PETRONAS TECHNICAL STANDARDS

Grievance Mechanism

PTS 18.92.04
April 2021

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© 2021 PETROLIAM NASIONAL BERHAD (PETRONAS)
All rights reserved. No part of this document may be reproduced, stored in a retrieval system or transmitted in any form
or by any means (electronic, mechanical, photocopying, recording or otherwise) without the permission of the copyright
owner. PETRONAS Technical Standards are Company’s internal standards and meant for authorized users only.
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FOREWORD

PETRONAS Technical Standards (PTS) has been developed based on the accumulated knowledge,
experience and best practices of the PETRONAS group supplementing National and International
standards where appropriate. The key objective of PTS is to ensure standard technical practice across
the PETRONAS group.

Compliance to PTS is compulsory for PETRONAS-operated facilities and Joint Ventures (JVs) where
PETRONAS has more than fifty percent (50%) shareholding and/or operational control, and includes
all phases of work activities.

Contractors/manufacturers/suppliers who use PTS are solely responsible in ensuring the quality of
work, goods and services meet the required design and engineering standards. In the case where
specific requirements are not covered in the PTS, it is the responsibility of the
Contractors/manufacturers/suppliers to propose other proven or internationally established
standards or practices of the same level of quality and integrity as reflected in the PTS.

In issuing and making the PTS available, PETRONAS is not making any warranty on the accuracy or
completeness of the information contained in PTS. The Contractors/manufacturers/suppliers shall
ensure accuracy and completeness of the PTS used for the intended design and engineering
requirement and shall inform the Owner for any conflicting requirement with other international
codes and technical standards before start of any work.

PETRONAS is the sole copyright holder of PTS. No part of this document may be reproduced, stored
in a retrieval system or transmitted in any form or by any means (electronic, mechanical, recording or
otherwise) or be disclosed by users to any company or person whomsoever, without the prior written
consent of PETRONAS.

The PTS shall be used exclusively for the authorised purpose. The users shall arrange for PTS to be
kept in safe custody and shall ensure its secrecy is maintained and provide satisfactory information to
PETRONAS that this requirement is met.

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Table of Contents
1.0 INTRODUCTION ..................................................................................................... 4
1.1 SCOPE .............................................................................................................................. 4
1.2 GLOSSARY OF TERMS ...................................................................................................... 5
1.3 SUMMARY OF CHANGES ................................................................................................. 7
2.0 REQUIREMENTS..................................................................................................... 8
2.1 KEY ROLES AND RESPONSIBILITIES.................................................................................. 8
2.2 COMMUNICATION .......................................................................................................... 9
3.0 GRIEVANCE MECHANISM PROCESS ...................................................................... 11
4.0 PERFORMANCE MONITORING ............................................................................. 12
4.1 DATABASE ..................................................................................................................... 12
4.2 PERFORMANCE MONITORING & REPORTING .............................................................. 12
4.3 EFFECTIVENESS.............................................................................................................. 13
5.0 BIBLIOGRAPHY .................................................................................................... 14
APPENDIX 1 : GRIEVANCE MECHANISM PROCESS DESCRIPTION .................................. 15
APPENDIX 2 : EXAMPLE OF GRIEVANCE FORM ............................................................ 18
APPENDIX 3 : GRIEVANCE MECHANISM SHARING OF BEST PRACTICES TEMPLATE ....... 20
APPENDIX 4 : UNGP GRIEVANCE EFFECTIVENESS CRITERIA.......................................... 21
APPENDIX 5 : MAPPING AGAINST HSE MANDATORY CONTROL FRAMEWORK ............. 23

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1.0 INTRODUCTION
The energy sector recognises the importance of an effective Grievance Mechanism (GM) to
meet expectations from its stakeholders. Even operational activities employing the highest
standards can have adverse social and environmental impacts.

Grievance refers to allegations of specific incidents and of any damage, impact or

dissatisfaction resulting from company or contractors’ actions, whether perceived or actual.
Companies are expected to promptly address grievances in a fair and consistent manner. This
mechanism can complement but do not replace state-based judicial or non-judicial forms of
remedy.

