REPUBLIC OF LEBANON Ministry of Finance (MOF) Lebanon Fiscal Management Project (P181155) PRELIMINARY STAKEHOLDER ENGAGEMENT PLAN (SEP) BEIRUT October 2023 1 Abbreviations and Acronyms AFD Agence Française de Développement CERC Contingent Emergency Response Component COVID-19 Coronas Virus CSO Civil Society Organization E&S Environmental and Social ESF Environmental and Social Framework ESS Environmental and Social Standard EU European Union GDP Gross Domestic Product GOL Government of Lebanon GM Grievance Mechanism ICT Information and Communication Technologies IMF International Monetary Fund LFF Lebanon Financing Facility LMP Labor Management Procedures LPHU Lebanese Physically Handicapped Union MENA Middle East and North Africa MOE Ministry of Environment MOF Ministry of Finance MOSA Ministry of Social Affairs NACC National Anti-Corruption Commission NGO Non-Governmental Organization PBC Performance-Based Condition PCU Project Coordination Unit PFM Public Financial Management SEA/SH Sexual Exploitation and Abuse/Sexual Harassment SEP Stakeholder Engagement Plan UNDP United Nations Development Programme UNHCR United Nations High Commissioner on Refugees WB World Bank 2 Table of Contents Abbreviations and Acronyms ........................................................................................................................ 2 Table of Contents .......................................................................................................................................... 3 List of Tables ................................................................................................................................................. 4 1. Introduction and Project Description ............................................................................................... 5 2. Objective/Description of SEP ............................................................................................................ 7 3. Stakeholder identification and analysis ............................................................................................ 7 3.1 Methodology ................................................................................................................................... 7 3.2. Affected parties and other interested parties ............................................................................... 8 3.3. Disadvantaged/ vulnerable individuals and groups ........................................................................... 9 4. Stakeholder Engagement Program ................................................................................................. 10 4.1. Summary of stakeholder engagement done during project preparation .................................... 10 4.2. Summary of project stakeholder discussion ................................................................................ 11 4.3. Stakeholder engagement plan ..................................................................................................... 13 4.4. Reporting back to stakeholders ................................................................................................... 13 5. Resources and Responsibilities for implementing stakeholder engagement activities ................. 14 5.1. Human Resources......................................................................................................................... 14 5.2. Budget .......................................................................................................................................... 14 6. Grievance Mechanism .................................................................................................................... 14 6.1. Description of GM ........................................................................................................................ 14 6.2. Principles of a Grievance Mechanism .......................................................................................... 15 6.3. Grievance Mechanism Handling Process ..................................................................................... 16 7.1. Summary of how SEP implementation will be monitored and reported..................................... 19 7.2. Reporting back to stakeholder groups ......................................................................................... 20 3 List of Tables Table 1: Feedback received on consultations ............................................................................................. 10 Table 2: Summary of stakeholders needs ................................................................................................... 12 Table 3: Strategy Engagement Plan ............................................................................................................ 13 Table 4: Proposed Budget for SEP Implementation ....................................... Error! Bookmark not defined. 