Improving Mental Health Services Project in Sint Maarten (P177679) IMPROVING MENTAL HEALTH SERVICES IN SINT MAARTEN PROJECT (Grant TF C1500; P177679) Stakeholder Engagement Plan Borrowing Agency (SEP) National Recovery Program Bureau November 3, 2023 Mental Health Project (P177679) Contents 1 Introduction ..................................................................................................................................... 5 2 World Bank ESF Requirements for Stakeholder Engagement – ESS10 ........................................ 5 2.1 Objectives of the Stakeholder Engagement Plan ............................................................................ 6 3 Project Description.......................................................................................................................... 6 4 The Project design and the link with strategic developments ......................................................... 7 5 Location and Description of Affected Communities ...................................................................... 8 6 Stakeholder Identification and Analysis ......................................................................................... 9 6.1 Stakeholder Analysis - Identification and Categorization .............................................................. 9 7 Project Stakeholder Engagement during project preparation and implementation ....................... 21 7.1 Stakeholder Engagement completed during the Project Preparation Phase .................................. 22 7.2 Feedback Following Public Consultation and Disclosure of E&S Instruments (SEP and ESMP)31 7.3 Stakeholder Engagement During Implementation ........................................................................ 32 8 Monitoring and Reporting of the SEP During Project Implementation ........................................ 34 9 Grievance Redress and Feedback Mechanism .............................................................................. 39 10 World Bank Grievance Redress Service ....................................................................................... 54 11 Budget for the SEP........................................................................................................................ 54 2 Mental Health Project (P177679) List of Tables Table 1: Elaboration of Stakeholder Analysis - Categories, Prioritization, Potential Impact and Strategies for Engagement .................................................................................................................... 11 Table 2: Stakeholder Analysis - Category, Level of Influence and Importance .................................. 12 Table 3: Priority Groups Per Project Activity and Level of Engagement ............................................ 18 Table 4: Timeline for Assessments ...................................................................................................... 23 Table 5: Stakeholder Engagement Activities (Chronological) During Project Preparation Phase ...... 25 Table 6: Situational Analysis Stakeholder Engagement Log Scheme (Up to Pre-Appraisal Early January 2023) ........................................................................................................................................ 28 Table 7: Capacity Needs Assessment Stakeholder Group Engagement Log Scheme .......................... 30 Table 8: Responses from Emails Following Public Disclosure of Instruments ................................... 32 Table 9: Stakeholder Groups - Engagement Methods and Topics During Implementation ................ 33 Table 10: Stakeholder Groups - Engagement Methods, Frequency, Topics and Indicators for SEP ... 35 Table 11: Stakeholder Groups - Risks and Mitigation Measures ........................................................ 38 Table 12: Levels of Complaints ........................................................................................................... 42 Table 13: Roles and Responsibilities ................................................................................................... 51 Table 14: Budget For SEP Implementation .......................................................................................... 54 List of Figures Figure 1: Site Location........................................................................................................................... 9 Figure 2: Situational Analysis, Organizational/Financial and Capacity Needs Assessment ................ 24 Figure 3: Visual Overview of Interview Results.................................................................................. 30 Figure 4: The Complaint Handling Process ......................................................................................... 45 3 Mental Health Project (P177679) Abbreviations and Acronyms ESCP Environment and Social Commitment Plan ESF Environmental and Social Framework ESMP Environmental and Social Management Plan ESS Environmental and Social Standards GRM Grievance Redress Mechanism LMP Labour Management Procedures MHF Mental Health Foundation NRPB National Recovery Program Bureau SEP Stakeholder Engagement Plan SZV Hea Social and Health Insurances TPF Turning Point Foundation VSA Ministry of Public Health, Social Development and Labour WYCCF White and Yellow Cross Care Foundation 4 Mental Health Project (P177679) 1 Introduction The Stakeholders Engagement Plan (SEP) guide the outreach and information disclosure of the Improving Mental Health Services in Sint Maarten Project as it moves through critical milestones. The SEP recognizes the importance of open and transparent engagement between the project implementer, project beneficiaries, and other stakeholders as an essential element of good international practice. Stakeholder engagement is most effective when initiated at an early stage of the project development process. Furthermore, it is an integral part of early project decisions and the assessment, management & monitoring of the project's environmental and social risks and impacts. The Improving Mental Health Services Project will focus on construction of a mental health facility, changes to legislation and financing mechanisms, stigma reduction and providing training to key mental health service providers and other stakeholders regarding mental health issues and services in Sint Maarten. The SEP highlights the way the NRPB plans to communicate with those most affected by the project and those who will be the ultimate users of the facility. It also outlines a grievance mechanism whereby stakeholders and citizens can raise any concerns to the attention of the project, both verbally, written (by post or e-mail) or by filling in a grievance form. The implementation of the SEP will support the project’s overall goals to improve and increase mental health services of Sint Maarten. 2 World Bank ESF Requirements for Stakeholder Engagement – ESS10 The World Bank's Environmental and Social Framework (ESF) 's Environmental and Social Standard (ESS) 10, "Stakeholder Engagement and Information Disclosure", recognizes "the importance of open and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice" (Introductory Paragraph, ESS10, Guidance Note for Borrowers, Environmental and Social Framework, IPF Operations). Specifically, requirements 6 to 9, set out in ESS10, as outlined in the Guidance Notes, are the following: • Borrowers will engage with stakeholders throughout the project life cycle, commencing such engagement as early as possible in the project development process and in a timeframe that enables meaningful consultations with stakeholders on project design. The nature, scope and frequency of stakeholder engagement will be proportionate to the nature and scale of the project and its potential risks and impacts. • Borrowers will engage in meaningful consultations with all stakeholders. Borrowers will provide 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 and intimidation. • The process of stakeholder engagement will involve the following, as set out in further detail in this ESS: (i) stakeholder identification and analysis; (ii) planning how the engagement with stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders; (v) addressing and responding to grievances; and (vi) reporting to stakeholders. • The Borrower will maintain and disclose as part of the environmental and social assessment, a documented record of stakeholder engagement, including a description of the stakeholders 5 Mental Health Project (P177679) consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account, or the reasons why it was not." (World Bank, 2017: 98). 2.1 Objectives of the Stakeholder Engagement Plan ESS10, Stakeholder Engagement and Information Disclosure, “recognizes the importance of open and transparent engagement between the Borrower and project stakeholders as an essential element of good international practice�. The objectives of ESS10 are as follows:1 • To establish a systematic approach to stakeholder engagement that will help Borrowers identify stakeholders and build and maintain a constructive relationship with them, in particular project affected parties • To assess the level of stakeholder interest and support for the project and to enable stakeholders’ views to be taken into account in project design and environmental and social performance. • To promote and provide means for effective and inclusive engagement with project- affected parties throughout the project life cycle on issues that could potentially affect them. • To ensure that appropriate project information on environmental and social risks and impacts is disclosed to stakeholders in a timely, understandable, accessible, and appropriate manner and format. • To provide project-affected parties with accessible and inclusive means to raise issues and grievances and allow Borrowers to respond to and manage such grievances. 3 Project Description The Improving Health Services in Sint Maarten Project is co-funded by the Sint Maarten Recovery and Reconstruction Trust Fund, which is financed by the Government of the Netherlands, and administered through a tripartite partnership of the Sint Maarten and the Netherlands governments, and the World Bank via the Steering Committee. The project will consist of three components: Component 1: Supporting the strengthening of the national mental health system. This component would finance technical assistance to: (i) provide training related to mental health governance to the Ministry of Public Health, Social Development and Labour (VSA); (ii) explore supporting changes to legislation and financing mechanisms (within the boundaries of the national legislative context and guided by government requests for support) to address gaps in mental health service delivery, including substance abuse treatment gaps; (iii) develop and operationalize institutional arrangements for the national mental health promotion and prevention program; and 1 https://documents1.worldbank.org/curated/en/476161530217390609/ESF-Guidance-Note-10-Stakeholder- Engagement-and-Information-Disclosure-English.pdf 6 Mental Health Project (P177679) (iv) strengthening treatment protocols, referral protocols, and mental health expertise within the mental health care chain, as needed. Component 2: This component would finance civil works and related activities to build a multifunctional facility for individuals with mental health illness, including a day-care treatment facility, crisis intervention rooms, office space, out/inpatient treatment facilities on a land recently acquired by MHF. Improving service capacity would include expanding the physical infrastructure of the Mental Health Foundation (MHF) to accommodate and expand capacity of existing services. In order to develop the design a capacity needs assessment is conducted by the Ministry of Public Health. The new facility will be located on a flat land in the St. John’s neighborhood in the Cul-de-Sac district. Component 3: Project Management, monitoring and evaluation. This component will support all activities related to project management and coordination. 4 The Project design and the link with strategic developments The Project design complements the objectives of the National Mental Health Plan which is currently being updated. The National Mental Health Plan 2014-2018 remains one of the top Government priorities. In 2014, VSA, the government agency responsible for the legal, policy, and quality framework for healthcare in Sint Maarten, published the Sint Maarten National Mental Health Plan to guide the development of the national mental health sector. An evaluation of the 2014-2018 plan was carried out in 2021, in collaboration with the Pan American Health Organization (PAHO). The evaluation found that strategic objectives are still relevant because the national plan was not fully implemented. Implementation gaps of the plan were due to challenges with governance and coordination, as well as insufficient financial and human resources. The four countries in the Kingdom, (which are The Netherlands, Curacao, Aruba and Sint Maarten) are developing a joint vision document with a focus on reform and stronger cooperation among the four countries where it concerns mental health service provision and sharing recourses. This vision document includes a strategic agenda for the coordination of the different national multi annual implementation plans and was scheduled for June 2023. The strategic objectives of the 2014-2018 plan include the: (i) development and implementation of mental health policies, plans, and legislation to achieve effective governance; (ii) improvement in the response capacity of mental health services to provide comprehensive, quality care in community-based settings; (iii) preparation and implementation of programs for promotion and prevention in mental health and alcohol and substance abuse; and (iv) improvement of stakeholder collaboration. 