This PTS supports the implementation of the PETRONAS Human Rights Commitment.
Implementation of GM is a requirement in PTS 18.00.02 HSE Mandatory Control Framework
(MCF). PTS 18.92.04 Grievance Mechanism standardises the implementation of grievance
mechanism across PETRONAS to enable an effective process to be established to manage HSE
and Social impacts.

1.1 SCOPE

The PTS is applicable to all projects, facilities and businesses where PETRONAS has operational
and/or major equity share. GM is a requirement which applies throughout the lifecycle of
projects and businesses regardless the level of perceived risks. The scope of grievances
received from the stakeholders such as employee, contractors and surrounding communities
are limited to impacts related to PETRONAS’ operations.

Contractors are expected to also have their own GM procedure as required in the PETRONAS
Contractors Code of Conduct on Human Rights (CoCHR).

The following items are not included in this PTS as it will be covered by their respective
processes:

PETRONAS Employee Grievance

Grievances raised by PETRONAS employee on employment & industrial relations matters (e.g
performance evaluation, remuneration, employee benefits, employee-employer relations)
shall be channelled directly to PETRONAS Human Resource Management or its business
Human Resource focal.

Unsafe Act Unsafe Conditions (UAUC)

The Unsafe Act, Unsafe Condition (UAUC) programme is established to reduce and eventually
eliminate workplaces incidents through early observation, identification, and intervention.
UAUC shall be reported into UAUC System, not through Grievance Mechanism.

Note: For listing of PETRONAS business, operations and assets that shall comply with this
PTS, please refer to PTS 18.00.04 PETRONAS HSSE Universe:
(https://ghsse.petronas.com/HSEPTS/Pages/HSE-PTS.aspx)

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1.2 GLOSSARY OF TERMS

1.2.1 General Definition of Terms & Abbreviations

Refer to PTS Requirements, General Definition of Terms, Abbreviations & Reading Guide PTS
00.01.03 for General Definition of Terms & Abbreviations.

1.2.2 Specific Definition of Terms

No Term Definition

1 Contractors A firm which has entered into a legal contract to supply

services or material to PETRONAS HCU/OPU/JV. Any
reference to Contractors shall, unless otherwise stated, be
taken to include Consultants, Agents, and other Third
Parties who have entered into similar legal contract for the
supply of services or material to PETRONAS HCU/OPU/JV.

2 Complainant/Aggrieved An individual, group, or organisation that presents a

Party/Grievant written or verbal grievance and is directly or indirectly
impacted by PETRONAS’ projects or operations.
Complainant/Aggrieved Party/Grievant may also be a
representative for the affected community.

3 Concern / Complaint General perception, dissatisfaction, etc. towards

PETRONAS that are not regarded as grievance. These may
be received via the GM platform and are to be managed
and addressed by the relevant functions within PETRONAS.

4 Cultural Sensitivity to other cultures and the awareness of how

Appropriateness other ethnic, racial, and/or linguistic groups differ from
one’s own.

5 Inquiries / Request Inquiries for information and requests for donations,

sponsorships, community investments, employments, etc.
that are not regarded as grievance. These may be received
via the GM platform and to be managed and addressed by
the relevant functions within PETRONAS.

6 Issue Owner Function/department that is relevant to the cause of

grievance. Responsible to form and lead investigation team
and propose options for resolution of grievance cases.

7 Grievance Grievance refers to allegations of specific incidents and of

any damage, impact or dissatisfaction on human rights
resulting from company or contractors’ actions, whether
perceived or actual.