4 1. Introduction and Project Description For more than three years, Lebanon has been impacted by a devastating multi-pronged crisis. The unfolding economic and financial crisis that started in October 2019 has been further exacerbated by the dual economic impact of the COVID-19 outbreak, and the Port of Beirut explosion in August 2020. Lebanon crisis ranks among the worst crises globally since the mid-nineteenth century1. Real GDP has contracted by close to 40 percent since 2018 while nominal GDP plummeted from close to US$52 billion in 2019 to an estimated US$21.5billion in 2022; the crisis has wiped out more than 15 years of economic growth. The crisis has caused staff attrition and absenteeism in the public sector, severely impacting the government’s ability to respond to the crisis, maintain core government operations and basic services for citizens, and to create the foundations for recovery. Currency devaluation has eroded public sector salaries, rendering them too low for civil service staff to afford fuel costs to commute and basic day-to- day necessities. As a result, a significant number of staff have left the public sector, either for the private sector where salaries have been partially adjusted or for opportunities abroad, leaving a critical skills gap in the public sector. For staff that remain, there are high absenteeism rates with a majority of staff only coming into the office one day of the week. The proposed project will bring development results by restoring critical public financial management functions. The Project Development Objective is to mobilize and allocate public resources in an accountable manner, to support the crisis response and recovery in Lebanon. The project is comprised of 4 components and a CERC component: Component 1: Stabilizing Revenue Administration in Domestic Revenue Mobilization (US$12.1 million: loan US$10.6 million and grant US$ 1.5 million). This will help provide much-needed fiscal space to allocate funding for urgent needs and to finance recovery and/or debt reduction. It is comprised of 3 subcomponents as follows: Subcomponent 1.1: Strengthening Large Taxpayer Office and Large Debtor Unit. The aim of the subcomponent is to enhance tax compliance. Subcomponent 1.2 Restoring basic functions of Customs. The project will support implementation of the existing Customs Law through training and capacity building, to ensure basic functioning of the customs administration and to be in alignment with international obligations. Subcomponent 1.3: Restoring Revenue management ICT systems. The subcomponent will provide support to maintain and make critical upgrades to the hardware, software, and the ICT capacity of the tax and customs ICT systems. Additionally, funding will be provided to install solar panels for electricity generation, in the buildings of these agencies as needed. Component 2: Restoring Fiscal Controls (US$ 12.4 million: loan US$10.4 million; grant US$ 2 million). The objective of the proposed component is to reestablish the critical pillars for allocating and utilizing resources to meet urgent needs and set the foundation for recovery. The component supports the following subcomponents: Subcomponent 2.1: Strengthening Budget 1 World Bank Spring 2021 Lebanon Economic Monitor. 5 Preparation. The subcomponent will support the resumption of a budget preparation process that will result in a timely and balanced annual budget, underscored by a sound macro fiscal framework and supports the crisis response and recovery. Subcomponent 2.2: Regularizing Fiscal Reporting. The subcomponent will support the clearance of the backlog and regularize the generation of budget execution reports, annual financial statements, and bank reconciliations that are essential for closely monitoring budget execution and fiscal risks. Subcomponent 2.3. Maintaining Timely Payments. This subcomponent supports the maintenance of an efficient payment function. Subcomponent 2.4. Restoring Cross-cutting ICT functionalities. The subcomponent will replace urgent main hardware such as servers, software and licenses that provide cross cutting support to expenditure management. Funding will be provided to install solar panels for electricity generation, in the buildings of these agencies as needed. Component 3: Revitalizing Oversight and Accountability Institutions and Procurement Capacity Building (USD$ 5 million: loan US$ 5 million; grant US$ 0). This component aims to restore the role and capacity of the Court of Accounts (CoA), Central Inspection (CI) and the institute of finance and new public procurement institutions in their oversight, audit, capacity building and inspection mandates and expand their engagement with the citizens. Subcomponent 3.1 Increase Capacity to oversight and accountability institutions. In the short term, support will be provided to strengthen the capacity of the Court of Accounts (CoA) and Central Inspection (CI) in performing some of their core functions. Subcomponent 3.2 Procurement certification programs and training. The proposed initiative will support establishing a certification program in public procurement. A third-party certification entity will independently certify practitioners’ learning performance. IT equipment, office supplies, and software for the operations and for training of management shall be supported. Furthermore, funding will be provided to install solar panels for electricity generation, in the buildings of these agencies as needed. Component 4: Project Management (US$2.5 million: loan US$2.5 million; grant US$ 0). This component will support the management, coordination, communication and M&E of project activities. Component 5: Contingent Emergency Response Component - CERC (US$ 0). This component will support provision of immediate response to an Eligible Crisis or Emergency, as needed. The Project is being prepared under the World Bank’s Environment and Social Framework (ESF). Per Environmental and Social Standard (ESS)10 on Stakeholder Engagement and Information Disclosure, the implementing agency, MOF should provide relevant stakeholders with timely, relevant, understandable, and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination, or intimidation. This Stakeholder Engagement Plan (SEP) is prepared to respond to the requirements of ESS10. It is a living document and will be updated as needed in line with the ESCP during the project life cycle. Other E&S instruments were prepared for this project and these are the Environmental and Social Engagement Plan (ESCP), the Labor Management Procedures (LMP), the Occupational Health and safety Plan (OHS) Plan and the Waste Management Plan (WMP). 