7 Mental Health Project (P177679) The proposed Project complements the objectives of the National Mental Health Plan well. One of the proposed Project components prioritizes strengthening governance capacity for mental health (including support for improving legislation and governance) and systemic prevention and promotion interventions, reflecting key aspects of the strategic objectives (i) and (iii). Next, the proposed components focus on strengthening the quality of mental health care and service capacity through enhancing treatment and referral protocols and improving physical infrastructure in alignment with the strategic objectives (ii) and (iv). 5 Location and Description of Affected Communities The new mental health facility will be located in the neighborhood of St. John’s, which is a mixed use residential/social/commercial neighborhood within the Cul de Sac district. The Cul de Sac district is mainly a residential area, known as the school center of Sint Maarten. The actual plot is located inside a mixed-use area, 7 minutes or 2.5km away from Philipsburg, along LB Scott Road main road. There are no residential or business properties located along the east side of the vacant project site, which runs parallel to the LB Scott Road. An apartment building is located on the far south side corner of the plot, with the MAC Browlia F. Maillard Campus adjacent to it. Two similar key service providers are situated in the residential area of St John. These are the White and Yellow Cross Care Foundation (WYCCF) and the Ujima Foundation. The Mental Health Foundation provides mental health services to both entities. The WYCCF is a not-for-profit non-governmental organization which provides a combination of health care services to clients in various categories to a diversity of target groups. This includes the elderly, disabled and those who need chronic care. UJIMA is a partially government-subsidized “residential, therapeutic facility for boys and girls�. The facility offers a 24-hour residential therapeutic program for “at risk� youth who have been diagnosed with an emotional or behavioral disorder ". In addition, it offers an After-school Day Treatment Program for those who are not enrolled in the Residential program. The new building will be constructed on flat, undeveloped, uninhabited land with a total size area of approximately 6000sq m, with access to water, electricity, and sewer lines. The draft zoning demarcation for the site shows that the intended planned use is “Central�, with 12m maximum height and 50% maximum building density permitted. The plot is in a flood prone area. There are rainwater drain gutters at the eastern and southern boundaries and a total of 5 midsized trees growing on the property. Additionally, there are two monuments located in proximity with the development plot, the Emilio Wilson Estate and Mary’s Fancy Plantation. 8 Mental Health Project (P177679) Figure 1: Site Location 6 Stakeholder Identification and Analysis Stakeholder Engagement is an important part of project planning and execution and plays a crucial role in achieving a project’s goals and objectives. This Stakeholder Analysis conforms the bases for the development of the Stakeholder Engagement Plan (SEP). Stakeholders were identified, categorized and assessed by their level of influence and importance. The results of the analysis will guide how each stakeholder will be consulted with and will determine content, frequency, strategies, methods and timing of consultations, among other requirements for effective engagement. This SEP provides a Stakeholder Identification and Analysis. Each of the three (3) steps below have been conducted and presented in tabular format. 1 Stakeholder Identification and Analysis - Identification of stakeholders - Categorization of the identified stakeholders (Affected or Interested) 2 Determination of stakeholder influence on and importance to the project 3 Determination of the following for each stakeholder: (i) Frequency of Engagement (ii) Engagement Strategy/Method (iii) Engagement Logistics (Date, Time, Venue, Budget) (iv) Content/Purpose of Engagement 6.1 Stakeholder Analysis - Identification and Categorization One of the main elements of stakeholder engagement is stakeholder identification. The World Bank’s ESF Guidance Notes for ESS10 describes the process for stakeholder identification. This includes the development of a list of stakeholders who have any type of link with the project. These stakeholders are then categorized as a project affected or a project interested party and assigned a perceived level of influence and importance during the preparation and implementation of the project. 9 Mental Health Project (P177679) According to the ESF, the term "stakeholder" refers to individuals or groups who: (a) are affected or likely to be affected by the project (Project-affected parties) for example project beneficiaries. (b) may have an interest in the project (Other interested parties); and (c) may be disadvantaged or vulnerable because of their particular circumstances (project-affected parties) Influence indicates a stakeholder's relative power over and within a project. A stakeholder with high influence would control key decisions within the project and have strong ability to facilitate implementation of project tasks and cause others to act. Importance (interest) indicates the degree to which the project cannot be considered successful if needs, expectations, and issues are not addressed because of the level of interest by the stakeholder. This measure is often derived based on the interest of the stakeholder for the project's goals and purposes. Table 1 on the following page presents an explanation of the categories of stakeholders, their levels of Influence (Power) and Importance (Interest), their priority and the strategy for engagement. 10 Mental Health Project (P177679) Table 1: Elaboration of Stakeholder Analysis - Categories, Prioritization, Potential Impact and Strategies for Engagement Stakeholder Categories and Potential Impact on the project and strategy for engagement prioritization High Influence (power) and These stakeholders are both influential and important and will require more time and resources to engage with effectively because their High Importance (interest) impact on the project is high. This is the priority group of stakeholders who will require regular, robust, two-way engagement and active involvement. Priority high Strategy is to closely manage these stakeholders, involve them in governance and decision making and regularly engage and consult them. High Influence (power) and Because this group of stakeholders has power over the project (e.g., financial, permitting, etc.), their needs must be fulfilled. They Low Importance (interest) need to be kept satisfied, since their level of influence can affect project outcomes. These stakeholders may be a source of significant risk, and they will need careful monitoring and management. Priority medium high Strategy consists of involvement and consultations on areas of influence with the aim to increase level of interest. Low Influence (power) and These stakeholders have little influence on the outcomes of the project yet have a high interest in the progress or ultimate result of the High Importance (Interest) project’s activities. However, this group can often be overlooked. This implies that they will require special engagement initiatives if their interests are to be protected. Vulnerable project-affected parties (individuals or groups) who, because of their particular circumstances, may Priority medium be disadvantaged or vulnerable are part of this group. Strategy is showing consideration and concern, and involve them in specific areas of interest, keep them informed and consult on interest areas. Low Influence (power) and This group of stakeholders is least important, however should not be ignored. They require limited special engagement. Low Importance (interest) Strategy is to keep them informed via general communications, newsletters, websites, media releases and factsheets Priority low 11 Mental Health Project (P177679) A detailed overview of the stakeholder analysis for this project can be found in Table 2 below Table 2: Stakeholder Analysis - Category, Level of Influence and Importance Stakeholder Group Specific Stakeholder Categorization Influence/Importance Project Affected Stakeholders Project Interested Stakeholders (b) Influence (Power) Importance (a) (Beneficiaries) High/Low (Interest) High/Low Licensed Care Institutions Mental Health Foundation (MHF) - x x High High Also project partner White and Yellow Cross Care x Low High Foundation (WYCCF) Sint Maarten Medical Center x Low High General Practitioners x High Low Foundations providing mental Turning Point health or related services Foundation (TPF) (substance use) x Low High Key to Freedom Low Low x Ujima (Youth) x Low High Clients via Client Council or Client Council MHF their representatives x Low High Government Department of Public Health (PHD) - Ministry of Public x High High Health, Social Development & 12 Mental Health Project (P177679) Labour (VSA) - Also project partner Collective Prevention x High High Services (CPS) - Ministry of Public Health, Social Development & Labour (VSA) Department of Social x High High Development (SDD) - Ministry of Public Health, Social Development & Labour (VSA) - Also project partner Community x Low High Development, Family and Humanitarian Affairs (CDFHA) - Ministry of Public Health, Social Development & Labour (VSA) Social Services and x Low High Labor Affairs, Ministry of Public Health, Social Development and Labour (VSA) Ambulance Service x Low Low Sint Maarten (AMS) Council for Public x Low Low Health 13 Mental Health Project (P177679) Inspectorate of VSA x Low High (IVSA) Public Prosecutor x High High Policy Department - x High Low Ministry of Justice Police Department - x High Low Ministry of Justice Student Support x Low Low Services, Ministry of Education, Culture Youth and Sports Ministry of Finance x High Ministry of VROMI x High Judicial Institutions Stichting Justitiele x Inrichtingen Low Low Bovenwindse Eilanden/Sint Maarten (SJIB/SJIS) Voogdijraad/Court of x Guardianship Low Low Medical Associations Association for x Low High Psychologists and Allied Professionals Sint Maarten (APAP) Medical Specialists x Low Low Association (MSA) Sint Maarten Medical x Low High Association (SMA) Windward Islands x Low High Medical Association (WIMA) 14 Mental Health Project (P177679) Sint Maarten x Low High Foundation for Psychologists & 'Orthopedagogues' (SFPO) Sint Maarten Social x Low Low Workers Association (SSWA) Insurance Sociale & x High Low Ziektekosten Verzekering (SZV) Private Insurances & x Low Low brokers (i.e. Ennia, Nagico, Guardian, Henderson, Boogaard, ICWI, etc.) International Pan American Health x Low Low Support Organization (PAHO) Organization Surrounding Community MAC Browlia x Low High Maillard School St. Johns Estate NV x Low Low Homeowners x Low High Association 15 Mental Health Project (P177679) Surrounding Businesses Wizard (IT x Low High Company) Soil x Low High Co-financier To be confirmed x High Low Vulnerable Groups LBTGI+, woman x Low High (substance use), lesser/differently abled persons, non- English speaking persons Interest Groups Men's Mental Health x Low High Awareness 16 Mental Health Project (P177679) A range of engagement methods are available with different levels of engagement depending on the prioritization of the stakeholder. The following definitions are used when choosing the specific method of engagement per stakeholder or stakeholder group during the preparation and implementation of the project. Inform: Present information to the public or stakeholder groups about a particular aspect of the project, questions can be answered during public meetings. Engagement is one way with possibility to scale up if key concerns arise. Consult: Elicit stakeholder feedback on proposed options and decisions, acknowledge their point of view, and explain how they affect the final decision. Involve: During the entire decision-making process, work closely with the stakeholders to learn about and reflect on their concerns and goals. The latter should be considered in possible solutions. Collaborate: Partner with the stakeholders during all phases of the decision-making process. This includes identifying possible solutions to a problem and determining the preferred one. Their advice is considered to a large degree in the final decision. Generally, informing will be used with low interest and less powerful stakeholders, consultation will be utilized with individuals and organizations exhibiting high interest but limited influence, involvement will be employed with stakeholders having low interest and a large amount of power and collaboration will be applied with key players displaying both high influence and interest. In the table 3 below, stakeholders are mapped per priority group and linked to the project activity for which the stakeholder group needs to be engaged on, and the level of engagement. This table applies to both the preparation and implementation phases. Stakeholder engagement activities during preparation are discussed more in detail in Section 7.1. Section 7.2 describes more in detail the activities during implementation of the project. 