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No Term Definition

8 Grievance Mechanism Grievance Mechanism is a non-judicial process through

which grievances can be raised and remedy can be sought
by aggrieved party in a timely, fair, and consistent manner.
Table 1: Specific Definition of Terms

1.2.3 Specific Abbreviations

No Abbreviation Description

1 CLO Community Liaison Officer

2 CoCHR PETRONAS Contractors Code of Conduct on Human Rights

3 GM Grievance Mechanism

4 HSE MS Health, Safety and Environment Management System

5 IP Indigenous Peoples

6 LT Leadership Team

7 HSE MCF HSE Mandatory Control Framework

8 SP Social Performance

9 TP Technical Professional

10 NGO Non-Governmental Organisation

11 UNGP United Nations Guiding Principles on Business and Human

Rights
Table 2: Specific Abbreviations

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1.3 SUMMARY OF CHANGES

This PTS 18.92.04 (April 2021) replaces PTS 18.92.04 (September 2018)
Incorporation of HSSE Learnings*

No Current statement Changes / addition Basis (indicate source of

/ requirement (for Learnings)
revised document)

1 Incorporation of GM a. Incorporating GM Lessons PHRP on COVID-19 Pandemic in

and COVID-19 Learnt template into the 2020 - Grievance on Labour and
Pandemic lesson PTS Working Conditions is identified
learnt and b. Adding Communication’s as one of the key emerging risks
communication details into the PTS from COVID-19
requirements.

2 External assessment’s Addition of requirement: External assessment gap analysis

recommendation of a. GM Effectiveness on Social Performance
findings in improving b. Assurance governance was conducted in
the effectiveness of c. Evaluation of GM 2020 to enhance human rights
GM in the PTS Effectiveness management in PETRONAS.

3 Clarity of roles and
responsibilities.
a. Addition of role and Feedback from users from of GM
enhancement of Module in Borealis system
responsibilities of personnel
managing grievance at
OPU/Asset/Facilities/Project

*Note: HSSE Learnings include lesson learnt from previous incidents, audit findings and other
sources

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2.0 REQUIREMENTS
GM is applied throughout the lifecycle of projects and businesses. It shall be made available
throughout exploration, project (FEL, Execution), development, start-up, operations &
maintenance, to the decommissioning / abandonment phase.

2.1 KEY ROLES AND RESPONSIBILITIES

As a minimum, the following resources shall be established:

ROLE RESPONSIBILITIES
Grievance • Develop and manage grievance mechanism procedure
Focal (GF) /
Community • Forms cross-functional team to develop GM
Liaison Officer • Deal with complainant/aggrieved party /grievant in managing grievances
(CLO)
• Conducts screening and initial assessment
• Assign issue owner with notification to Grievance Mechanism Custodian for minor
grievances
• Promotes grievance resolution to complainant
• Establish and maintain grievance database / system
• Analyse, monitor, and report GM Performance
• Attend GM training
Grievance • Appoint dedicated GF/CLO
Mechanism
Custodian • Oversees the overall development and management of GM
(Chair of HSE • Assigns Issue Owner for major grievances
Committee)
• Chairs Grievance Resolution/Appeal Committee (at site)
• Appoints third party mediator, if required
• Escalates the grievance to higher level (i.e. BUs), if required
• Approves reports for internal and external reporting
• Attend GM training
Grievance • HSE Committee shall act as Grievance Resolution Committee/Appeal Committee
Resolution
Committee / • Grievance monitoring/tracking shall be a fixed agenda for HSE Committee meeting
Grievance • Analyse grievances and deliberates options for resolution, ensures no conflict of
Appeal
Committee interest
(site level) • Deliberates on appeal cases
• Approves resolution

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• Ensure and oversees implementation of resolution or escalate the grievances

(when necessary)
• Signs off case closure
• Attend GM training
Issue Owner • Function/department that is most relevant to the cause of grievance.
• Forms and leads investigation team upon assignment by CLO/GF and recommend
options for resolutions to GRC
• Supports CLO/GF on dialogue or engagement with the Complainant/ Aggrieved
Party/ Grievant to achieve resolution
• Implement and follow-up where relevant on action items once the resolution has
been approved by the Grievance Resolution Committee
Table 3: GM Key Roles and Responsibilities

When receiving grievances from complainants, PETRONAS employee and contractor shall
direct the complainant to the grievance focal or CLO at sites. Otherwise, they can use the GM
form and submit to the grievance focal or CLO for their action. Using community
representatives such as village head, or respected community members as the first point to
receive complaints can be considered.