6 2. Objective/Description of SEP The overall objective of this Stakeholder Engagement Plan (SEP) is to define a program for stakeholder engagement, including identification of relevant stakeholders, public information disclosure and consultation throughout the entire project cycle. The SEP outlines the ways in which the project team will communicate with identified stakeholders and includes a mechanism by which people can raise concerns, provide feedback, or make complaints about project activities or any activities related to the project. 3. Stakeholder identification and analysis 3.1 Methodology To meet best practice approaches, the project will apply the following principles for stakeholder engagement: • Openness and life-cycle approach: Consultations for the relevant project(s) activities will be arranged during the whole life cycle, carried out in an open manner, free of external manipulation, interference, coercion, or intimidation. • Informed participation and feedback: Information will be provided to and widely distributed among identified stakeholders for relevant project activities in an appropriate format; opportunities are provided for communicating stakeholder feedback, and for analyzing and addressing comments and concerns. • Inclusiveness and sensitivity: Stakeholder identification is undertaken to support better communications and build effective relationships. The participation process for the projects is inclusive. All identified stakeholders at all times are encouraged to be involved in the consultation process. Equal access to information is provided to all identified stakeholders. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods. Special attention is given to identified vulnerable groups, if any, that may be at risk of being left out of project benefits, particularly women, the elderly, persons with disabilities, displaced persons, and migrant workers and communities, and the cultural sensitivities of diverse ethnic groups. • Flexibility: If governance factors (for example, high risk of retaliation) inhibit traditional forms of face- to-face engagement, the methodology should adapt to other forms of engagement, including various forms of internet- or phone-based communication. • Scope: As different project activities are geared to different stakeholders; the above approach will be targeted to stakeholders identified to a specific project activity. Following the main principles of proportionality to project activities, flexibility, inclusiveness and sensitivity as outlined above and as per ESS10 objectives, the Borrower will engage, throughout the project life cycle, with the below identified 3 categories of stakeholders including project affected parties, other interested parties and vulnerable groups, with the objective of raising awareness related to the proposed project components, the Environmental and Social Framework (ESF), the project associated environmental and social impacts and the respective mitigation measures in line with the key environmental and social instruments which have been prepared under this project as mentioned above. The project grievance mechanism and responsible persons in charge of implementation and monitoring of the E&S instruments will also be effectively communicated to affected stakeholders. The dissemination of the project information will also be coordinated closely with the communications specialist to ensure all relevant project details and information are adequately communicated following the relevant channels and will be documented. 7 3.2. Affected parties and other interested parties 1- The Ministry of Finance (MOF) leads the Government’s economic reform through sound formulation and management of fiscal policy and public debt in order to foster sustainable economic growth in alignment with national priorities. 2- The Ministry of Environment (MOEsets the national environmental policy. The service of MOE) sets the national environmental policy. The service of Urban Environmental Protection is mandated the monitoring of solid waste. 3- Lebanese Center for Energy Conservation (LCEC): LCEC’s mission is to lead the efforts of Lebanon in the development of Energy Efficiency and Renewable Energy to increase energy security and de-carbonization levels. LCEC proactively develops policies, implement projects, and shape the market in harmony with the global sustainable energy transition (https://lcec.org.lb). As the technical arm of the Ministry for Energy and Water, LCEC is involved in supporting projects and initiatives launched by the Ministry in the sustainable energy sector. 4- Ministry of Energy and Water (MoEW): The Ministry of Energy and Water undertakes the affairs of water, electricity, oil, minerals, mines and quarries. The LCEC falls under the responsibility of the MoEW. 5- The Central Inspection has the authority to audit all public institutions. It plays a central role in uncovering any violation of the applicable laws and regulations. It provides also guidance, advice and recommendations to improve administrative processes and coordinate joint operations between public administrations. 