ieng Group

POLICIES

Policy Title: Community Grievance Mechanism

Department: POPs (People Operations)
Directed To: All Employees

Brief Explanation:
This community grievance mechanism policy states the process for receiving, investigating, responding to, and
closing out grievances from affected communities where ieng operates. And this shall be done in a timely, fair,
and consistent manner. In addition, all cases will be treated in a culturally appropriate manner without being
offensive to local traditions and norms.
This policy will be shared by email to all employees, saved on the TwoThirtyThree platform and regularly explained
via awareness sessions.

Purpose:
ieng is committed to fulfil its responsibility to respect Human Rights, proactively treat any issue that might be
caused by its activities to gain local communities trust and operate in a healthy environment.

Criteria:
I. Community Grievance Mechanism Procedure

ieng community grievance mechanism shall be shared to all local communities where the company operates via
flyers distributed in those areas, contact details to be displayed on the sites and local municipalities to spread
the word among chief of villages/inhabitants.

• Step 1: Reception

Grievances can be deposited in various forms:

➢ Verbal complaint to ieng staff (to be directed to the hotline number holder)
➢ Hotline Number

Country Phone Number

Afghanistan +93 795 986 374
Algeria +213 70 679 979
Chad +235 616 180 15
Eki Struct +385 913 794 200
Ethiopia +251 978 197 814
Ghana +233 242 022 222
Guinea Conakry +224 625 795 422
Liberia +231 778 323 783
Myanmar +959 777 004 890
Nigeria +234 813 175 7915
Pakistan +92 3 109 244 277

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POLICIES

RCA +236 725 047 77

South Sudan +211 926 605 476
Kenya +254 780 998 817
DR Congo +243 993 773 854
Uganda +256 759 221 554
KSA +966 537 788 986
GreenPole +91 8 078 925 031

Grievances received through any channel should be filled in the Online Community Grievance form on SharePoint
by the holder of the hotline number. The grievance filled online will be accessible to all members of the
community grievance committee. Same for all actions taken online by the grievance owner, such as community
grievance approval, rejection, or appeal. Members of the community grievance committee will all be trained on
the community grievance workflow on SharePoint.

The links of all forms related to this policy are found in part IV.

For grievances received anonymously, ieng will not be disclosing the identity(ies) of the complainant(s) and
proceed with the whole process in total confidentiality.
Each grievance is acknowledged once received, and the complainant is informed of the next steps within a max
of 2 working days via the most adequate channel to reach the complainant.
The grievance is registered in the community grievance register by the grievance owner.

• Step 2: Assessment & Assignment

The grievance management committee will meet for a preliminary assessment of the case and define its
legitimacy, category, and severity – (Check III. Grievance Category & Severity below).
If the grievance is groundless, the complainant(s) will receive a letter indicating the reason(s) why the grievance
was rejected, within 2 days of receiving the complaint. If the grievance is legitimate, a grievance owner, part of
the community grievance committee, will be assigned to handle investigations and communications with the
complainant(s), and any party involved.

• Step 3: Grievance hearing

When the grievance is legitimate, the grievance owner will inform the complainant using the most adequate
channel, of next steps related to the grievance management, including an estimated time to come back with a
solution to close the issue and any relevant information that he/she/they must be aware of.
The designated grievance owner will invite the employee to discuss his/her issue in more detail within a period
of 48 hours after being selected. The party aggrieved can be accompanied and represented during the
community grievance process by a lawyer, chief of village, family member in case of a minor, community
representative or others if they wish to.

This step shall be taken within a maximum of 5 working days.

• Step 4: Investigation

The grievance owner proceeds with an investigation on the case that includes but not limited to meeting with
the complainant(s), interviewing relevant stakeholders, site visits, and collecting material evidence.

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The grievance owner will seek an understanding of the root cause of the issue to provide a solution that will also
prevent the same from happening in the future.
Documentation related to all interactions with internal and external stakeholders should be maintained. The
community grievance register should be regularly updated by the grievance owner.
The community grievance management committee will take a decision based on the findings, after analyzing all
facts.