Conflict of Interests
Where a complaint or concern is raised on a specific employee or contractor, the latter shall
not be involved in handling the case. Similarly, any employee related to the complainant shall
not be involved in the case due to conflict of interest.

Escalation of Grievance
In some circumstances, grievance cases may require escalation (i.e. Limit of Authority (LOA)
and/or coverage by national/international media which may impact the Company’s
reputation). In these cases, decisions are not to be made at site level. The Grievance
Resolution Committee/Appeal at site shall escalate the grievances to BUs and/or relevant
HCUs.

Protection From Retaliation

Retaliation is any adverse action taken against a complainant, employee or contractor that
hinders the operation of this procedure. PETRONAS will not tolerate such conduct. When
concerns about retaliation or victimization are raised against PETRONAS staff, they will be
investigated under the PETRONAS Code of Conduct and Business Ethics (CoBE).

2.2 COMMUNICATION
Information about how and where to report grievances shall be made publicly available (e.g
brochure, posters, telephone line, CIMAH engagement, village heads, townhall, etc) with
consideration to cultural appropriateness. It shall be made known to all affected stakeholders’
regardless of language, gender, age, race, literacy level or socio-economic status.

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Where face-to-face communications is not possible due to circumstances/situation such as

pandemic and natural disaster, grievances shall be managed through appropriate means of
communication e.g. virtual (Microsoft Teams, Text-Messaging) and telephone conversation.

In promoting shared learning, GHSSE may require CLO/GF to share best practices on managing
grievances by using template in Appendix 3.

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3.0 GRIEVANCE MECHANISM PROCESS

The Grievance Mechanism process shall be established as below and implemented as per Appendix 1

1. Receive, screen, acknowledge and register grievances 5. Track and document responses
2. Assess (verify the grievance) and assign issue owner 6. Recourse mechanism for grievances
3. Conduct investigation for valid grievances 7. Follow up and Close Out
4. Establish timelines for providing responses

Figure 1: GM Process

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4.0 PERFORMANCE MONITORING

GM is a tool to identify and address systemic issues. The Grievance Performance Monitoring
shall be used to monitor the management of grievances and analyse for reporting purpose.
It shall be reported and maintained by projects, facilities and businesses.

4.1 DATABASE
As a minimum, the GM Database shall be established and consist of the following items:
i. Date of case received
ii. Name of Complainant
iii. Type/Category of grievance
iv. Brief description of grievance
v. Date acknowledged
vi. Responsible unit or contractor
vii. Issue owner
viii. Proposed solution/Feedback to complainant
ix. Date of resolution/acknowledged by complainant
x. Date closed
xi. Satisfied with process (provide reason)
xii. Satisfied with resolution (provide reason)

4.2 PERFORMANCE MONITORING & REPORTING

As in PTS 18.06.04 HSE Performance Monitoring and Reporting, performance indicator for
GM shall be reported into the online Group HSSE reporting tool:
INDICATOR INDICATOR HIGHEST TARGET REPORTING
REPORTING FREQUENCY
LEVEL
Percentage of Grievance Cases Lagging Group 100% Quarterly
Closed (%)

Number of grievance case

X
closed
100
Number of grievance case
received

Requirements of the implementation of Grievance Mechanism in this PTS is in accordance to

the HSE MCF (Refer to Appendix 5). However, Asset/OPU/Facility shall provide necessary GM
information upon request by GHSSE/BU as and when required.

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4.3 EFFECTIVENESS

4.3.1 Assurance

The Asset/OPU/Facility shall be accountable to plan and conduct the self-assurance of GM

MCF & Functional Checklists and HSE Management System. Asset/OPU/Facility shall analyze
the findings, establish and execute intervention plans as and when applicable.

4.3.2 Evaluation of Effectiveness

To ensure the effectiveness of Grievance Mechanism, SP Practitioners at BU/HCU shall

conduct GM Effectiveness Evaluation as per evaluation criteria on Appendix 4.