6- Public Procurement Institutions such as the Central Tender Board that is meant to act as the main public procurement agency. 7- The Court of Accounts is tasked with overseeing the management of public funds. Its mandate does not cover all public bodies as its role overlaps with the MOF in control over proposed and past expenditure, and punishments. 8- Council of Ministers (COM) which will lead the reform under the Lebanon Financing Facility (LFF) umbrella as the project will benefit from parallel co-financing from the multi-donor Lebanon Financing Facility (LFF) for Reform, Recovery and Reconstruction. 9- National Anti-Corruption Commission (NACC) that is responsible for disclosing the financial disclosures of employees, heads of state, MPs, and ministers, punishing illicit enrichment, recovering funds obtained through corruption, protecting whistle-blowers, preserving the right to access information, supporting transparency in the petroleum sector, combating money laundering and terrorist financing, and exchanging information for investigative purposes. 10- United Nations Development Programme (UNDP) is carrying out an e-readiness assessment as part of the digital transformation reforms, and potentially supporting Domestic Revenue Mobilization (tax compliance policy). UNDP is also carrying out a diagnostic on civil servants’ incentives provided within the Lebanese administration 11- Agence Française de Développement (AFD) is a public financial institution that implements the policy defined by the French Government. It works to fight poverty and promote sustainable development. AFD is providing technical assistance on public procurement reforms. 8 12- The European Union (EU) is a major contributor to the Lebanon Financing Facility (LFF) and is committed to provide additional $20 million contingent on the implementation of the IMF Staff-Level Agreement (SLA) leading to a comprehensive reform program. In addition, the EU is contributing to transparency and accountability reforms through its support to oversight bodies. 13- IMF is conducting consultations, assessing the economic situation in the Country, and discussing policy priorities. In April 2022, a SLA with the IMF was reached on a US$3 billion, 46-month lending program (Extended Fund Facility), subject to the implementation of eight prior actions and confirmation of international partners’ financial support. 14- LFF Donors: The project will benefit from parallel co-financing from the multi-donor Lebanon Financing Facility (LFF) for Reform, Recovery and Reconstruction. The proposed subcomponent under component 1 will build upon and be linked to results of the planned Civil Service Census to be conducted under the Fiscal Governance and Restoration ASA (P181162) using LFF funds 15- The Environmental and Social Non-Governmental and Civil Society Organizations (E&S NGOs and CSOs) that are most active and who have knowledge about the environmental and social risks. The NGOS and CSOs are distributed in the sectors of environment, social, women, disabled and youth such as such as Lebanon Eco Movement, Lebanon Environment Forum, Live Love Recycle, Arcenciel which is involved in waste management, Lebanese Solar Energy Society which has members involved professionally and academically in promoting the use of solar and renewable energy. 16- Academic Institutes such as: The American University of Beirut (AUB), Universite Saint Joseph (USJ), Universite Saint Esprit (USEK), University of Balamand 17- Public Administration Employee’s Union 18- The Arab Watch Coalition is a regional coalition of civil society organizations that monitors the operations of International Financial Institutions in the region to make sure that the development processes are inclusive, participatory, just, and sustainable for all. The coalition engages with civil society, local communities, and right-holders to ensure their interests are reflected in national development2. 3.3. Disadvantaged/ vulnerable individuals and groups It is important to understand project’s impacts and whether they may disproportionately fall on disadvantaged or vulnerable individuals or groups, who often do not have a voice to express their concerns or understand the impacts of a project. The project activities which are associated with minor civil works during IT upgrading and installation of solar panels may have disproportionate impacts on women groups and persons with physical disabilities and the youth through potential community health and safety impacts involving waste generation (including e-waste) and disposal sites and other traffic related risks associated with transport and shipment of goods and materials for the minor civil works associated with the project activities. Relevant NGOs representing such vulnerable groups will be involved in the consultations and include the Lebanese Union for People with Physical Disabilities, and Kafa. 9 4. Stakeholder Engagement Program 4.1. Summary of stakeholder engagement done during project preparation During project preparation, the following consultation meetings and workshops were conducted to discuss project design. o Ministry of Finance: ▪ Minister’s office ▪ Acting Director General’s Office ▪ Macro-fiscal department ▪ Public Debt Directorate ▪ IT Department ▪ Budget Directorate ▪ Customs DirectorateRevenues and VAT