• Step 5: Respond

The grievance owner will communicate the offered solution to the complainant(s), and that should be within a
maximum time of 20 working days. After hearing the complainant(s) views on the proposed solution, and if
approved, the grievance owner will get his/her approval in writing to upload it in the grievance acceptance &
closure form after filling it with the necessary information. The said form details the description of the solution
and the schedule for its implementation as agreed on together.
In case of anonymous grievance, if the identity of the party aggrieved has not been voluntary revealed during the
investigation time, the grievance owner will find the most effective way to post/share the solution(s) offered/the
action(s) taken that address the issue raised. Thus, indirectly inform the anonymous party aggrieved.
Appeal
If the solution offered is not approved by the complainant, he/she can appeal. The grievance owner will get their
appeal decision in writing to upload it in the online community grievance appeal form after filling it. Depending
on the case, the internal grievance committee can still handle the case once again taking into consideration any
updates, changes, new evidence. Further investigation should be initiated for further potential actions if possible.
The community grievance committee members can be substituted with other members of higher-ranking leaders.
Or this time with the intervention of a third party (could be another HOD, the company lawyer or any other person
that might be needed, whether internal or external). The third party will serve as a mediator and facilitate
negotiations with the party aggrieved.
If a new solution is agreed on, the party aggrieved shall provide the grievance owner with a written approval on
the implementation of the said solution, the grievance owner uploads it in the grievance acceptance & closure
form and duly fills it. If not, the case comes to an end, and the complainant(s) can go for legal proceedings.
The appeal process shall not exceed a period of 20 working days.
The grievance owner shall update the grievance register following any step.

• Step 6: Monitoring & Evaluation

The grievance committee will gather to assess the way the grievance was handled and set an action plan to
avoid reoccurrence of same issue(s) if needed.
Once the case is closed, the grievance owner will constantly follow up on the proper implementation of the
proposed solution, making sure it is effective and the party aggrieved is satisfied. The case will then be closed,
and the grievance owner will mention it in the grievance register.

II. Grievance Management Committee

The grievance management committee shall be constituted of all HODs to represent different functional areas
of the company. The grievance management committee will gather and brainstorm on the case received, sharing
different ideas and points of views to come up with the most suitable solutions to close the case. Each team
member’s responsibility is to remain objective and present all findings needed and provide the necessary support
to manage grievances in an efficient and effective way.
In case of appeal, the same community grievance committee can reopen the case for further investigation taking
into consideration recent updates and new evidence. Or they can be substituted with other members of higher-

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 ieng Group
POLICIES

ranking leaders. The intervention of a third party might be essential, such as another HOD, the company lawyer
or any other person that might be needed, whether internal or external.

III. Grievance Category & Severity

Grievance Categories Brief Explanation

Tangible culture: buildings, monuments, landscapes, books, works of art, artifacts
Cultural Heritage Intangible culture: folklore, traditions, language, knowledge)
Natural heritage: culturally significant landscapes and biodiversity
Hydrocarbon or chemical spills
Excessive noise emissions from the site that could impact on local residents
Excessive dust emissions that are observed to leave the site
Subsidence impacts on natural or built features outside predictions
Unauthorized impacts to flora, fauna or heritage items
Spillage of tailings or reject material
Environmental
Non-compliance with approvals, licenses or environmental legislation
Inappropriate waste management
Offsite water discharges outside of Environment Protection License (EPL)
requirements
Strong odors that are noticeable offsite
Direct lighting that impacts on adjoining residences or public roads
Human Rights Human rights violations, Gender based violence, or any type of abuse
Change of a land surface that potentially changes its runoff characteristics including
Land Disturbance
clearing, grading, or excavation without approval
Other issues might be considered as grievances that doesn’t fall under the above
Other
categories

Grievance Severity Brief Explanation

Moderate impact on community and / or company reputation. An answer can be
Moderate
provided immediately and / or ieng Group is already working on a resolution
Significant Significant impact on community and company reputation, resulting in direct threat
to license to operate
Extreme, widespread / permanent impact on the community that will or is
Extreme
jeopardizing the reputation of CREI

IV. Community Grievance Templates

• Identified/Anonymous Community Grievance Form
https://forms.office.com/r/k4F7FVfs7w
• Community Grievance Acceptance & Closure Form
https://forms.office.com/r/au40vVMVCd
• Community Grievance Appeal Form
https://forms.office.com/r/gQr3V4eu6z
Reviewed By: Group ER & CSR Manager Date: 16-Mar-22
Approved By: CHRO Date: 16-Mar-22
Last Updated By: Group ER & CSR Manager Date/Time: 11-Oct-23

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This document is the property of i engineering Group. It cannot be copied or transferred without prior authorization.