17 Mental Health Project (P177679) Table 3: Priority Groups Per Project Activity and Level of Engagement Priority group Stakeholder Project activity Engagement level High Ministry VSA All project activities Collaborate MHF Component 1: Technical Support (ii) explore supporting changes to legislation and financing mechanisms (within the boundaries of the national legislative context and guided by government requests for support) to address gaps in mental health service delivery, including substance abuse treatment gaps; (iii) develop and operationalize institutional arrangements for the national mental health promotion and prevention program; and (iv) strengthening treatment protocols, referral protocols, and mental health expertise within the mental health care chain, as needed. Component 2: Civil works and related activities to build a multifunctional facility Medium High Public Prosecutor Component 1: Involve SZV (ii) explore supporting changes to legislation and financing mechanisms (within the boundaries of the national legislative context and guided by government requests for support) to address gaps in mental health service delivery, including substance abuse treatment gaps. Component 2: civil works and related activities to build a multifunctional facility 18 Mental Health Project (P177679) Co-financer Component 2: Civil works and related activities to build a multifunctional facility GP’s Component 1: (iv) strengthening treatment protocols, referral protocols, and mental health expertise within the mental health care chain, as needed. Component 1: (ii) explore supporting changes to legislation and financing mechanisms (within the Ministry Justice boundaries of the national legislative context and guided by government Ministry Finance requests for support) to address gaps in mental health service delivery, including Ministry VROMI substance abuse treatment gaps. Component 2: civil works and related activities to build a multifunctional facility. Medium TPF Component 1: Consult Ujima WYCCF (iii) develop and operationalize institutional arrangements for the national mental health SMMC promotion and prevention program; and (iv) strengthening treatment protocols, referral protocols, and mental health expertise Client Council MHF within the mental health care chain, as needed. Vulnerable groups Component 2: 19 Mental Health Project (P177679) Men's Mental Health civil works and related activities to build a multifunctional facility Awareness Inspectorate VSA APAP SMA WIMA SFPO MAC Browlia Maillard School Home Owners Association Soil Wizard Low Key to Freedom Component 1: Inform Council for Public Health Ministry Education, Culture, (iii) develop and operationalize institutional arrangements for the national mental health Youth and Sport promotion and prevention program SJIB Voogdijraad Component 2: MSA civil works and related activities to build a multifunctional facility SSWA Private Insurances & Brokers PAHO St. Johns Estate NV 20 Mental Health Project (P177679) 7 Project Stakeholder Engagement during project preparation and implementation Consultation Methods The nature of engagement required for the various categories of stakeholders may differ during the preparation and implementation phases of the project when engagement is most fruitful and productive. The consultation method is determined by the level of influence and importance of the stakeholder. Consultation methods vary. Public in-person and group consultations are used. Consultations take place in the form of public meetings, disclosure of documents to the public, interviews, meetings (groups or individual), workshops or work sessions. Consultations also take place during assessments and reviews. Given that the nature of the project is health related, important to note is that methods chosen for consulting with each group and where information is provided, will be guided by national ordinances for the protection of personal data, especially where it concerns information provided by medical professionals and clients or caretakers of clients (usually family members of clients). The principle of Informed Participation will be one of the foundations for consultation and provision of information (specifically Personal Information of attendees – name, contact details), with the disclosure that information will be kept confidential where required. Special consideration should be given to project affected persons who, because of their particular circumstances, may be disadvantaged or vulnerable. The project outcomes cannot have a negative effect on vulnerable groups or put them in a worse situation than they were before. Based on the situational analysis the following vulnerable groups were identified. The needs of persons with disabilities need to be taken into consideration when designing the new facility. Secondly special consideration must be given to the LGBTQI+ community when developing the referral systems or assessment/screening tools. Women can be considered a vulnerable group where it concerns addiction care, since the majority of the existing organizations focus on men. These aspects have to be taken up when developing the terms of reference for different project activities. Consultations through focus groups on needs and concerns will be used as tools, next to surveys amongst specific targeted groups. Collecting information for the project design is at the core of the engagement activities during the preparation phase. Different stakeholder groups were engaged from the start to collectively develop the project vision and design. Engagement was done amongst a larger group of stakeholders, both internal(government) and external to validate the goals of the project. During the implementation phase the approach is twofold: at one hand stakeholders need to be kept informed about the activities in order to address needs and concerns in an appropriate manner, and on the other hand input needs to be collected for further detailing the project activities to ensure the project objectives are reached. In section 7.1, stakeholder consultations conducted during the preparation phase are discussed. This is followed by (future) stakeholder engagements, that are planned for during the implementation phase, after signing of the grant agreement, discussed in Section 7.2. Consultation via disclosing of environmental and social safeguards documents is required and an important way of engaging stakeholders who can provide feedback on the documents. The NRPB follows World Bank’s requirements for consultation and disclosure. Consultations take place at different stages before and after the signing of the grant agreement. The goal is to be able to adjust the documentation at different stages during preparation and implementation depending on the feedback received. Consultations take place via online publications accompanied by social media coverage requesting the public to comment. Stakeholders are contacted in person via email to provide feedback. If needed, meetings will be organized to explain the content of the documents. 21 Mental Health Project (P177679) 7.1 Stakeholder Engagement completed during the Project Preparation Phase On July 14th, 2021, the Steering Committee of the Sint Maarten Recovery and Reconstruction Trust Fund allocated USD $8 million to a Mental Health Project, based on the circulated project concept note and subject to World Bank appraisal. The Ministry of VSA is responsible for health sector policy and strategic direction and for the implementation of the National Mental Health Plan, which will be supported by the Project and prioritized by the Ministry. The Ministry is also responsible for legislative reform in the health sector, which is prioritized at the Kingdom level. In the following months, consultations were held on the concept note by the project team of the World Bank and the NRPB, with main stakeholders and the Ministry of VSA. The Steering Committee requested that the NRPB and the World Bank consider support to substance abuse services in the context of the appraisal of this project, as appropriate. The considerations from the Steering Committee were taken up in discussions with the stakeholders. In February 2022, a virtual preparation mission took place. Subsequent to this, the NRPB facilitated consultation on the project scope and the outline of the project design between the Ministry of VSA and MHF. During the preparation NRPB consulted with other relevant stakeholders (foundations providing mental health or related services): Turning Point, WYCCF and Ujima. In April 2022, consensus was reached on the project design resulting in Guiding Principles signed by the Minister of VSA and the chair of the board of MHF. The parties also agreed on conducting a situational analysis and a capacity needs assessment. In June 2022, a second (on island) preparation mission took place. Consultations were held with main stakeholders and the Bank team conducted a site visit of the current facility and the project site. In order to prepare the project and inform the updating of the National Mental Health Plan, VSA undertook a Situational Analysis to assess the current mental health system. This analysis, which was conducted by a Social Specialist, included a mapping of mental health services and the sector and stakeholder engagements amongst the stakeholders as identified under the project. The documented output of the Situational Analysis informed national mental health sector planning, and provided an evidence-informed basis for the Project design. Stakeholder engagement during the analysis was aligned and coordinated with the NRPB, and took place in the form of interviews and where required, focus groups. Specific project-related questions were added to the interview questionnaires, that are tailor-made to each target group of stakeholders. The assessment was concluded in August 2023. Secondly, the Ministry in coordination with the NRPB conducted a Capacity Needs Assessment to inform the establishment of a new mental health care facility for the MHF and determined the footprint and required investments based on the outcome of the Assessment. The Capacity Needs Assessment informed the project on the size and differentiation in functionalities of the new mental health facility. An Assessment was conducted of the facility’s current capacity, gaps in capacity, and delivered scenarios for the new building based on future projections of services. Findings are being used as a basis for developing the Terms of Reference for the structural design of the building. Preliminary results were presented mid November 2022 which were validated by the Ministry and MHF. The feedback from MHF were taken up in the report. Final results were presented mid-January 2023, after which the report was finalized in ending of January 2023. Stakeholder engagement activities during the capacity needs assessment were aligned to other ongoing stakeholder engagement activities in coordination with the NRPB. Stakeholder engagements took place in the form of interviews, focus groups and surveys. 22 Mental Health Project (P177679) The WB team conducted an organizational/financial assessment of the MHF. This assessment determined the current operating financial model of MHF. The assessment used the current financial model, along with findings from an organizational review examining operational gaps/challenges, and projected long term financial and operational scenarios for the future. The financial model and predicted scenarios were used to evaluate MHF’s capacity to deliver current and planned services and development of MHF’s strategic planning. The assessment was concluded in May 2023. While the capacity needs assessment aimed to inform the design of the proposed building, the organizational/financial assessment aimed to assess the mid to long term sustainability of MHF through a financial and operational lens, including MHF’s financial capacity. Additional funding will be needed to cover the full cost of civil works for the new MHF building under Component 2 as the project budget does not fully cover the costs of the construction of a new facility. A new facility requires more space to deliver current and scaled-up mental health care services to respond to the increased demand for services. Both the capacity needs assessment and the organizational and financial review informed the project design. Stakeholder engagement activities during the commencement of the Situational Analysis, the Capacity Needs Assessment and organizational/financial review were aligned in coordination with the NRPB in order to meet the ESF standards. This is because of the overlap among stakeholders that needs to be consulted for all assessments and design. Outcome of the activities are described below in Section 7.1. Table 4: Timeline for Assessments Assessment Timing Responsibility Situational Analysis July 2022 – August 2023 VSA in coordination and with support from NRPB Capacity Needs Assessment August 2022 – January 2023 VSA in coordination and with support from NRPB Organizational and Financial July 2022 – May 2023 WB Assessment Consequently, the Situational Analysis of the national mental health system, the Capacity Needs Assessment to be carried out by VSA, together with the organizational/financial review led by the Bank, were all geared to consult with stakeholders on access, availability and quality of mental health services and the provision and improvements thereof. Outcomes provided the necessary inputs of stakeholders to not to inform the proposed Project design, but also assist in the formulation of a business plan for the MHF. Summarized, the three assessments can be visualized as illustrated in Figure 2 below 23 Mental Health Project (P177679) Figure 2: Situational Analysis, Organizational/Financial and Capacity Needs Assessment The Ministry has appointed a focal point for the project. Furthermore, the Ministry initiated a working group consisting of representatives from the Departments of Public Health and Social Development. The NRPB is part of the working group. NRPB initiated a joint project group between the Ministry and the MHF which reconvenes every 6 to 8 weeks. During the monthly MHF board meetings, the NRPB discussed the project with the Foundation and provided updates. Based on the outcome (outlined in the table below) the project design related to these aspects were developed together with the stakeholders. Additionally, a Tripartite Committee was installed to develop an action plan on the financial sustainability aspects of the project prior to the start of the implementation. The Tripartite Committee, consisting of the MHF, Minister of VSA and the National Health Insurance Agency, will be supported by a monitoring committee. The Monitoring Committee, will, at a technical level, jointly implement an Action Plan to safeguard financial aspects regarding the sustainability of MHF and develop a Business Case to support any additional investments. The Tripartite will function throughout the implementation of the project. The table below provides a detailed overview of consultation activities conducted to date. The detailed stakeholder consultations for the Situational Analysis and the Capacity Needs Assessment are captured in separate tables (Tables 6 and 7). 