Directorate ▪ Expenditures Directorate ▪ Cash Management Department ▪ Treasury Directorate ▪ Public Accounting Directorate o Prime Minister’s Office ▪ Deputy Prime Minister ▪ Advisors to the Prime Minister o Court of Accounts o Central Inspection o Institute of Finance The summary findings and conclusions of the environmental and social instruments which were prepared by the MoF including the Environmental and Social Commitment Plan (ESCP), the Labor Management Procedures (LMP), Stakeholder Engagement Plan (SEP), Occupational Health and Safety Plan (OHS Plan) and the Waste Management Plan (WSMP) were presented by MoF via a brief in a written email and shared with all identified stakeholders as detailed above. Feedback received to date during consultations were taken into account. A summary of the main recommendations received and integrated into the Stakeholder Engagement Plan is provided in table 1. Table 1: Feedback received on consultations Stakeholder Dates of Summary of Response of Follow-up Timetable/ Date (Group or Consultations Feedback Project Action(s)/Next to Complete Individual) Implementation Steps Follow-up Team Action(s) 10 Beneficiary June and July Design: Project design Further August/September institutions 2023 • Technical will factor in updates on 2023 (MoF, CoA, assistance these project design CI) should be suggestions via will be field based results based provided and financing and an during project available expenditure appraisal regularly framework that • A conducive funds the work requirements to environment achieve results . is key to staff productivity • Pragmatic measures are essential to bring staff back to work. Currently there is a high cost for regular attendance at work Minister of June and July Design: Project design Further August/September Finance and 2023 Results-based will factor in updates on 2023 Prime financing is welcome these project design Minister’s suggestions via will be Offices results-based provided financing during project appraisal CSOs and October 2023 Invitations sent out Academia 11 October 2023 and feedback is expected within 10 days. This section will be updated thereafter with feedback from the stakeholders and the SEP will be revised and redisclosed further to obtaining Bank clearances. 4.2. Summary of project stakeholder discussion Different engagement methods will be considered throughout the project life-cycle and cover different stakeholders needs as stated in Table 2 below: They may include (i) phone calls, (ii) focus group meetings/discussions, (iii), one-on-one interviews, (iv) meetings, (v) disclosure of information on social 11 media or by emails, (vi) official correspondence and through engagement with the relevant and identified CSOs and NGOs Table 2: Summary of stakeholders needs Stakeholder Key Language Type of notification (e.g., Specific needs Group Characteristics s needs email, phone, radio, letter) Government − MOF Arabic − Email. Agencies including − official correspondence customs − Phone Technical assistance to administrati − Consultation meetings enhance work processes, on − one-on-one interviews emergency IT requirements − MOSA, − formal meetings to maintain the existing IT − MoE, − roundtable discussions facilities and prepare for MoEW, LCEC recovery, staff availability − , and a conducive work − Court of environment. Appeals, − Central Inspection, − Public Procuremen t Institutions, − Court of Accounts, − NACC. International English − Email. Organizations − UNDP, − official correspondence Transparency throughout − AFD, − Consultation meetings project life-cycle − EU /LFF, − formal meetings − IMF. − roundtable discussions NGOs & CSOs − E&S Arabic − Email. Transparency throughout − Recycling and − official correspondence project life-cycle and e-waste English − Phone − Solar energy − Consultation meetings − one-on-one interviews − formal meetings − roundtable discussions. Academic − High level Arabic − Email.official No specific need Institutes education and correspondence Public English − Phone − Consultation meetings − one-on-one interviews − formal meetings − roundtable discussions. 12 Stakeholder Key Language Type of notification (e.g., Specific needs Group Characteristics s needs email, phone, radio, letter) MoF − Very large Arabic Disseminate information Transparency throughout Administratio number through union project life-cycle n Employees − All levels of − Email. literacy − official correspondence − Consultation meetings − one-on-one interviews − formal meetings − roundtable discussions 4.3. Stakeholder engagement plan The stakeholder engagement plan is presented in Table 3 below. Information will be disclosed using the preferred notification and languages needs presented in Table 2. Table 3: Strategy Engagement Plan Project Stage Estimated Topic of Method Used Target Responsibilities Date/Time Consultation/ (examples) Stakeholders Period Message Project Design Pre-Appraisal Project Phone All identified MOF Description Email stakeholders SEP Focus groups Labor Consultation Management meetings Procedures one-on-one (LMP) interviews Grievance formal Mechanism meetings (GM) roundtable discussions Implementation During the Activities under Workshop All identified MOF and PCU Phase implementation implementation Social media stakeholders E&S specialist of the project and results Meetings with and activities GM stakeholders communication specialist Pre project After project Information Social Media All identified MOF and PCU closure end about impact, stakeholders E&S specialist sustainability 4.4. Reporting back to stakeholders Stakeholders will be kept informed, as appropriate, as the project develops, including reporting on project environmental and social performance and implementation of the SEP and GM, and on the project’s overall implementation progress, as relevant to specific stakeholder. 