and Simpatika) will be integrated

with the latest applications and data.

The Project will open access to

13


consultation



Impact Assessment

applications will be synergized with new

applications and the data will be up dated

according to existing conditions and easily

accessible to all parties.

information for the public, including

data on teachers, students and

madrasahs/schools that have received

training or assistance from the Project

and regular project reports and other

information relating to the operational

of the Project.

For the grievance redress mechanism

will be opened various accesses

through:

• twitter, facebook (will be ready before the Project starts)

• Email: Project’s email address (will be ready before the Project starts)

• Kantor Proyek/PIU, Direktorat Jenderal Pendidikan Islam, Gedung Kementrian Agama, Lt 6, Jl. Lapangan Banteng Barat No 3-4, Jakarta Pusat.

• Hotline number: can be text through WA or SMS (will be ready before the Project starts)

Data on education in MoRA is very

minimal and the level of use of the budget

is also still low. This is one of the

constraint in related to providing BOS

Agree, Component 4 is designed to

solve those problem as well as

Component 1 through e-RKAM.

14


consultation



Impact Assessment

support. Hopefully with Component 4

there is a significant improvement in data

and is able to use the budget properly.

If the Project start in 2019 please be sure

MoRA has proposed allocation proper

budget to MoF to cover activities in 2019

till 2024.

The Ministry of Religion has proposed

a project budget that is not too large

for 2019. The budget for project

launch activities and the formation of

a Project Team (functional team) while

the budget for 2020 and so on

requires a larger allocation than the

first year.

Closing:

1. MoRA will do bigger public consultation to discuss more detail on substance 2. Involving more CSO, not only NU and Muhammadiyah 3. Also to involve professional such as teacher association – to get input from

education perspective

15

The list of attendees of the Public Consultation, April 23, 2019

18

Public Consultation on April 23, 2019

20

ANNEX 2: GRIEVANCE/INQUIRY RECORD

GRIEVANCE/INQUIRY RECORD (Form A)

Instructions: This form is to be completed by staff receiving the inquiry or grievance and kept in the Project’s file. Attach any

supporting documentation/letters as relevant.

Date Grievance Received:

Name of Staff Completing Form:

Grievance Received (check √):

□ National □ City/Town □ Municipality □ Village

Mode of Filing Inquiry or Grievance (check √):

□ In person □ Telephone □ E-mail □ Phone Text Message □ Website

□ Grievance/Suggestion box □ Community meeting □ Public consultation □ Other ______________

Name of Person Raising Grievance: (information is optional and always treated as confidential)

Gender: □ Male □ Female

Address or contact information for Person Raising Grievance: (information is optional and confidential)

Location where grievance/problem occurred [write in]

National:

Town/City: Province: Village:

Brief Description of Grievance or Inquiry: (Provide as much detail and facts as possible)

Category 1 Social Safeguards

Category 2 Environmental Safeguards

Category 3 Grievances regarding violations of policies, guidelines and procedures

Category 4 Grievances regarding contract violations

Category 5 Grievances regarding the misuse of funds/lack of transparency, or other financial management concerns

Category 6 Grievances regarding abuse of power/intervention by Project or government officials

Category 7 Grievances regarding staff performance

Category 8 Reports of force majeure

Category 9 Grievance about Project interventions

Category 10 Other

Who should handle and follow up on the grievance:

Progress in resolving the grievance (e.g answered, being resolved, settled):

stakeholder engagement plan -...

Documents