24 Mental Health Project (P177679) Table 5: Stakeholder Engagement Activities (Chronological) During Project Preparation Phase Timeframe/Date Stakeholder Activity Outcome of Consultation, key issues discussed and how they will be addressed 20th July 2021 VSA, WB, Feedback on Request to carefully assess, consider, and aim to NRPB concept note address the sustainability impacts of any proposed investments. Include other organizations on SXM that provide mental health care services or are closely linked to it. Keep in mind the scope and look at the project in a comprehensive manner. This is taken up during the preparation phase, added to project scope is substance use. 8th October 2021 MHF, WB, Presentation MHF indicated the need 1) to include substance use in NRPB proposed the legislation; 2) increase the crisis care capacity; 3) project based for additional funding to move the entire operations to on concept the new building. Bank/NRPB noted to take point 1 note and 2 up during further project preparation. Point 3 will be further discussed. If there is additional financing the entire financing for construction will be subject to Bank rules that apply. 8th October 2021 VSA, WB, Presentation Confirmation of Governments request to aspects of NRPB proposed substance abuse, including prevention and treatment project based across health sectors (not only at MHF). VSA noted on concept that there is a need to carry out a situational assessment note and gap analysis of mental health services in Sint Maarten (including legislation). It was noted and confirmed that focus cannot only be on construction/reconstruction but must also include interventions that would ensure sustainability of the proposed operations. Additionally, the Bank team added that there is flexibility along the different stages of the project, if urgent needs arise. Overall, the Bank confirmed that the project components can be modified and will likely be shifted over the preparation phase. 15th October Minister VSA, Presentation Minister VSA indicated priorities for the project: 2021 NRPB, WB proposed strengthening day treatment and crisis care. It was noted project based that beyond the new building, there should be a focus on on concept improving operational aspects of MHF (including note increasing the productivity of staff and improving the quality of care). VSA indicated that their priorities for this project are: (1) assistance to support legislative reform; (2) support with establishing an umbrella of care for cases of substance abuse; and (3) carrying out a capacity assessment to identify the scope of the problem and gaps. These issues will be addressed in the preparation phase. 22nd October MHF, WB, Interviews Request to MHF to clarify planned capacity for guided 2021 NRPB, VSA and online living as the submitted functional requirements included Meetings 36 spaces for guided living, which differs from the Consultations previously discussed 25 spaces. VSA shared that the Concept note policy on guided living and day care needs to be approved by the government, and a legal basis and recommended expert validation of plans from MHF. WB/NRPB confirmed that further review is needed by 25 Mental Health Project (P177679) experts on financing and guided living. Retroactive financing has to be further explored if possible. 23rd November WB, NRPB, Coordination Planning outline and strategic plan discussed. 2021 PAHO, VSA meeting PAHO WB 20th December VSA Answers to Written Q&A on cooperation PAHO-VSA, status GHI, 2021 questions for inclusion of substance use under insurance scheme, preparation classification & coding systems, updating legislation, phase M&E and quality care. October - WB, WYCCF, Interviews Input from stakeholders for PID based on concept note. December 2021 TPF, Ujima and online Confirmation of the need for substance use as part of Meetings the scope of the project. 26th January VSA PID VSA provided feedback on PID. 2022 1st February 2022 MHF, VSA, Preparation VSA indicated that the introduction of a new care WB, NRPB mission product ‘Guided living’ as part of the project is not supported as product by policy and legislation and therefore poses high risk for the success of the project; scope of project further discussed. 3rd -10th February MHF, VSA, Multiple joint Discussions on scope and design of the project. 2022 NRPB work sessions Consensus on shared mission and vision for the project. 16th – 23rd MHF, VSA, Continued Consensus on a shared mission and vision for the February 2022 WB, NRPB Preparation project reached. Scope project discussed. VSA mission indicated that a shift in priorities in the proposed project is needed. The project activities should be based on a decentralized approach, where strengthening and enhancement is offered to a broad range of service providers. Examples of activities/plans that the country would like to see are: improvement and expansion of ambulant care; improvement in delivery of crisis care; integration of mental health care in primary health care; execution of audits to determine baselines; improvement of service quality; and improvement and establishment of quality mental health facilities. Details on capacity needs assessment shared. VSA and MHF work on proposed components and subcomponents. March 2022 MHF, VSA, Multiple joint Revised project description (components and NRPB work sessions subcomponents) based on shared vision and mission. April 2022 MHF, VSA, Multiple joint Development of Terms of Reference for Capacity NRPB work sessions Needs Assessment. May 2022 MHF Consultations Clarification of and discussion on project scope and VSA on project guiding principles for the project shared by both MHF scope and VSA. Result: signed Guiding Principles document by both VSA and MHF as guideline for the project. Resulted in joint project description of the activities. June 2022 VSA Consultations Needs identification for project scope. Needs for MHF on project addiction/substance use to be part of the project TP, Ujima scope identified. Addiction/substance use description and WYCCF activities adjusted. August 2022 VSA, MHF, Consultations Follow up discussions on the project activities. Agreed NRPB on project to work on project activities during workshops on activities needs for the project. 15th September NRPB, MHF Workshop Defining needs - MHF to finetune the activities for 2022 project description. 26 Mental Health Project (P177679) 20th September NRPB, VSA Workshop Defining needs - VSA to finetune the activities for 2022 project description. 15-19th VSA, MHF, Conference Diverse workshops on Community based approach, November representatives mental health stakeholder collaboration, quality of care, prevention from: Justice, and promotion, data management. Outcome presented mental health in report on outcomes of the Conference. The service following priorities were identified: Implementing a providers, Community Based Approach; promotion and Ambulance prevention strategies and materials with active department, participation from diverse stakeholders, (continuous) interviewees education and training, updating legislation and for situational financing system, Quality system: referral system and analysis, social quality standards. First presentation of draft situational services, analysis. community development December NRPB, VSA, Verification Verification Capacity Needs Assessment and MHF reports Organizational and Financial Review Discussions resulted in an agreement to work out an Action Plan to support project activities (coordination mechanism) in order to secure co-financing and organizational changes at MHF under guidance of a Tripartite cooperation between Minister VSA, Director SZV and chair of the board MHF. Installation of technical monitoring committee. January 2023 VSA, MHF Verification Team meeting MHF to verify the outcome of the capacity capacity needs assessment. Final footprint adjusted needs based on feedback of the staff of MHF. assessment June 2023 VSA Mental Health Second presentation draft situational analysis during Situational stakeholder session. Feedback incorporated in final Analysis report. Stakeholders confirmed content of the report. Results and Stakeholder Feedback July 2023 NRPB Consultation Meeting to introduce the project. Director of the school director of the expressed that the school is positive MHF is going to MAC Browlia be built close to the school, in order for the school and Maillard MHF to collaborate. Because no building activities are School foreseen until 2025, NRPB will consult with the school at a later stage. October 2023 VSA/NRPB Conference Two-day conference with stakeholder to discuss the mental health strategic goals. Outcome: confirmation of project activities. NRPB moderated the workshops. As stated in the above the Situational Analysis was initiated in July and was finalized in Q2, 2023. In the table below, the Key discussion points and findings are described per stakeholder group of conducted interviews. Inputs from the stakeholders were the basis for the National Conference on Mental Health and the project design. Outcome of the stakeholder consultations on the situational analysis was a need for an advisory group of persons with lived experience under guidance of VSA. The organization and set-up of this group is currently ongoing at date of this report (November 2023). 27 Mental Health Project (P177679) Table 6: Situational Analysis Stakeholder Engagement Log Scheme (Up to Pre-Appraisal Early January 2023) Conventional MH Service Group Code Interview Date: Key issues discussed Providers (In no particular A: order): UJIMA A-1 July 28th/Oct.11th 2022 Knowledge and MHF qualifications; quality of APAP service (M&E of Key to Freedom services); substance use WYCC (treatment, support, needs TPP target group); perception PsychCare mental health services; Independ. MH professional stigma and discrimination, SFPO access to services and Independent MH Prof. programs (waiting lists, A-2 Aug. 19th 2022 referral, information); legislative reform A-3 Aug. 26th 2022 including mandatory A-4 Aug. 26th 2022 admission; broad based A-5 Aug. 25th 2022 approach to mental health; consultation needs for A-6 Aug. 25th 2022 project. A-7 Aug. 22nd/ Oct. 7th 2022 A-8 Sept. 26th/Oct. 17th) 2022 A-9 Aug. 26th 2022 A-10 Aug. 25th 2022 A-11 Sept. 29th 20222022 A-12/T-3 Aug. 5th Wellness Practitioners Group Code D: Interview Date: Key issues discussed (In no order): unconventional practitioners such D-1 Aug. 24th 2022 Knowledge and as yoga studios, shamans, qualifications; quality of dieticians service (M&E); sensitivity D-2 Aug. 22nd 2022 to mental health and D-3 Aug. 25th 2022 substance use in service D-4 Aug. 25th 2022 provision; need for D-5 Aug. 25th 2022 education; stigma and discrimination; access to D-6 Sept. 7th 2022 service and programs; understanding of mental wellness Physicians Code B: Interview Date: Key issues discussed (In no order): Dutch quarter clinic, Colebay B-1 Aug. 31st 2022 Qualifications and clinic, Philipsburg Clinic, and education needs; other doctors. assessment, referral and B-2 Aug. 30th 2022 treatment; substance use B-3 Sept. 1st 2022 (needs for treatment); B-4 Sept. 2nd 2022 attitudes and perception B-5 Oct. 6th 2022 (role government, stigma, culture), consultation needs for project. Auxiliary (In no order): Code E: Interview Date: Key issues discussed 28 Mental Health Project (P177679) institutions that support E-2 Sept. 6th 2022 Knowledge and chronically ill or are involved with qualifications (additional mandatory/involuntary care specific qualifications); (KPSM, Ambulance, Prosecutor’s work processes, formal Office) procedures and protocols; E-3 Sept 9th 2022 educational needs; referral E-4 Sept. 20th 2022 and assistance other service providers during interventions; attitudes and perceptions; role government, legislative changes; consultation needs during the project. Persons of