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5.0 BIBLIOGRAPHY
In this PTS, reference is made to the following Standards/Publications. Unless specifically
designated by date, the latest edition of each publication shall be used, together with any
supplements/revisions thereto:

PETRONAS TECHNICAL STANDARDS / GUIDELINES

Project HSE Management Standard PTS 18.05.13

HSE MCF PTS 18.00.02
PETRONAS HSE Assurance PTS 18.07.02
Environmental Impact Assessment PTG 18.71.02
Decommissioning, Remediation and Reclamation of On-Shore E & P Sites PTG 18.70.06
Human Rights Due Diligence PTG 18.92.03
Temporary Onshore Accommodation PTG 18.53.12
Health Risk Assessment PTG 18.31.01
Indigenous People Assessment PTG 18.92.05
Land Acquisition and Involuntary Resettlement PTG 18.92.06
Cultural Heritage Assessment PTG 18.92.07
PETRONAS Project Management System (Version 6.0) 2019
PETRONAS Procedures and Guidelines for Upstream Activities (PPGUA)
PETRONAS Contractors’ Code of Conduct on Human Rights
INTERNATIONAL STANDARDS / GUIDELINES / REFERENCES
Anglo American. Socio-Economic Assessment Toolbox Version 3. 2012.
FTSE. FTSE ESG Ratings: Methodology Document Version 1.0. 2015.
International Finance Corporation (IFC). Good Practice Note: Addressing Grievances from
Project-Affected Communities. 2009.
International Finance Corporation (IFC). Stakeholder Engagement: A Good Practice
Handbook for Companies Doing Business in Emerging Markets. 2007.
Interim Advice for IFC Clients On Safe Stakeholder Engagement In The Context Of COVID-19,
May 2020
IPIECA. Community grievance mechanisms in the oil and gas industry: A manual for
implementing operational-level grievance mechanisms and designing corporate
frameworks. 2015.
United Nations (UN). United Nations Guiding Principles on Business and Human Rights:
Implementing the United Nations “Protect, Respect and Remedy” Framework. 2011.
International Association of Impact Assessment), Social Impact Assessment. Guidance for
Assessing the Social Impacts of Projects, 2015

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APPENDIX 1 : GRIEVANCE MECHANISM PROCESS DESCRIPTION

Grievance Mechanism Process description is as follows:
PROCESS DESCRIPTION
Step 1: Receive & • Availability of a GM shall be publicised and the process shall be made
Screen clear to stakeholders/ complainant/ aggrieved party /grievant
• Provide a variety of access points for complainants / aggrieved party /
grievant to lodge concerns, complaints and grievance in a manner
convenient (e.g. location, time, costs, etc.)
• Examples of access points are as follows:
o Face to face with PETRONAS/contractor staff
o Telephone call
o Text message
o Complaint boxes
o Email
• The CLO/GF is to record the statements from the complainant in the
Grievance Form (Appendix 2).
• Ensure sufficient information is initially available to establish the nature
of concerns, complaints and grievance.
• It is important to maintain complainant’s confidentiality and provide
grievance details only to those directly involved in the investigation. If
confidentiality cannot be guaranteed (e.g. due to government
regulations), grievances may be lodged under an alias/assumed name.
• GMs shall be open to anonymous grievances. Addressing anonymous
grievances can be challenging as they may lack sufficient details for an
investigation or for meaningful feedback. Nevertheless, anonymous
grievances shall be treated equally and feedback is usually provided
during open engagement with community.
• The CLO/GF is to screen the concerns and complains received whether
is it grievance or not
• If the concerns and complains received are not a valid grievance i.e.
request, suggestion, UAUC, etc. they shall be managed by appropriate
issue owners and systems.
Step 2: Register • If the grievance received is valid, the CLO/GF is to register the concerns,
and Acknowledge complains and grievance in a grievance database/system.
• CLO/GF shall provide complainant an acknowledgement within 24
hours upon receiving the complaint. The expected outcome or progress
on the action item closure of the complaint shall be communicated to
complainant within one month of receiving complaint.
• Acknowledgement shall be in a culturally appropriate manner such as:
a. Telephone call
b. Text message
c. Visit/face to face
d. Letter
e. Email
Step 3: Assess and • When the concerns and complaints are accepted as a legitimate
Assign grievance, it shall be assessed.