13 5. Resources and Responsibilities for implementing stakeholder engagement activities 5.1. Human Resources The MOF will be in charge of the stakeholders’ engagement activities as outlined in this SEP. The MOF and the E&S specialist (to be hired as per the ESCP) will establish the process in due time. 5.2. Budget The budget for the SEP is 18000 $US and is included in component 3 of the project. The E&S specialist who will be recruited as part of the project and in line with the ESCP will ensure the monitoring and implementation of the below with due documentation in the progress report. Table 4: Proposed Budget for SEP Implementation Budget Category Quantity Unit Costs Times/Years Total Costs Remarks 1. Estimated staff salaries* and related expenses Included in 1a. E&S specialist the PM cost 2. Events 2a. Focus groups, group meetings and 2 1000 workshops 2000 3. Communication and disclosure of information 3b. social media campaign and disclosure of information - 4. Trainings 4a. Training on stakeholders’ engagement for PCU 2000 4b. Training on gender-based violence (GBV) for PCU and consultant/contractors staff 2,000 6. Grievance Mechanism 6a.Establishment of a solid GM 10,000 6b. Training of E&S specialist on GM 2,000 TOTAL STAKEHOLDER ENGAGEMENT BUDGET: 18000 6. Grievance Mechanism 6.1. Description of GM The main objective of a Grievance Mechanism (GM) is to assist in resolving complaints and grievances in a timely, effective, and efficient manner that satisfies all parties involved. GMs refer to the formal institutions and channels that capture relevant beneficiary complaints or grievances related to targeting, service delivery, or other program functions, and provide redress. GMs 14 are not just developed for complaints since they also constitute a channel for a two-way communication between the implementer and the different stakeholders to communicate, share feedback, inputs, recommendations or any concerns or questions. Effective GM facilitates Project progress by reducing the risk that unaddressed complaints eventually lead to implementation delays, lengthy court procedures, or adverse public attention. The GM will be accessible to all relevant stakeholders who can use this mechanism to send their suggestions, concerns and complaints related to the Project. The GM aims to provide individuals and communities who feel aggrieved by Project activities with accessible, timely, effective and culturally appropriate opportunities to raise their complaints, feedback, concerns and questions about the Project when it directly affects the complainant. It also aims to identify, propose and implement fair and appropriate solutions in response to the complaints and concerns raised. Specifically, the objectives are to: • Establish a system for receiving, recording and processing complaints and concerns in a timely manner with particular attention to vulnerable groups. • Provide an effective, transparent, timely, fair and non-discriminatory system that would allow aggrieved persons to complain and avoid litigation. • Ensure the sustainability of Project interventions and ownership by stakeholders. • Minimize bad publicity and delays in Project implementation. • Provide clarification in response to requests for information in a timely manner. • Encourage the amicable settlement of complaints and avoid, whenever possible, recourse to the courts. 6.2. Principles of a Grievance Mechanism The GM is guided by several key principles like: ▪ Protect the confidentiality and anonymity of complainants; practicing non-discrimination, centering their safety, and treating them with dignity and respect for their needs. The project staff must be trained on how to preserve the confidentiality and safety of complainants. ▪ Adopt risk-based approaches that aim to identify key risks of Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH) and to undertake measures to prevent or minimize harm. ▪ Engage community partners as resources for knowledge on local-level risks, effective protective factors and mechanisms for support throughout the project cycle. ▪ Adapt and adjust prevention and mitigation measures to respond to the unique drivers. ▪ Ensure operations integrate mechanisms for regular monitoring and feedback to track effectiveness and to build internal knowledge of what works to prevent, mitigate and respond to complaints in any given setting. ▪ Adopt accessible, collaborative, expeditious, and effective approaches in resolving concerns through dialogue, joint fact-finding, negotiation, and problem solving In general, GMs need to have multiple uptake channels, need to be accessible, collaborative, expeditious, and have timely responses and effective in resolving concerns through dialogue, joint fact-finding, negotiation, and problem solving. 