lived experience: Code F: Interview Date: Key issues discussed Persons who are consumers of F-1 Oct. 5th/Oct. 20th 2022 Experience with illness mental health services or those and challenges (diagnoses, with chronic mental health treatment, crisis situations, concerns or have experience with quality, referral, access to mandatory involuntary care care); suggestions F-2 Oct. 5th 2022 legislation and processes F-3 Oct. 9th 2022 mandatory admission; F-4 Oct. 5th 2022 human rights (dignity, stigma and discrimination autonomy, privacy, patient rights); access insurance; role government; consultation needs during the project) Informal Caretakers/Co- Code G: Interview Date: Key issues discussed Dependents: Individuals who care for and G-1 Sept. 5th 2022 Experience with illness support persons with chronic and and challenges (diagnoses, or serious mental health care treatment, crisis situations, issues. These could be parents, or quality, referral, access); another family member, close suggestions legislation and friends and or relatives. processes mandatory G-2 Sept. 11th 2022 admission; human rights G-3 Sept. 11th 2022 (dignity, stigma and G-4 Aug. 29th 2022 discrimination autonomy, G-5 Sept. 11th 2022 privacy, patient rights); access insurance; support G-6 Sept. 11th 2022 for caregivers; role G-7 Sept. 11th 2022 government; consultation needs during the project) Government Entities Code C: Interview Date: TBD Note interviews not yet (In no order) January/February 2023 completed at time of draft SEP (October 2022) Public Health, Youth, Culture, C-1 Jan. 10th 2023 Quality service provision, Justice, VSA. Government entities governance (including that have been identified as having financial system, and a stake and or responsibility to legislation), stakeholder mental health service and collaboration, data development. management, community- C-2 Jan. 29th 2023 based approach. C-3 Jan. 18th 2023 C-4 Jan. 23rd 2023 Similar to the above 29 Mental Health Project (P177679) Figure 3: Visual Overview of Interview Results Main findings: During the interviews 4 key themes were identified by the different stakeholder groups. The preliminary findings were presented and discussed in workshops with the stakeholders present at the National Conference on Mental Health. Across the board there is consensus on a community-based approach, strengthening the referral system and linking the social domain to the health domain, improving the quality-of-service, reform of financial and legal systems, closer collaboration between stakeholders (formalized), and more emphasis on early detection, prevention and promotion. The suggestion to structure a workgroup with mental health experts to jointly work out prevention and promotion programs and campaigns chaired by the Ministry of VSA is taken up in the project activities as a result of the outcome of the workshops. The kick-off session of the workgroup prevention and promotion took place on October 30th, 2023. The table below describes the overview of stakeholders that were consulted during the capacity needs assessment and the main findings. The final report was presented January 2023. . Table 7: Capacity Needs Assessment Stakeholder Group Engagement Log Scheme Consultation date Organization Topic Main findings consulted September 19, 2022 GP Prison Department Public • The legislation has to be Health modernized September 20, 2022 SMIA • All involved are positive PAS about the strategic direction Ujima towards Community Based Inspectorate VSA Approach 30 Mental Health Project (P177679) MHF support functions • Opinion about the • Insufficient public MHF Psychiatric nurses current situation in awareness around mental MHF admission/crisis mental healthcare health care • Lack of prevention and early September 21, 2022 GP • Volume of MH care detection activities patients and MHF management • Need for attention for the treatments MHF Psychiatrists, youth with mental health Psychologists, Forensic • Capacity needs in the • Collaboration between counselor, Occupational future mental healthcare providers Therapist, Social can be strengthened worker, Social Service • General practitioners in asst. general are satisfied with the MHF Social Psychiatric possibility to refer patients Workers for local assessments and SFPO treatments APAP • There is no long waiting September 22, 2022 WYCCF • Opinion about the time for intakes and initial Safe Haven current situation in assessments. SZV mental healthcare Recognition of underlying GP • Volume of MH care conditions that can cause mental patients and health issues and reimbursement September 23, 2022 Psycare treatments for their treatment (substance use) Miss Lalie Center • Capacity needs in the SJIB future Medical Specialist Association September 24, 2022 Council Public health December 2022 MHF, VSA, WB, NRPB Presentation Comparison requested initial preliminary findings footprint and outcome capacity capacity needs needs assessment and more in- assessment depth discussion with MHF board December 17, 2022 MHF, VSA, NRPB Second round Discussion on footprint, verification capacity agreement in principle with needs assessment projections and outcome capacity needs assessment by VSA and MHF. Request MHF for discussion with staff to collect feedback January 16, 2023 MHF staff Third round verification Discussion on footprint and with staff capacity functionalities in assessment needs assessment report with MHF staff, feedback taken up in final report and adjusted footprint. 7.2 Feedback Following Public Consultation and Disclosure of E&S Instruments (SEP and ESMP) The Stakeholders Engagement Plan and the Environmental and Social Management Plan prepared for this project were disclosed on March 10th 2023 with deadline for receipt of feedback set for March 21, 2023. Copies of the documents were uploaded on the NRPB website and the public was invited and encouraged to read both documents and provided with an email address to express their opinions and give feedback on both. An email account was created for this purpose, with access available to the 31 Mental Health Project (P177679) Project Management and E&S for the monitoring of responses. The links to the documents were also published in the local newspaper, The Daily Herald. An email account was created to receive feedback from members of the public, at address mentalhealth@nrpbsxm.org. Responses are also sent to info@nrpbsxm.org. Responses received from Emails Table 8: Responses from Emails Following Public Disclosure of Instruments Instrument SEP ESMP Date of Disclosure 10th March, 2023 Source of Feedback Emails sent to MHP Email Account 4 respondents Feedback Received Responses ranged between Very Satisfied and Satisfied with the SEP and ESMP One respondent approved of the approach taken for the project and pledged support through an existing organization which focuses on men’s mental health. H is organization was added to the stakeholders’ list. 7.3 Stakeholder Engagement During Implementation During implementation and depending on the impact of the project, different stakeholder groups require a different approach to engagement to ensure information and feedback is collected and shared in a timely manner in order to address needs and concerns. The strategy for engagement methods is developed based on the stakeholder assessment and level of priority outlined in Section 6. During the design phase, as part of the implementation of the project, before plans are submitted for approval/clearance and before starting the bidding procedures for the construction of the new facility, consultations will be held with the potential users of the facility (staff and client council), and other interested parties, including the surrounding community, families and businesses to garner ideas and get feedback on the site and building plans. Special consideration will be given to project affected persons who, because of their particular circumstances, may be disadvantaged or vulnerable. The project outcomes cannot have a negative effect on vulnerable groups or put them in a worse situation than they were before. Based on the situational analysis the following vulnerable groups were identified. 32 Mental Health Project (P177679) People With Disabilities: The needs of persons with disabilities must be taken into consideration when designing the new facility. LGBTQI+ community: Need to be considered when developing the referral systems or assessment/screening tools. Women: Can be considered a vulnerable group where it concerns addiction care, since the majority of the existing organizations focus on men and need to be considered when developing the referral systems or assessment/screening tools. Non-English-speaking Groups: Special consideration should be given to non-English speaking persons in the surrounding community in regard to the construction, for the promotion and prevention activities and general information that will be provided on the project to the public. Communication should be multilingual and in English, Creole, Spanish. These aspects must be taken up when developing the terms of reference for different project activities. Consultations through focus groups on needs and concerns will be used as tools, next to surveys amongst specific targeted groups. Table 9: Stakeholder Groups - Engagement Methods and Topics During Implementation Priority group Stakeholder Engagement method Topic High Ministry VSA Weekly meetings focal point Collaborate in decision and internal workgroup, making process. MHF monthly meetings All project activities under monitoring committee, and component 1 and 2. Tripartite. Workshops, SZV presentations, monthly board meetings MHF. Medium Public Prosecutor Meetings mental health task Involve in legislation High force, presentations, involuntary admission and consultations documents, awareness mental health every 6-8 weeks. Meetings decision makers, Involve in financial aspects presentations, information system. fact sheets Co-financer Presentations, advisory Quality of service, committee, assessments assessment/screening, surveys, focus groups referral system. GP’s monthly during implementation activity. Presentations, meetings Legal, financial, permits. decision makers. Ministry Justice Ministry Finance Ministry VROMI Medium TPF Consultations documents, Consult on quality mental Ujima meetings when required, health services, substance WYCCF information via newsletter use, collaboration and SMMC or factsheets and website, referral system. quarterly. 33 Mental Health Project (P177679) Client Council Survey, opinion polls, Quality service, referral MHF information via newsletter system, new facility. or factsheet and website. Inspectorate VSA Consultation documents, Legislative aspects, quality meeting when required. of service, monitoring and evaluation. APAP SMA Focus groups, consultation Quality of service, financial WIMA documents, meetings when system, SFPO required (presentation at screening/assessments, Vulnerable groups associations meetings), referral system. Men's Mental information via newsletter Health Awareness or factsheets and website, when required. MAC Browlia Maillard School Presentations, public Design and build new Home Owners meetings, information via facility. Concerns related to Association newsletter or factsheets and noise, dust, pollution during Soil website, quarterly and more construction. Possible Wizard frequent when required. implications for community of new facility. Low Key to Freedom information via newsletter Inform on project progress Council for Public or factsheet, meetings when with focus on legislation, Health required. construction of new facility, Ministry and quality of service and Education, referral systems. Culture, Youth and Sport SJIB Voogdijraad MSA SSWA Private Insurances & Brokers PAHO St. Johns Estate NV 8 Monitoring and Reporting of the SEP During Project Implementation Monitoring is a management tool for tracking progress of ongoing projects. The basic idea is to compare actual performance with plans and to measure actual results against expected results. The monitoring function is an integral part of project execution. The same holds for the monitoring and reporting of the activities described in the Stakeholders Engagement Plan. It is necessary to document the procedure and personnel for ensuring that the SEP is executed as planned to ensure that there is adequate 34 Mental Health Project (P177679) communication and feedback with and from the stakeholder community and otherwise. Within the project, specific roles and responsibilities are assigned. These roles and responsibilities maximize efforts for successful project completion and are therefore also an integral part of monitoring the execution of the SEP itself. Specific roles and responsibilities for stakeholder engagement: NRPB: The Stakeholders' Engagement Plan was developed by the NRPB's Environmental and Social Specialists in close consultation with the Project Team to guide the communication and interaction with Stakeholders, including the project beneficiaries. A Social Specialist engaged by the NRPB will help guide the stakeholder engagement activities together with the Communications Team. The NRPB is responsible for overseeing all stakeholder engagement activities. Per activity, technical expertise will be hired to implement the project activities, including stakeholder engagement, for example through surveys, assessments, focus groups etc. The Works Contractor is expected to develop a contract specific Stakeholders Engagement plan (to include a Grievance Redress Mechanism) as a component of the Contractor's Environmental