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• If the grievance issue owner is external parties outside PETRONAS or

other internal parties in PETRONAS, it shall be referred to the relevant
issue owner (Internal / External Mechanism) and recorded as closed.
• Quick assessment by the CLO/GF may help to address minor grievances
satisfactorily so that they do not escalate
• The complexity and severity of the grievance will determine what
action is required, who needs to be informed and who manages the
case.
• For major and more complex grievances that require further
investigation, the CLO/GF may propose to the Grievance Custodian to
assign an Issue Owner. Typically, minor / major criteria are as follows:
Minor Grievance Major Grievance
1. Requiring little/no Prolonged effect wit External
investigation exposure – out of fence
2. Low risk to PEAR/Human effect/social media/media
Rights Matrix – Low/ No coverage.
Likelihood of escalation
3. Transient effect with no Example: Groundwater
exposure contamination which requires
Example: Labour and working periodical samplings and
conditions grievance which can intervention by authority,
be resolved internally, nuisance national media coverage on
from smell, noise and light odour pollution, community
pollution, unsafe driving grievance on their safety due to
behaviour, etc. influx of workforce, etc.
*minor grievance shall not be treated as low priority
Step 4: Investigate • An issue owner is usually the function/department associated with the
cause of the grievance. Once an Issue Owner is assigned, the person
shall lead the investigation team for fact-finding.
• Third party experts may be involved if strict impartiality is needed or
the grievance is due to a complex technical matter. It could also be a
joint effort with participation by following parties:
a. Local authorities
b. Local agencies
c. Community leaders
d. NGOs
e. Worker representatives
• Timeframe for investigation shall be determined by Grievance
Custodian.
• Ensure that there is clear investigation procedure, timeframe and
roles/responsibilities. Involve the legal team whenever appropriate.
Step 5: Respond • Complainant is to be updated on the status of the grievance procedure
within one month after the grievance has been registered. In cases
whereby closure may take longer, the CLO/GF shall update the
complainant periodically.
• If the grievance is found to be unsubstantiated or
PETRONAS/contractor is not at fault, the CLO/GF shall provide a

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detailed and respectful explanation to complainant with compelling

evidence.
• Issue Owner may propose options for resolution. However, in order to
ensure there is no conflict of interest, the options shall be deliberated
by a Grievance Resolution Committee/Appeal or LT.
• Best practice is to have a joint decision-making process where a
mutually agreed resolution is achieved through collaborative dialogue
with complainant.
• Ensure resolutions are consistent with PETRONAS Human Rights
Commitment and local legislation.
Step 6: Recourse • Consider a recourse mechanism for grievances when
PETRONAS/Contractor and the complainant cannot reach an
agreement.
• A recourse process can take place in-house or via third party.
• Below is typical recourse mechanism:
a. Internal appeal process
b. Third party mediation
c. Arbitration
d. Legal recourse
Step 7: Follow up • When implementing the resolution, follow up and corrective actions
and Close Out may be needed to address the problems that may arise.
• Grievance close out occurs after the implementation of an agreed
resolution has been verified by the complainant by provided feedback
on level of satisfaction with the grievance procedure of the outcome.
This must be recorded ensuring the complainant is aware of the agreed
resolutions.
• Even when recourse mechanism has been implemented and an
agreement is not reached, it is important to close the case, document
the results and request complainant’s feedback of the process of its
outcome.
• Close-out shall be deliberated in GRC and recorded in the Grievance
Database / System.
Table 4: GM Process

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APPENDIX 2 : EXAMPLE OF GRIEVANCE FORM

(Consider Translating The Form Into Language Understood By All Affected Stakeholders)
Name of
Complainant:
Contact Details:

Town/Community/
Company:
Grievance Title:

Grievance
Reference
Number:
Grievance Type & Labour & Working Condition Community Well-Being
Sub-type □ Forced or trafficked labour in contractors’ □ Community health & safety
and subcontractors’ workforce □ Access to natural resources for health,
□ Child/minor labour cultural needs and livelihood
□ Condition of employment & work □ Land acquisition & involuntary
□ Discrimination in hiring & contractual terms resettlement with/without economic
□ Freedom of association & collective displacement
bargaining □ Indigenous peoples
□ Workers’ health & safety □ In-migration
□ Workers’ camp conditions
Supply Chain Responsible Security
□ Contractor/Supplier performance related to □ Use of force and conduct of third-party
labour and working conditions, community security
well-being and security □ Human Rights training for staff and third-
party security
Others □ Inquiries
□ Concerns
□ Suggestions
□ ……………………………………

Details of Statement

To include the minimum details by answering the following: What, When, Where, Who, Why,
How

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Complainant Name/Signature: Date:

CLO Name/Signature: Date:

Acknowledgement

Complainant Name/Signature: Date:

CLO Name/Signature: Date:

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APPENDIX 3 : GRIEVANCE MECHANISM SHARING OF BEST PRACTICES TEMPLATE

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APPENDIX 4 : UNGP GRIEVANCE EFFECTIVENESS CRITERIA

Effectiveness Criteria

1 Legitimate: Enabling trust from the stakeholder groups for whose use they are intended, and being accountable for the fair
conduct of grievance processes.
 Credible in the eyes of its intended users.
 Users are confident that complaint will be treated in a fair and objective manner.

2 Accessible: Being known to all stakeholder groups for whose use they are intended, and providing adequate assistance for
those who may face particular barriers to access.
 Mechanism is made known to all affected stakeholders, regardless of language, gender, age, literacy level or socio-
economic standing.
 Promote awareness of the mechanism and understanding of its purpose and functioning.
 Readily accessible, culturally appropriate and should not impede access to other forms of remedy.
 Take into account of potential barriers to access, for example in terms of cost, language, fear of retaliation, as well as
the needs of any vulnerable or disadvantaged groups.

3 Predictable: Providing a clear and known procedure with an indicative time frame for each stage, and clarity on the types of
process and outcome available and means of monitoring implementation.
 Clarity on access points, type of complaints that are within scope, process, timeline for resolving complaints, types of
outcome available, how agreed resolutions are followed up and monitored.
 Grievance handling process operates in a consistent manner.

4 Equitable: Seeking to ensure that aggrieved parties have reasonable access to sources of information, advice and expertise
necessary to engage in a grievance process on fair, informed and respectful terms.
 The equitability principle seeks to redress real or perceived imbalances by placing responsibility on the company to
help level the playing field.
 The complainant should have reasonable access to information, advice and expertise necessary to engage in the
grievance process on fair and equitable terms.
 Equitability also implies handling every grievance consistently and with due respect for the complainant, regardless of
whether the company considers the issue to be well founded.

5 Transparent: Keeping parties to a grievance informed about its progress, and providing sufficient information about the
mechanism’s performance to build confidence in its effectiveness and meet any public interest at stake.

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 The intent of the transparency principle is to build trust in the CGM by keeping complainants informed about the
progress of their case, and communicating with user groups about the overall functioning of the mechanism.
 Transparency about outcomes does not imply that details of individual grievances should be made public.
 Transparency should also be weighed against other considerations, such as the need to respect confidentiality and
avoid exacerbating tensions between different groups.

6 Rights-compatible: Ensuring that outcomes and remedies accord with internationally recognized human rights.
 A CGM should promote equitable resolution processes and equitable agreements based on informed decisions.
 A project-level CGM is not a substitute for, nor should it undermine, a complainant’s right to pursue other avenues of
remedy, judicial or non-judicial.

7 Continuous learning: Drawing on relevant measures to identify lessons for improving the mechanism and preventing future
grievances and harms.
 Enables company to identify trends and patterns, and take appropriate measures to reduce the risk of recurrences.
 The more grievances a mechanism handles, the more experience the team managing the process has to understand
the root causes of community concerns and how to resolve them.
 This principle highlights the need to analyse root causes and focus on prevention rather than simply managing
grievances as they arise.

