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
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