and Social Management Plan (C-ESMP), in-line with the provisions of this SEP, which will focus on communicating with the nearby homes and business during the construction phase. The Environmental and Social Safeguards Specialist hired by the Works Contractor is the point person for management/development of the SEP for the Contractor. SEPs are site specific and should provide a mitigation plan for the negative environmental and social impacts identified in the ESMP prepared for the project. The plan should explain in detail, the activities for stakeholder engagement at the project site, following the provisions of the C-ESMP, also developed by the Works Contractor. The ESMP for this project contains the requirements of the C-ESMP, and these requirements will be in the Procurement Documents for potential bidders. The qualifications and experience required for the post of Environmental and Social Specialist will be described in the Procurement Documents for the project. Supervision Contractor, hired by the NRPB, is responsible for ensuring that the Works Contractor develops and executes a formally prepared SEP, which will provide effective mitigation measures for any environmental and social impacts outlined in the Contractor- ESMP. The ESHS Specialist hired by the Supervision Contractor is expected to monitor the works contractor's implementation of their SEP. Periodic reports with information relevant to the SEP will be described in these reports. In the table below, the monitoring methods, topics, output and outcome indicators are listed per category stakeholder, from high priority to low priority. Table 10: Stakeholder Groups - Engagement Methods, Frequency, Topics and Indicators for SEP Stakeholder Engagement Topic Output Outcome indicators priority method indicators group High 35 Mental Health Project (P177679) Ministry Weekly meetings Collaborate in decision Meetings VSA supports and VSA focal point and making process, for all project minutes. implements outcome internal activities under component 1 Report outcome technical assessments, MHF workgroup, and 2. workshops. recommendations, monthly meetings implementation, and action monitoring plans. MHF implements SZV committee, and organizational changes Tripartite. requires to implement new Workshops, systems presentations, (referral/screening/quality). monthly board SZV support proposed meetings MHF. revision of financial system. Medium High Public Meetings mental Involve in legislation Meetings Support for outcome gap Prosecutor health task force, involuntary admission and minutes analysis legislation. presentations, awareness mental health. Feedback consultations recorded documents, every consultations 6-8 weeks. and how feedback was incorporated. Co-financer Meetings Involve in financial aspects Meeting Investment in new facility decision makers, system. minutes. presentations, information fact sheets. General Presentations, Quality of service, Advisory GP’s who support the new Practitioners advisory assessment/screening, referral committee referral system, including (GP’s) committee, system. agenda and assessment/screening tools. assessments minutes. Positive relationship GP’s. surveys, focus Record outcome Willingness to implement groups monthly focus group, changed processes. during assessment implementation report, number activity. of surveys collected. Presentations, Legal, financial, permits. Meeting Support recommendations Ministry meetings decision minutes. system changes Justice makers. (legal/financial), permits Ministry provided for new facility Finance Ministry VROMI Medium TPF Consultations Consult on quality mental Feedback Positive relationship with Ujima documents, health services, substance use, recorded stakeholders, support system WYCCF meetings when collaboration and referral consultations changes, organizations well SMMC required, system. and how informed. information via feedback was newsletter or incorporated, factsheets and no. of website, newsletters or quarterly. factsheets, publications on 36 Mental Health Project (P177679) website multilingual. Client Council MHF Survey, opinion Quality service, referral Number of Support design of new polls, information system, new facility (design surveys facility, client council well via newsletter or and during construction). collected, no. of informed. factsheet and newsletters or website. factsheets, Inspectorate publications on VSA website multilingual. Consultation Legislative aspects, quality of Feedback Support recommendations documents, service, monitoring and recorded system changes. meetings when evaluation. consultations required. and how feedback was APAP incorporated, SMA meeting WIMA minutes. SFPO Focus groups, Quality of service, financial Record outcome Support recommendations Vulnerable consultation system, screening/assessments, focus group. system changes., groups documents, referral system. Feedback stakeholders well informed. meetings when recorded required consultations (presentation at and how associations feedback was meetings), incorporated, information via no. of newsletter or newsletters or factsheets and factsheets, MAC website, when publications on Browlia required. website Maillard multilingual. School Home Presentations, Design and build new facility. Report outcome Support design new facility, Owners public meetings, Concerns related to noise, dust, public meetings, community well informed Association information via pollution during construction. no. of Soil newsletter or Possible implications for newsletters or Wizard factsheets and community of new facility. factsheets, website, quarterly publications on and more website frequent when multilingual. required. Low Key to Information via Inform on project progress No. of Stakeholders well informed, Freedom newsletter or with focus on legislation, and newsletters or positive relationship Council for factsheet, quality of service and referral factsheets, stakeholders. Public Health meetings when systems. publications on Ministry required. website Education, multilingual Culture, Youth and Sport SJIB Voogdijraad MSA SSWA Private Insurances & Brokers 37 Mental Health Project (P177679) PAHO St. Johns Estate NV Detecting risks at an early stage and monitoring whether risks occur is important to measure the quality of the stakeholder engagement and expected outcomes of the engagement. For each stakeholder group, albeit differences in needs and frequency of contact/engagement, it is important they have a positive attitude towards the introduced changes and a willingness to accept and implement these where needed. Identifying risks and monitoring the risks provides the opportunity to mitigate them. The table below lists the risks per priority stakeholder group and mitigating measures. Table 11: Stakeholder Groups - Risks and Mitigation Measures Priority group Engagement method Risks Mitigating measures High Weekly meetings focal No meetings organized or Scale up to Tripartite point and internal low attendance, no input (decision makers VSA, workgroup, monthly provided. Negative SZV, MHF). Support meetings monitoring attitude towards project with capacity building committee, and activities. where possible. Closely Tripartite. Workshops, manage relationships; presentations, monthly address needs and board meetings MHF concerns and report back to the stakeholder, seek solutions, manage expectations, build trust by personal contact regularly. Medium High Meetings mental health No meetings organized or Personal invitations, task force, presentations, low attendance. Negative regular contact by email consultations documents, decisions towards project and phone, check level of every 6-8 weeks. activities. information needed to Presentations, advisory keep them satisfied, committee, assessments provide regular updates, surveys, focus groups manage expectations in monthly during transparent manner, scale implementation activity. up to decision makers. Medium Consultations No feedback provided, no Contact by email, phone. documents, meetings regular provision of Follow up with check when required, information, resistance in how information was information via media outlets (including perceived via targeted newsletter or factsheets social media) on project. evaluations. Implement and website, quarterly. No surveys executed. communication plan. Presentations, public Add stakeholder meetings. Focus groups. engagement activities Survey, opinion polls. and communication strategies as integral part of the deliverables in Terms of References. Low Information via No regular provision of Implement newsletter or factsheet, information, resistance in communication plan and meetings when required. media outlets (including follow up with checks social media) on project. how information was perceived by evaluations in affected community. 38 Mental Health Project (P177679) Follow up when negative social media becomes a trend. 9 Grievance Redress and Feedback Mechanism NRPB has a Grievance Redress Mechanism (GRM) in place and available for all stakeholders. The updated GRM was revised and cleared by the World Bank in October 2022 and is disclosed on NRPB's website at: https://nrpbsxm.org/complaints-procedure/ 9.1 Scope Definition of Complaint A complaint is an issue, concern, problem (perceived or actual) which an individual, group or community wants addressed by the NRPB. This Grievance Redress Mechanism applies to complaints or grievances filed about services, products, impacts, or about employees and consultants at all levels within the Bureau. Note that this is limited to projects implemented by the NRPB. In case of doubt, the Complaints Officer will contact the complainant to clarify the merits of the request, report or complaint. Complaints are to be distinguished from queries, requests for information and service, comments and suggestions. These will be referred to the appropriate internal or external partner. In this document, the term grievance is interchangeable with the term complaint. 9.2 Who can submit a complaint? Complaints can be submitted by any member of the public, including individual or collective community members, project-workers, NRPB-staff and consultants. In accordance with the World Bank’s Environmental and Social Standard 2, on labour management, this GRM functions as a GRM for labour related complaints for direct workers and workers from contracted third-parties. It is preferred that persons submitting a complaint provide the following information: • Personal and contact information: name, address (when applicable), phone number, email address. When the complaint is submitted anonymously (see below), this information does not need to be provided. • Date the complaint is being submitted • Date of the occurrence that led to the complaint or date the complaint was discovered • Nature of the complaint: what happened, when it happened, who was involved • The consequences of the occurrence: damage, or other grievance Suggestions regarding the proposed resolution or the assistance requested from the GRM are not required, but welcomed. Complaints can be submitted via the following means: 39 Mental Health Project (P177679) 1. NRPB's website ➢ Complaints Procedure – National Recovery Program Bureau (nrpbsxm.org) 2. Telephone ➢ +1(721) 542-8886/7 ➢ The complaint form will be completed for you during the phone call, providing your name and contact details is optional. 3. E-mail ➢ Download and complete the complaint form at the link below: https://docs.google.com/forms/d/e/1FAIpQLScp07AeJ53-M_Piuf12j4owx_4d6m- MRO8BQCMDk06AfBI6g/viewform ➢ E-mail the completed form to complaints@nrpbsxm.org with "Complaint [name] Project" in the title of the e-mail. For example, "complaint Emergency Recovery Project I". Providing your name and contact details is optional. 4. Social Media – messages on the NRPB’s Facebook and LinkedIn Pages, respectively ➢ SXM National Recovery Program Bureau (facebook.com) ➢ https://www.linkedin.com/company/sxmnationalrecovery/mycompany/ 5. By visiting the office during office hours ➢ National Recovery Program Bureau #57 Walter A. Nisbeth Road Philipsburg Sint Maarten ➢ The complaint form will be provided, for completion, for further processing of the complaint The NRPB will provide the necessary assistance in cases whereby complainants experience difficulty submitting a complaint. This could be, but is not limited to, recording the complaint (completing the form) for the individual. 9.3 Anonymous Complaints Submitting anonymous complaints is possible. All complaints are handled in a confidential manner, including anonymous ones, meaning that the text of the complaint itself and the documentation relating to the complaint, is only accessible to the Complaints Officer and designated staff members that need to have access in order to address the complaint properly. Naturally, NRPB’s abilities to inform complainant of the follow up, and to ensure the resolution is satisfactory, is limited if the complainant does not provide a name and contact details. Details of any complaint may be made available to the World Bank upon their request, if anonymity has been requested by the complainant, then this will be maintained by the NRPB. 9.4 When A Complaint is admissible A complaint will be admissible if: 40 Mental Health Project (P177679) 1. Complainant is impacted by a project or anticipates that they will be impacted by a project; there is an indication that the project has caused a negative economic, social, health or environmental impact on the complainant, their immediate surroundings or has the potential to cause such an impact. 