Despite including much more information about consultations, the revised SEP does not meet the ESF requirement to describe the timing of engagement by providing a timeline for consultations.20 As the template SEP suggests to Borrowers, if the Borrowers did not know when and where they would conduct consultations during project preparation, they should provide ways for stakeholders to get that information, but these ways are not made clear despite consultations having already begun at the time the revised SEP was disclosed. Without a timeline for consultations or ways to access the times in the future, stakeholders may not know when and where to go to participate in them. Furthermore, both the Bank and appropriate personnel cannot monitor that consultations are occurring and the Borrower cannot easily be held to account for conducting them. D. Grievance Redress Mechanism (GRM) 1. Anonymous complaints and forms of appeal in the GRM process → The revised SEP has a more thorough description of the GRM that allows for stakeholders to submit complaints anonymously and appeal decisions Borrowers are required to set up grievance mechanisms that “allow for anonymous complaints to be raised and addressed.”21 According to the annex of ESS10, the mechanism also “may include... an appeals process to which unsatisfied grievances may be referred when resolution of grievance has not been achieved.”22 paramount.”23 In Appendix 4 of the SEP, “Sample letter of acknowledgement of receipt of an ineligible complaint,” which states the name of the complainant is “not required if anonymous.”24 The description of the grievance mechanism also explicitly includes a method for complainant to appeal the grievance process. Complainants “may appeal to the Minister for Health...and will be reassured of their legal rights under the national judicial process to go to court.”25 With this additional information included about the GRM, Liberia’s Ministry of Health revised the description of the mechanism to meet these ESS10 requirements. 2. Consultations about GRMs with representatives of marginalized groups → The revised SEP points to strategies to remove obstacles to participation for some marginalized groups See section C.1 in the main text for more information about relevant ESF requirements Borrowers are required to set up grievance mechanisms that are “expected to address concerns...in a transparent manner that is culturally appropriate and readily accessible to all projectaffected parties.”26 The revised SEP provides much more information about the grievance mechanism and process. Unlike the original, it addresses the requirement to “allow for anonymous complaints” and states that “in handling GRM matters, confidentiality will be Neither the original or revised SEP detail how the GRM will be set up to address complaints in a way that is “culturally appropriate.” As explained in the main text, guidance for Borrowers suggests that they should design grievance mechanisms in consultation with any project-affected Indigenous Peoples. While no Indigenous group is considered a project-affected stakeholder in the case of the LCERP, our analysis in the main text concludes that consultations with all marginalized groups would make it easier for these groups to know of the GRM’s existence and instruct Borrower’s in how to set up mechanisms in a “culturally appropriate” way that make stakeholders feel comfortable filing complaints. The analysis further concludes that it is good practice for projects’ Grievance Redress Committees (GRCs) -- which handle grievances that are submitted about projects -- to include representatives from marginalized groups. While it is not a requirement, the LCERP project staff consulting with all marginalized groups about their GRM and including representatives from these groups in its GRCs would help make 20 “Revised SEP - Liberia COVID-19 Project,” 29. 21 See 3eii under ESS10 in Annex 1: “Environmental and Social Framework,” 99, par. 27(b). 22 “Environmental and Social Framework,” 101, par. 2(d)-2(e). 23 “Revised SEP - Liberia COVID-19 Project,” 41. 24 “Revised SEP - Liberia COVID-19 Project,” 48. 25 “Revised SEP - Liberia COVID-19 Project,” 41. 26 See 3ei and 3eii under ESS10 in Annex 1: “Environmental and Social Framework,” 99, par. 27-27(a) The original LCERP SEP did not indicate that complaints could be filed anonymously. By not addressing anonymity of complaints, the SEP did not make clear that stakeholders have the choice to remain anonymous when submitting grievances. While it states that complainants will be “advised of their right to legal recourse” if they are not satisfied with the redress, it does not indicate that appeals are possible through the GRM. This obfuscates the way that complainants can seek legal recourse. BANK INFORMATION CENTER | MAR 2021 45