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
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