2. The project is in preparation, under implementation, or has been closed no longer than 12 months. A complaint is not admissible at the NRPB if: 1. complainant already filed a complaint about the same service, product or staff at the NRPB, which is at the time of re-submission, still being processed. Complainants will be provided with a status update of the complaint which was initially submitted. Follow-up complaints related to existing ones do not fall within this category. 2. the related event occurred, or concern arose, more than 12 months after the respective project was closed. 3. the complaint should be addressed to a different entity within government. In such an instance, the NRPB will receive the complaint and subsequently refer it to the right entity. Where necessary, the NRPB will monitor the addressal of the complaint and mediate where necessary, in order to ensure the complaint is being addressed. 4. the complaint is not about NRPB products, services, or conduct by staff or consultants of the NRPB; but the complaint is about personal and general conduct of one of the staff or consultants of the NRPB which occurred outside of the execution of their duties as staff or consultant of the NRPB. Reference is made to Chapter 4 paragraph 4.2 of the GRM, for a description of the relation between admissibility at the NRPB’s GRM and local complaint mechanisms, such as the Ombudsman and the Court. The following grievances will generally fall outside of the scope of the GRM and will be referred to the dedicated channels and addressed accordingly. • Procurement: any complaints regarding a procurement procedure fall outside of the scope of the GRM. The process by which complaints regarding procurement are handled, is described in the relevant bidding documents. In the event a complaint regarding procurement is received through the GRM, it will be promptly forwarded and referred to the Procurement Department, at procurement@nrpbsxm.org, for it to be addressed in line with the relevant provisions of the procurement framework. Admissible grievances generally contain complaints about: • Communications: information or consultation related issues • Conduct of persons involved in the project, including SH/SEA during the execution of their duties as staff or consultant of the NRPB. These can be NRPB-staff, consultants, staff or consultants or project-workers (hired by a (sub-)contractor) • Project performance and impacts o Any grievance related to the project description, for example the design or scope of the project o Environmental, social, health and safety concerns or harms generated by the project activities o Products provided by the project 41 Mental Health Project (P177679) o Reported defects on any works carried out under the projects: any complaints regarding observed defects during the defects liability period will generally be handled by the project team, as these situations are foreseen in the works contract. In the event a complaint regarding a defect is received through the GRM, it will be promptly forwarded and referred to the respective project team, for it to be addressed in line with the relevant provisions of the contract. The complaint officer will monitor the progress and ensure that the complaint is being addressed. o Any grievance related to an alleged violation of the (local) legislation by the project or its personnel. 9.5 Levels of Complaints Incoming complaints are categorized in three levels. As mentioned previously, requests for information and services, comments, suggestions and queries fall outside the scope of the GRM and are therefore not categorized. The grievance levels are based on severity of the following criteria: • Scale of the impact on the well-being of an individual or group and/or potential impact on the project, to include health and safety impacts • Scope and irremediable character • Impact on the environment and natural and cultural heritage • Violations of the national legislation and applicable treaties • Non-performance of contractual obligations The table below provides an overview of the three levels of grievances, accompanied by a description of the internal response and the staff member(s) responsible for the management of the complaint. Table 12: Levels of Complaints Level Description Internal Response Responsibility 1 The scale and scope are Respond immediately to minor. Often related to minor complainant. Record and Complaints Officer non-performance of project report as part of overall obligations. The complaint is reporting process. Does not quickly remediable. When an require internal answer can be provided consultation. immediately and/or NRPB is already working on a resolution. 2 The scope and scale are Needs consultation or input medium. It may relate to gross from Project Team and/or Complaints Officer non-performance of project Environmental and Social obligations or minor violations Specialists and/or of the law. One-off grievance Management Team that requires considered response and actions/commitments to resolve complaint. The complaint is remediable but requires planned efforts. 42 Mental Health Project (P177679) 3 The scale and scope are Needs extensive internal Executive level - medium to major. High risk consultation and needs NRPB Management of the complaint being of an input from relevant Team/Relevant irremediable character, e.g. ministries and/or external Ministry severe health and safety issue partners, including the WB. and/or law violations. Complaint may be of repeated nature and/or affecting an extensive area or group of persons. May requires significant, comprehensive action. .9.6 Guiding Principles The guiding principles of the GRM are accessibility, transparency, fairness, efficiency, collaboration and confidentiality. ➢ Accessibility: the NRPB strives for an easily accessible mechanism for all stakeholders, which allows for multiple channels of uptake (see Chapter 3 of the GRM). ➢ Transparency: the system will be publicized to a broad audience (e.g. beneficiaries, general public, CSOs, the media, government officials) to ensure all stakeholders are aware of the existence of the system and they understand how to access it. Complainants are kept informed and aware of the steps in their grievance procedure. NRPB reports to the general public on the status of the GRM through the annual report. ➢ Fairness: the NRPB strives for an equitable, unbiased grievance process by ensuring that complainants have reasonable access to sources of information, advice and expertise necessary to engage in a grievance process on fair, informed and respectful terms. ➢ Efficiency: responses will be provided as soon as possible and in accordance with the predetermined timeframes, to ensure predictability of the process. ➢ Collaboration: the NRPB strives to reach collaborative resolutions, in which dialogue with the complainant is sought and cooperation with relevant internal - and external parties is encouraged and facilitated. ➢ Confidentiality: the dialogue between the NRPB and affected stakeholders who submit a complaint, is confidential unless otherwise requested. The manner in which confidentiality is ensured, is outlined in Annex 2 of the NRPB GRM. 9.7 Grievance Management in Projects Complaints can arise throughout all projects that are prepared or implemented by the NRPB. Throughout the various projects, external partners such as Contractors, may have existing complaint Procedures in place or specifically designed, to manage incoming complaints. Additionally, Contractors may be required to have a referral system, to ensure that complaints are referred to the NRPB’s GRM for further handling, when necessary. The overall responsibility for complaint handling On projects implemented by NRPB, remains with NRPB. Incoming complaints at the Contractor’s GRM, may be handled by the Contractor or by the NRPB. 43 Mental Health Project (P177679) There are three ways in which complaints are taken up by the NRPB. o An individual or group verbally expresses a complaint to an NRPB staff member or consultant. o An individual or group submits a complaint directly to the NRPB via one of the designated channels (phone, email, letter, website, office visit, social media) o An individual or group expresses a complaint verbally or in writing to (an employee or consultant of a Contractor, who reports to the NRPB, which takes up the complaint for processing. The following factors guide whether the NRPB or the Contractor takes the lead in addressing the complaint. The details of the referral and reporting process from the Contractor to the NRPB is described in the respective project instruments, such as the CESMP and/or the LMP. (i) The sources of complaints: (sub-)contractors, (sub-)contractors’ employees, beneficiaries, stakeholders, staff and consultants of the NRPB o Contractors are generally required to have a labor-GRM in place to address worker complaints. (ii) The level of the complaint: Level 1, 2 or 3 as described in Chapter 3 of the GRM. o Level 1 complaints might be resolved by the Contractor on the spot, where possible. The Contractor will consult NRPB’s Complaints Officer when complaints cannot be resolved through the Contractor’s GRM. (iii) The type of complaint (e.g. SEA/SH complaints) o Complaints with a SEA/SH component are always referred to NRPB immediately. 9.8 NRPB’s GRM As the overarching GRM, NRPB’s GRM is extended to receive complaints from any project affected individual or group, including workers affiliated with the project, such as staff and consultants of the NRPB and workers hired by a contractor or their sub-contractor. NRPB will follow the process described in Chapter 8 of the GRM and may coordinate with the Contractor to address the complaint. 9.9 The Contractor’s GRM and its relationship to the NRPB’s GRM Contractors’ GRMs are managed by the Contractor in collaboration with the NRPB. Contractors have A key role in identifying adverse impacts in the respective project area and in implementing resolutions. Furthermore, the Contractor’s GRM should address labour complaints and, as such, be fully accessible and explained to the respective project workers. The requirements for the Contractor’s GRM, and the referral process on an operational level, are mainly governed by the Safeguards/ESF Instruments designed for the respective project, such as the (C-) ESMP and accompanying documents, Labor Management Procedures (LMP) and a Stakeholder Engagement Plan (SEP). Contractors are obligated to report all submitted complaints. For Level 2 and Level 3 complaints, incidental reports are required to be submitted to the NRPB within 24 hours of the occurrence. Additionally, regular reports on grievances received are expected in the Contractor’s monthly ESHS reports to the NRPB. The NRPB‘s Complaints Officer instructs the Supervisor and Contractors on the operation of the Contractor’s GRM with regards to the respective complaint and the Complaints Officer may take over The management of the complaint, if deemed necessary by the NRPB. Chapter 9 of the GRM provides further details on project worker complaints. 44 Mental Health Project (P177679) 9.10 Processes of the GRM This section provides a detailed description of the series of actions comprising the GRM from the moment a complaint is submitted to the eventual resolution and close out. Operating a Grievance Redress Mechanism requires a process with clearly defined steps, illustrated in the flowchart in Figure 4 and as explained in the complaint handling process presented subsequently. Figure 4: The Complaint Handling Process The Complaint Handling Process Phase 1: Receiving, Recording, Screening and Acknowledging Complaints 1 Receiving Complaints can be submitted via various channels, free of costs. Where possible, complaints will be resolved at first contact with the NRPB and handled by a designated Complaints Officer. Complaints that are submitted via the website or e-mail, are automatically sent to the second Complaints Officer within the NRPB, to ensure complaints are received and recorded. In the event of any conflict of interest, the person handling the complaint will excuse themselves. 2 Recording NRPB will record the complaint and its supporting information and will assign a unique identifier to the complaint file. The complainant should only provide necessary information for the handling of his/her complaint, to prevent irrelevant personal data from being stored by the GRM. The GRM stores the data provided by the complainant, or their authorized representative, in the e- mail box (complaints@nrpbsxm.org) and in its Case Management System. The Case Management System is on a secure digital server in a folder with restricted access. Personal data is managed in a confidential manner and in accordance with the National Ordinance on Data Protection. The record of the complaint will document: 1. the contact information of the person making a complaint (this will be left blank if the complainant wishes for anonymity) 2. issues raised by the person making a complaint and the outcome/s they propose 3. any other relevant documents or information that is provided and 4. any additional support the person making a complaint requires 3 Acknowledging NRPB will acknowledge receipt of each complaint promptly within 5 working days. Communication will be made either verbally or in written form, or the Complainant’s preferred contact method, as indicated by the complainant on the Complaint Form. If required, the acknowledgement provides an opportunity to ask for any additional information or to clarify any issues. 