Table 4: Involvement of Marginalized Groups in GRMs
Country SEP
Is ESS7 being applied,
according to the
ESCP?
Does the SEP indicate
that the GRM will take
"into account the
needs" of Indigenous
Peoples?
Does the SEP indicate
that marginalized will
be consulted about
the GRM?
Will women be
included on the
project's Grievance
Redress Committee?
Burkina Faso
No
No
No
No
Liberia
No
No
No
No
The Gambia
No
No
No
No
Uganda
Yes
No
No
Yes
Bangladesh
Yes
No
No
No
Nepal
Yes
No
No
No
Sri Lanka
No
No
No
No
Cambodia
Yes
Yes
No
Yes
Philippines
Yes
Yes
No
No
El Salvador
Yes
No
No
No
Guatemala
Yes
Yes
No
No
Total Yes
7
3
0
2
Total No
4
8
11
9
obtained any feedback from any other affected and
marginalized communities or that grievances will be
handled in a way that is appropriate to them. None
stipulate that they should be set up in a child-friendly
manner. Marginalized communities are already more
susceptible than others to the negative health and
economic impacts of the pandemic. Without having
consulted these communities, such as children or
illiterate individuals, they may not know the GRMs
are in place nor how to utilize them. Children may
be most likely to have trouble accessing or learning
about the GRMs, so communities and child-focused
agencies should know how to support children to
utilize them.
Although none of the GRMs were designed with
feedback from marginalized groups, Table 4 shows
that the Cambodia and Uganda projects indicate that
women would be included on the projects’ Grievance
Redress Committees, which handle grievances that
are submitted about the projects.59 This is a good
practice that should be replicated and expanded in
59 Hyder, “SEP - Cambodia COVID-19 Project,” 8; Borrowing Agency,
“SEP - Uganda COVID-19 Project,” 9.
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other projects GRCs to include representatives from
other marginalized groups, such as a member of
Indigenous Peoples and child advocacy groups, who
understand the possible concerns and grievances
that project-affected communities might experience.
2. GRMs equipped to handle GBV/SEA/SH
Relevant ESF requirements and guidance for
equipping GRMs to handle GBV/SEA/SH
Borrowers are required to set up grievance
mechanisms in a way that is readily accessible and
proportionate to the potential risks and impacts of
projects.60 They must address grievances “promptly
and effectively, in a transparent manner” and
“allow for anonymous complaints to be raised
and addressed.”61 They should also “require all
grievances to be treated confidentially, impartially,
objectively, and in a timely manner.”62
60 See 3ei under ESS10 in Annex 1; “Environmental and Social Framework,” 100, par. 27. If suitable for the project, “grievance mechanism may
utilize existing formal or informal grievance mechanisms.” See “Environmental and Social Framework,” 11, footnote 41.
61 See 3eii and 5c under ESS10 in Annex 1; “Environmental and Social
Framework,” 100, par. 27(a)-(b).
62 See 3p under ESS10 in Annex 1; “Guidance Note: ESS10,” 9, GN27.5.
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