3B.3 Management and resources

One senior staff member from the SP team should have overall responsibility for the communication, co-ordination and functioning of the grievance process, although at large sites the person may not need to be personally involved with the handling of every grievance.

Even though grievances are co-ordinated by the SP teams, all departments need to understand the grievance process and their role in it. Operational and technical teams should be trained in the key components, commitments and lines of communication to ensure that responsibilities are met.

Sites should ensure that enough social performance staff are trained on LFI so that they are able to conduct LFI investigations for incidents of all consequence levels.

All site functions need to collaborate with the SP teams to undertake the following key activities:

help communicate the grievance process to the stakeholders they engage with as part of their work activities
follow the established procedures for reporting incidents and grievances
participate in the investigation of incidents that relate directly to their department and their teams' activities
participate in the resolution of grievances that relate directly to their department and their teams' activities.

Internal lines of accountability

The table below lays out the internal roles, responsibilities and lines of accountability in relation to Social Incident and Grievance Management.

Table 3B.6 Internal roles, responsibilities and lines of accountability

ROLES AND RESPONSIBILITIES IN SOCIAL INCIDENT AND GRIEVANCE MANAGEMENT
COMPANY LEVEL	PERSON	ROLE
GROUP	Group Social Performance Principal	Provides advice and input on how to meet IFC Performance Standards and UNGPs Makes training and knowledge about grievance management available to site teams Receives details of incidents and grievances rated 4 and 5 Receives quarterly reporting on incidents and grievances
BUSINESS UNIT	Legal Manager	Notified if an actual or potential violation of law is involved Leads on investigating non-compliance with the law Liaises with relevant authorities in cases where legal proceedings might be, or have been, initiated Oversees site-level process where there is a possible violation of the law
SITE	Social Performance Team	Consults external stakeholders on design of grievance process Develops action plan for implementing the grievance process Develops communication materials to publicise the grievance process Raises awareness of the grievance process externally Develops systems for centralising grievances received via other departments Updates complainant on a regular basis Verifies the proper application of procedures, and corrects them where necessary Processes all incoming grievances by documenting them, tracking them, and following-up with concerned parties Co-ordinates with relevant departments to resolve grievances Escalates 'High' and 'Major' (levels 4 and 5) incidents and grievances to the GM and SPMC Produces reports on incidents and grievances Closure of each incident Quarterly report (at minimum) to GM on incident monitoring and analysis findings Submits reports to BU and Group
	Health, Safety, Environment; Supply Chain Team	Participate in incident investigation as needed
	HoDs	Assume responsibility for investigation of incidents and grievances relating to their department Discuss serious incidents and grievances at the Social Performance Management Committee
	General Manager	Assumes responsibility for the most serious cases Receives monthly reports summarising incidents and grievances Receives immediate notifications of 'High' and 'Major' incidents and grievances (levels 4 and 5) and reports these incidents to the BU CEO Involved in resolution of serious incidents
CONTRACTOR		Formally adopts the site's external grievance process

3B Incident and grievance management

3B Incident and grievance management