8 Based on engagement and dialogue: Consulting the stakeholder groups for whose use the CGMs are intended on their design
and performance, and focusing on dialogue as the means to address and resolve grievances.
 Engagement and dialogue form the foundation of the grievance handing process.
 This applies to the design of the mechanism as well as the way in which the process operates.
 Solutions reached through dialogue are more likely to satisfy the interests of the parties than those imposed
unilaterally.
 Open engagement helps the company and neighbouring communities minimize barriers and find acceptable
resolutions to the issues identified.

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GRIEVANCE MECHANISM April 2021
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APPENDIX 5 : MAPPING AGAINST HSE MANDATORY CONTROL FRAMEWORK

MCF Requirements
MCF 10.2
Establish and implement a mechanism to managed
grievances. It shall include the following
1. Roles and responsibilities of a dedicated focal
person to manage grievances.
2. Receive and register grievances.
3. Establish timelines for providing responses.
4. Track and document responses.
5. Verify and investigate grievances.
6. Establishment of a grievance database.
7. Analysis of grievances and identification of
appropriate action to prevent recurring
grievances.
8. Reporting to appropriate Committee on
grievances received and actions taken.
PTS Grievance Mechanism
Refer to 2.1 Key Roles and Responsibilities Table 3
Refer to 3.0 GM Process and Appendix 1
Refer to 3.0 GM Process and Appendix
Refer to 3.0 GM Process and 4.2 GM Performance
Monitoring & Reporting
Refer to 3.0 GM Process and Appendix 1
4.1 GM Database
Refer to 3.0 GM Process and Appendix and Refer to
2.1 Key Roles and Responsibilities Table 3
Key Roles and Responsibilities Table 3

Make publicly available, information about how and Refer to 2.2 Communication
where to report grievances.

Monitor and track implementation of the Grievance 4.2 GM Performance Monitoring & Reporting
mechanism through suitable performance indicators
as per PTS 18.06.04 HSE Performance Monitoring
and Reporting and report to BU and/or Group HSE

MCF 10.2 Checklist

1.1 A dedicated focal person/Community Liaison Key Roles and Responsibilities Table 3
Officer has been appointed to manage
grievances.
(e.g HR Manager, HSE Manager, Public
Relations Manager etc.)
1.2 The focal person is trained to manage Key Roles and Responsibilities Table 3
grievances(N)

1.3 The roles and responsibilities of the dedicated Key Roles and Responsibilities Table 3
focal person to manage grievances are clearly
defined as follows:
a. Develop and implement Grievance
Mechanism procedure at business level and
project / operation level
b. Analyse grievances and take appropriate Key Roles and Responsibilities Table 3
action to prevent recurring grievances within
the company’s control
c. Establish and maintain Grievance Key Roles and Responsibilities Table 3
Mechanism database

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 PTS 18.92.04
GRIEVANCE MECHANISM April 2021
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d. Report grievances received and actions Key Roles and Responsibilities Table 3
taken to the appropriate committee (e.g HSE
Committee)
1.4 The Grievance Mechanism procedure has been Refer to 3.0 GM Process and Appendix 1
established and implemented. It includes
methods to:
a. Receive, acknowledge and register
grievances

b. Verify and investigate the grievances Refer to 3.0 GM Process and Appendix 1
c. Establish timelines for providing responses Refer to 3.0 GM Process and Appendix 1
d. Track and document responses Refer to 3.0 GM Process and Appendix 1

e. Investigate valid grievances Refer to 3.0 GM Process and Appendix 1

f. Escalation of grievances(N) Refer to 3.0 GM rocess and Appendix 1

g. Recourse mechanism for grievances(N) Refer to 3.0 GM Process and Appendix 1

2.0 Information about how and where to report
grievances is made publicly available and to
consider cultural appropriateness
3.1 High level management is timely and formally
updated on grievances(N)
Refer to 2.2 Communication
Key Roles and Responsibilities Table 3 and 4.2 GM
Performance Monitoring & Reporting

3.2 Monitor and track implementation of the 4.2 GM Performance Monitoring & Reporting
Grievance Mechanism through suitable
performance indicator(N)
3.3 Performance is reported to Business Unit 4.2 GM Performance Monitoring & Reporting
and/or GHSE(N)

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