15 6.3. Grievance Mechanism Handling Process a) Receive and register grievance Uptake channels should be available to gather and forward local people’s concerns to ensure widespread accessibility. Currently, aggrieved stakeholders (complainants) can communicate their grievances by contacting Mrs Claudine Karaki by email on Claudinek@finance.gov.lb, Mr. Hasan Hamdan on by email on Hasanh@finance.gov.lb or Mrs Bassima Antonios by email on Bassimaa@finance.gov.lb . If there are any changes in the uptake channels, MoF will update the relevant information and will redisclose the SEP as per the provisions of the escp. MoF will also reflect the updates on their project website. MoF will compile all grievances in a grievance log which will be submitted on a regular basis with the quarterly progress reporting in line with the ESCP. This will be under the responsibility of the E&S specialist who will be recruited as part of the PMU and in line with the provisions of the ESCP. A variety of channels are already available but may not be operational for the time being, they are listed below. The SEP will be updated to include all contact details as soon as they are available as per the requirements of the ESCP; all contact details to be developed and established during the project preparation and included in an updated SEP which will be cleared by the Bank and redisclosed before commencement of project activities. • By email on infocenter@finance.gov.lb; Claudinek@finance.gov.lb, Hasanh@finance.gov.lb, Bassimaa@finance.gov.lb . • Through the following link http://www.finance.gov.lb/en-us/Pages/ContactUs.aspx • By submitting an official letter through MOF registrar The existence of the GM will be consistently publicized during all stakeholder engagement activities (meetings, focus group discussions, etc.) and also on the MoF website. In addition, the day and time of operation of the GM needs to be clearly mentioned in the SEP and communicated to all stakeholders. Grievance Registration The MOF will establish a centralized database (complaints log or data system) supported by the MOF E&S specialist and will require that all grievances received be logged into that database. Centralized logging and tracking are important both for accountability and for enabling continuous learning. The MOF E&S specialist will ensure coordination with those personnel handling the calls and grievances followed by documentation. The centralized database will include the following: ▪ A unique reference number of the complaint. ▪ The date and time of the complaint. ▪ Information about the complainant (name, gender, telephone number and preferred contact details, residence and address); complainant has the right also to raise the grievance anonymously. ▪ A brief description of the complaint to include details of the location, people involved so that a timeline of events can be created. ▪ The category of the complaint. A major incident requires reporting to World Bank within 48-hours. ▪ Time and date in which the complaint was closed/resolved. 16 ▪ Note if the complainant chose to appeal. b) Acknowledge, Assess, Assign This step determines whether a complaint is eligible for the grievance mechanism. There should be a system to categorize, assign priority, and route grievances to the appropriate entity for handling and resolution. Acknowledging receipt: Once information that a grievance has been received, the MOF centralized database will be updated. The person/entity raising the grievance will be contacted by the MOF E&S specialist to request additional information, if needed, within 3 working days from receipt of the grievance. Complaints could be acknowledged either in writing or through a phone call, depending on the complainant’s preference. The acknowledgement of receipt shall contain information about the next steps in the procedure, target timeframe and the contact details of the person who has been assigned to investigate and manage the grievance. Clear timetables need to be made publicly available. Assessing eligibility for the GM: The MOF will ensure that the issue being raised is relevant to the project. The MOF E&S specialist, responsible for the initial response, follows clear guidelines on what kinds of issues are eligible to be handled through the GM, and what issues should be referred to other mechanisms. The types of complaints and questions/concerns or feedback to be dealt with are as follows: • Concerns, questions, and clarifications related to the Project itself. • Environmental impacts and nuisance (air pollution, noise, dust, vibrations etc.) as minor civil works are expected for the upgrading of the Information and Communication Technologies (ICT) • Claims related to Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH). Major incidents need to be reported to the World Bank within 48 hours (injury-related grievances, SEA/SH-related grievances, labor and livelihood-related grievances). The process for addressing complaints would typically be along the following lines: • Nature of Complaints Grievances related to Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) are to be treated with confidentiality. The E&S specialist at MOF will be receiving those grievances first, and then the MOF will refer to the relevant GBV service providers as per the consent of the complainant. The World Bank team will be informed of any such incidents within 48 hours. • The MOF E&S specialist will keep SEA/SH allegation reports confidential and, unless the complaint was received through the GBV service provider or other identified reporting channels, refer the survivor immediately to the GBV service provider, depending on the consent of the complainant/survivor. • The GBV service providers accompany survivors throughout the process and play a critical role by updating them on the grievance management progress and on safety planning, especially when sanctions are envisaged or will soon be implemented. • As part of the established resolution mechanism SEA/SH allegations are considered and assessed, paying attention to due process for all involved, and in coordination with the accountability framework of the employer of the subject of the complaint. Agreement is reached on a plan for resolution as well as the appropriate disciplinary action for the perpetrator, all within the shortest timeframe possible to avoid further trauma to the survivor. 