the steps and components of the projects’ GRMs. Each describes the steps of its GRM a bit differently, but notable perhaps is Liberia in how it lacks details about the process. Liberia’s SEP doesn’t specify that grievances are recorded or responded to, let alone how much time each of those steps should take. The Liberia SEP is also the only one that does not indicate that complaints can be filed anonymously. The Uganda SEP is the only one that explicitly states that the Grievance Committee, that handles grievances from the project, must provide a reason for their decision about the grievance to the complainant. Bangladesh does not explicitly state that a reason must be provided, but says answers should be provided to any questions that arise about how grievances were resolved. The Philippines also does not indicate explicitly that a reason must be provided, but says that the GRM “provides transparent and credible processes for fair, effective and lasting outcomes.” the “composition of GRCs will take account of gender composition” and Cambodia’s SEP says that the GRC must include women. 3. Data and information reported about the GRM None of the SEPs specify that grievances filed will be disaggregated by the gender of the person who submitted them. Within the “monitoring” section, all of the SEPs indicate that at least some information about the GRM’s performance will be made public, like the number of grievances received and the number resolved in a prescribed time. The SEPs for Sri Lanka and Cambodia more specifically say that they will publicize a summary of complaints, the actions taken (Cambodia says it will also report on the time it takes to close complaints). 4. GRMs equipped to handle GBV/SEA/SH Along with the Burkina Faso and Guatemala GRMs, the Liberia GRM does not provide a form of appeal. All of the other SEPs specify as a step or component of their projects’ GRMs that there is an appeals process, and that if “all possible redress has been proposed and if the complainant is still not satisfied then they should be advised of their right to legal recourse.” Liberia and Burkina Faso only indicate that complainants will be advised on their right to legal recourse with no appeals process first. Five of the 11 GRMs are operationalized specifically to be able to handle cases of gender-based violence (GBV), sexual exploitation and abuse (SEA), and/ or secual harrassment (SH): Liberia, Philippines, Sri Lanka, Burkina Faso, and Nepal. The Uganda and El Salvador SEPs indicate that the projects will make available information about GBV and hotlines that people can use to report GBV, but do not explicitly state that these hotlines are in any way connected to the project’s GRM. 2. Consultations about GRMs with representatives of marginalized groups and GRCs The terminology used to describe what types of cases the GRMs will be able to handle is different in the SEPs. Specifically, the Liberia and Sri Lanka SEPs indicate that the GRMs will be “strengthened with procedures to handle allegations of GBV/SEA/ SH.” The Philippines, Burkina Faso, and Nepal SEPs indicate that the GRMs will have processes to address GBV-related issues. The Uganda and El Salvador SEPs describe the fact that the Ministries of Health will disseminate information about services and hotlines that people can use to report cases of GBV/SEA/SH as well as violence against children (VAC). None of the SEPs indicate that affected communities provided any input on the design of the GRMs, but those of the Philippines, Guatemala, and Cambodia indicate that the design will take into account the needs and concerns of Indigenous Peoples. Six of the 11 SEPs indicate that an entity other than the project implementing unit (PIU) will manage grievances and handle the GRM, either through a dedicated grievance redress committee (GRC) or other departments or lower tiers of the Ministries of Health: the Philippines, El Salvador, Sri Lanka, Uganda, Cambodia, and Nepal. The other SEPs indicate that the PIU will handle grievances, or in the case of LIberia, there is no mention of who will oversee the GRM. Only two SEPs provide criteria for the type of people that can compose their GRCs. Uganda’s SEP says that BANK INFORMATION CENTER | MAR 2021 Though only 5 projects indicate that their GRMs will specially handle GBV/SEA/SH complaints, all 11 projects’ ESRSs point to the fact that there is a potential risk of some combination of GBV/SEA/SH and VAC. The risk, however, comes up in different parts of the ESRSs in different ways: • The ESRSs for El Salvador, Sri Lanka, Burkina Faso, and Uganda mention the risk under “Social Risk Rating” in the “Environmental and 40

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