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Investigating a grievance is the same as investigating the actual or potential incident associated with the grievance.

The guidance provided in this section is not stand-alone and should be read alongside the S&SD Standard on Learning from Incident.

All incidents (i.e. independent of type and consequence level) should be investigated according to the S&SD Learning from Incident Standard, which follows the Learning from Incidents process.

Undertaking an investigation provides for a better understanding of the causes of unwanted events. Incident investigation is therefore an important tool to help analyse, review, refine and improve social and human rights impact and risk identification and management.

Logging incidents

All incidents should be logged, in addition to logging all grievances. (See 3B Task 7).

Self-observed incidents

Actual or potential incidents that are self-observed, i.e. that have not been brought to the site’s attention via the grievance mechanism, should be categorised, a consequence level assigned, and internal stakeholders notified as per the S&SD Standard on Learning from Incident and the site’s Learning from Incident Procedure. For self-observed incidents, the LFI process should be followed.

LFI Team Composition

The required LFI team composition by consequence level is outlined in the S&SD Learning from Incident Standard.

Where multiple consequence types are involved (for example, social, environmental, reputational, and safety), and/or where an incident or grievance has non-social causes (for example, environmental, safety, or labour-related), then the LFI team should reflect this in terms of knowledge and skills.

Involving Legal

Before starting the LFI investigation process, sites should inform the Legal team of the grievance/(actual or potential) incident. The Legal team will assess whether there are any legal risks that should be considered and provide guidance for the investigation process. 

LFI tools to be used

The S&SD Learning from Incident Standard lists the investigation tools that should be used, depending on the severity classification/consequence level.

Incident reporting

For all incidents, an incident report should be developed in accordance with the S&SD Learning from Incident Standard and associated templates.

For actual or potential Level 4 and 5 incidents, an Alert 1, Investigation Report, and Alert 2 must be prepared and submitted according to the S&SD Learning from Incident Standard and associated templates.

Incident action plan, sharing and learning

Any specific findings from the investigation that require action must be captured in an action plan, which must be tracked at site level until completion. The site is responsible for ensuring that all actions stemming from an incident investigation are closed-out in a timely fashion.

Findings from incident investigations should be shared across the Group in order to prevent similar social incidents from occurring elsewhere in the business. The site’s Social Performance business partner should be informed in order to help share the learnings, including via Global Calls to Action as appropriate.

Box 3B.9 Independent or participatory investigations

In certain cases, sites should consider recommending an independent process that is led by a credible institution or organisation, or inviting respected individuals to participate in the investigation. This not only builds confidence but also may be the best way of getting to the facts of what occurred. Independent assessments can also be useful in dealing with technical issues, such as concerns over environmental impacts.

The decision to proceed with independent or participatory processes should be discussed at the Social Performance Management Committee (SPMC) and approved at BU or Group level.

3B.2 Guidance | Do
3.Engagement and analysis  |  3B Incident and grievance management  |  3B.2 Guidance  |  Do