17 Assigning responsibility: The MOF E&S specialist is responsible for delegating the investigation to relevant personnel based on the type of grievance received. The grievance shall be investigated, and an Investigation Report shall be prepared and issued by the MOF E&S specialist after coordinating with relevant personnel, within 15 working days from registration of the grievance. The investigation shall involve an examination of the circumstances of the case and interviews with the parties involved. The report shall include details of the proposed steps to be taken to resolve the grievance based upon the facts. If resolution steps require disbursement of financial resources, the case shall be raised to the Project Manager for review and action. c) Develop a proposed response and seek agreement on the response The MOF E&S specialist will inform the person raising the grievance, within 10 working days from the date when the grievance was registered, of the outcome of the Investigation and of the proposed steps to be taken to resolve the grievance. This shall be conducted through a physical meeting/or remotely (if possible), with all persons who are able to be present. When there is agreement between a complainant and the E&S specialist to move forward with the proposed action or stakeholder process, then the response should be implemented within the agreed timeframe, and the grievance will be closed. If the person does not accept the resolution steps, MOF E&S specialist needs to make sure the complainant understands what other recourse may be available, whether through the judicial system or other administrative channels, and to document the outcome of the discussions with the complainant in a way that makes clear what options were offered and why the complainant chose not to pursue them. The persons will be able to appeal (as detailed below). d) Appeal Procedures As noted above, in some cases it may not be possible to reach agreement with the complainant on the proposed response. If the complainant is not satisfied with the resolution, he/she has the right to appeal. The MOF E&S specialist could ask for an independent person (e.g. MOF Legal Advisor) to help mediate the case. It is important that there is coordination with the E&S Specialist. At any time during the grievance resolution process, a complainant could seek independent legal advice or involve a court of law. The E&S specialist will ensure adequate follow-up of the appeal process to ensure the case is closed as promptly as practicably possible; the outcome should be documented. e) Close out or refer the grievance The final step is to close out the grievance. If the response has been successful, the E&S specialist should document the satisfactory resolution, in consultation with the complainant and ensure the implementation of the settlement. In cases where there have been major risks, impacts and/or negative publicity, it may be appropriate to include written documentation from the complainant indicating satisfaction with the response. Continuous engagement and consultation with all key stakeholders and transparency during the project life cycle is important. Where needed, the E&S specialist will prepare a ‘lessons learned’ document that outlines the steps taken to avoid similar grievances from re -occurring in the future and shared with the PCU team. If the grievance has not been resolved, E&S specialist should document steps taken, communication with the complainant (and other stakeholders if applicable), and the decisions made by the MOF and the complainant about referral or recourse to other alternatives, including legal alternatives (formal legal process of the national law). 18 GM documentation on particular cases should maintain confidentiality about details, while making public aggregate statistics on the number and type of complaints received, actions taken, and outcomes reached. Accurate case documentation using an electronic database is essential for public accountability, organizational learning, and resource planning. The World Bank and the Borrower do not tolerate reprisals and retaliation against project stakeholders who share their views about Bank-financed projects. 1. Monitoring and Reporting 7.1. Summary of how SEP implementation will be monitored and reported The E&S specialist and the PCU will assess progress on indicators in the Project’s result framework. Data on activities and outputs will be included in regular quarterly reports prepared by the PCU. 19 7.2. Reporting back to stakeholder groups The SEP will be published on the MOF official website and updated as needed to reflect relevant changes. The results of stakeholder engagement activities will be reported back to all relevant stakeholders who will be kept informed as the project develops whether involved or not in the implementation. The same communication mechanism will be applied for this purpose. Relevant stakeholders will be regularly reminded of the accessibility to the grievance mechanism. 20