In the context of this section, a grievance refers to a complaint from an external stakeholder. The grievance process outlined in this section aims to manage complaints from external stakeholders. Grievances from a local employee about conditions of work on site should be handled through the company’s internal human resources processes. However, if a suitable operational level employee grievance mechanism is not in place at a site, the grievance mechanism described in this section may be used by employees as a channel to raise concerns. In such situations the grievance should be referred to the HR team to address and close out.

A grievance expressed by an employee about an environmental impact in his/her community would be addressed through the grievance process; i.e. an employee may also be considered an external stakeholder when he/she is also a community member. The line of accountability depends on the principal role the person is assuming and the nature of the grievance he/she is making when lodging the complaint – employee or community member.

This section provides guidance on effective management of grievances from external stakeholders and on incidents that have social consequences, aligned with both IFC Performance Standards (IFC PS) and the United Nations Guiding Principles on Business and Human Rights (UNGPs).

Specifically, this section provides guidance on:

• definitions and explanations of incidents and grievances
• developing a grievance management procedure
• developing a Learning from Incident procedure
• incident classification and categorisation
• investigating incidents
• resolution of grievances.

Intended users

This section is primarily intended for the Social Performance team. Incidents and grievances, however, may result from the actions or behaviour of any site department, and all site departments should be able to self-report incidents and grievances. Accordingly, all site employees and on-site contractors should familiarise themselves with this section as they may become involved in recording and responding to grievances or investigating incidents.

Relevance to other sections

Incident and grievance management touches on all aspects of social performance. The grievance process itself is most closely tied to Stakeholder Engagement (Section 3A), and incident management is linked to the Social and Human Rights Impact and Risk Analysis (Section 3C).

• Governance (Section 1)
  • Section 1 provides an overview of the Social Performance Management Committee (SPMC). The SPMC provides the internal forum to raise and discuss incidents and grievances, as well as determine remediation measures if and as necessary.
• Review and planning (Section 2)
  • The baseline assessments and context review, updated as part of sites’ five-year social performance planning, provide the information required to determine the design of the grievance process. The context review also includes a review of trends around grievances and incidents.
• Engagement and analysis (Section 3)
  • Stakeholder Engagement – consultations with stakeholders are essential in ensuring the grievance process is appropriately designed, understood and trusted.
  • Social and Human Rights Impact and Risk Analysis – grievances and incidents provide an important source of information on risks and (potential) adverse impacts.
• Impact and risk prevention and management (Section 4)
  • Grievances and incidents may arise in relation to contractor social management, community health and safety management, emergency preparedness and response, security management and the Voluntary Principles on Security and Human Rights (VPSHR), land access, displacement and resettlement, site-induced migration, cultural heritage, indigenous peoples, conflict management and artisanal and small-scale mining management, as well as about socio-economic development opportunities. Investigation results should inform improvements to mitigation measures and controls.