45 Mental Health Project (P177679) 4 Screening The GRM will typically generate three primary types of responses to complaints: • Direct action to resolve the complaint: in case the complaint can be resolved quickly and easily, the NRPB will implement the resolution immediately and provide the complainant with reasons for the decision and a close out statement. These are generally level 1 complaints, as described in Table 11. • Determination that the complaint is not admissible for the GRM, because it does not meet the basic admissibility criteria (described in Chapter 3.3 of the GRM). • In complex complaints, further assessment and engagement will be initiated with the complainant and other stakeholders to jointly determine the best way to resolve the complaint. These are generally level 2 or 3 complaints, as described in Table 11. After acknowledging receipt of the complaint, or simultaneously with acknowledging receipt, NRPB will confirm, within 10 days of receipt of the complaint, whether the issue(s) raised in the complaint is/are admissible. NRPB will also consider the outcome(s) sought by the person making a complaint and, where there is more than one issue raised, determine whether each issue needs to be addressed separately. Conflicts of interest, whether actual or perceived, will be managed in a way that removes any person Within the NRPB from involvement in the complaint. Accordingly, if a complaint contains grievances directly related to a staff member or consultant of the NRPB, that respective person will be excused from having any responsibility in the complaint resolution process, other than providing information to the person responsible for that process. For example, if a complaint contains grievances on the conduct of the Complaints Officer, the complaint will be handled by the second Complaints Officer or Legal Officer. The NRPB will advise complainants within 10 days after receipt of the complaint, when It is not possible to deal with any part of a complaint. Advice will be provided about where such issues and/or complaints may be directed (if known and appropriate). The Complaints Officer will conduct the initial assessment to determine whether the grievance is Level 1, 2 or 3 as described in Chapter 3 of the GRM. If it is suspected that it may be a Level 2 or 3 grievance, the relevant parties will need to be included in further analysis of the grievance. Phase 2: Reviewing Complaints 5 Investigation To investigate a complaint, the NRPB may: 1. Gather information from the person, group or institution making a complaint 2. Gather information about the product, area or from the person that the complaint is about 3. Review other sources of information, as relevant. The investigation phase will lead to an assessment of the following: • The issues and events that have led to the complaint • The stakeholders involved in those issues and events • The stakeholders’ views, interests, and concerns on the relevant issues • Whether key stakeholders are willing and able to engage in a joint, collaborative process (which may include joint fact finding, dialogue and/or negotiation) to resolve the issues • How the stakeholders are represented, and what their decision-making authority is • What work plan and time frame the stakeholders could use to work through the issues 46 Mental Health Project (P177679) • What resources they will need, and who will contribute them The NRPB will keep the complainant updated on the progress, particularly if there are any delays. Time frames for progress updates will depend on the nature of the complaint. Situations where complaints are complicated, or require extensive investigation, will result in extended time for the provision of updates. However, a maximum of an initial ten (10) working days from the date of submitting the complaint is allowed for the provision of updates, regardless of the nature of the complaint. The update will include the time frame within which a response can be expected. Actions decided to be taken will be tailored to each case. Each complaint will be assessed on its merits and involve the person making the complaint and/or their representative, in the process, as far as possible. The NRPB will assess and prioritize complaints in accordance with the urgency and/or seriousness of the issues raised. If a matter concerns an immediate risk to safety or security, the response will be immediate and will be escalated to NRPB Management, according to the Level 3 complaint process described in Chapter 3 of the GRM. When similar complaints are made by related parties, the NRPB intends to communicate with a single representative of the group, if the parties agree to this. Where a complaint involves multiple organizations, the NRPB will work with the other organization(s) Where possible, to ensure that communication with the complainant and/or their representative is clear and coordinated. Subject to privacy and confidentiality considerations, communication and information sharing between the parties will also be organized to facilitate a timely response to the complaint. 6 Develop a proposed response After the investigation of the complaint, NRPB will consider how to address it. Complaints will be addressed as soon as possible, in any case within six (6) weeks, with an extension possibility for complex cases. The complainant will be informed accordingly. If a person prefers or needs another person or organization to assist or represent them in the making and/or resolution of their complaint, NRPB will communicate with them through their representative if this is their wish. NRPB will take all reasonable steps to ensure that persons making complaints are not adversely affected because a complaint has been submitted by them or on their behalf. When determining how a complaint will be addressed, NRPB will consider: a. How serious, complicated or urgent the complaint is b. Whether the complaint raises concerns about people’s health and safety c. How the person making the complaint is/has been affected d. The risks involved if resolution of the complaint is delayed, and e. Whether a resolution requires the involvement of other organizations Phase 3 – Resolving Complaints 7. Communicate and seek agreement on the response The NRPB will communicate the outcome of the investigation and proposed response using the most Appropriate medium. Telephone or in person conversations held throughout the process, will be followed up with a summary via e-mail, where reasonable and possible. The final response will always be communicated to the complainant in writing (e-mail or letter). Where the complainant has difficulty reading the final response, an authorized representative will be provided with the written response on the complainant’s behalf, if such a representative is not available or does not exist, a verbal explanation will also be given by the NRPB to the complainant. Following consideration of the complaint and any investigation into the issues raised, the NRPB will 47 Mental Health Project (P177679) contact the complainant and advise them of: 1. the outcome of the investigation 2. the reason(s) for the decision 3. the remedy or resolution(s) that have been proposed or put in place If during an investigation, any adverse findings about a particular individual are discovered that might be considered of a sensitive or confidential nature, the NRPB will consider any applicable privacy obligations under the National Ordinance on Data Protection and any applicable exemptions in or made pursuant to that Ordinance, before sharing the findings with the person making the complaint. 8 Implement the response The Complaints Officer will inform the respective Project Manager and/or Program Manager within the NRPB and/or the respective external Project Manager of the resolution to be implemented. The Complaints Officer will monitor the implementation of the resolution and coordinate where necessary. 9 Close out and follow up As a final step in the process, the complaint will be closed. What constitutes a resolution? NRPB follows the prescribed procedure and comes to a resolution that is accepted by the complainant. In complex cases, a written statement from the complainant may be requested, in which it is confirmed that the resolution is satisfactory. If an agreed upon resolution is not achieved in the regular process, the Complaints Officer will escalate the complaint to the Review Panel. Criteria for Escalation and Who Can Escalate a Complaint If the complainant does not agree with the NRPB’s decision to deem their complaint inadmissible or if the complainant is not satisfied with the provided resolution, the complainant may escalate the complaint internally to NRPB’s Review Panel, by sending an e-mail to info@nrpbsxm.org. The Complaints Officer will accommodate the escalation by sending the Review Panel an escalation report, containing the following. • Summary of the complaint • Summary of the communication with the complainant and course of action undertaken • Any suggestions provided by the complainant in order to reach a satisfactory resolution Purpose of Escalation Escalation takes place when the complainant is not satisfied with NRPB’s decision or does not agree with the proposed actions and requests further handling of the matter. The Review Panel will review if the procedures of the GRM were properly followed. Subsequently, the Review Panel will assess the complaint and the action taken. The Panel will review the course of events and decide if, and what kind of, follow up actions are required to resolve the complaint. A report will be provided to the Complaints Officer, with a summary of the review and the proposed course of action. The Complaints Officer will communicate the results of the review with the Complainant via letter and/or e-mail. The Composition of the Review Panel The Review Panel will consist of Senior Management, as follows: 48 Mental Health Project (P177679) • Program Manager • Environmental and Social (Team) Coordinator • Legal Officer • External Expert (such as a government official) and • Any other NRPB Management Team member, upon request of the Panel (e.g Communications or Finance). The External Expert is dependent on the nature of the complaint and will be selected based on the needs of the situation. The principle regarding (perceived) conflict of interest will lead the composition of the Review Panel. In other words, if a person on the Review Panel has a direct stake in the resolution of the complaint, the Review Panel will appoint a substitute to temporarily replace the excused individual. After the complaint is addressed and resolved, the NRPB closes the complaint. This may be done by the Complaints Officer by phone but must be followed by written notification to the complainant, of the said closure. In situations where an escalated complaint is not settled by the NRPB Senior Management or the Review Panel, the complainant may seek, at any point, redress through alternative complaint mechanisms, such as the National Ombudsman or the World Bank’s Grievance Redress Service. If the NRPB’s GRM, in the regular process or by the Review Panel, was not able to resolve a comp laint, the NRPB may close the complaint and refer the complainant to the aforementioned alternatives for recourse. The NRPB’s GRM remains open for the complainant in case they wish to revisit the initial decision to refuse the proposed resolution. 9.11 Specific procedure for complaints regarding SEA/SH The specific nature of SEA/SH requires tailored measures for the reporting, and safe and ethical handling of such allegations. Any such complaints will be handled by NRPB’s Grievance Committee for SEA/SH, consisting of two management team members and the Complaints Officer of the NRPB. The Grievance Committee for SEA/SH will be represented by diverse genders. Key definitions and concepts: ▪ Sexual exploitation and abuse (SE): Any actual or attempted abuse of a position of vulnerability, differential power or trust for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another. ▪ Sexual Abuse (SA): Actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions. ▪ Sexual harassment (SH): Any unwelcome sexual advances, request for sexual favors, and other verbal or physical conduct of a sexual nature or any other behavior of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation to another. ▪ Confidentiality and informed consent: the information contained as a product of this procedure is reserved and confidential; therefore, the persons involved in the procedure will take the necessary actions to guarantee the confidentiality of the case and, above all, the identity of the person who is the victim of SEA/SH. Confidentiality is essential throughout the entire process. Otherwise, the survivor runs the risk of retaliation and of losing her/his physical and psychosocial safety. 49 Mental Health Project (P177679) ▪ Survivor-centered: Approach considerations related to SEA/SH prevention, mitigation and response through a survivor-centered lens,5 protecting the confidentiality of survivors; recognizing them as principal decision-makers in their own care; and treating them with agency, dignity and respect for their needs and wishes. The Grievance Committee follows the general process described in Chapter 7 of the GRM. The process is guided by the circumstances of each individual case and the needs of the survivor who is submitting the complaint. Complaints will be dealt with a survivor-centered approach to ensure that anyone who has been the target of SEA/SH is treated with dignity, and that the person’s rights, privacy, needs and wishes are respected and prioritized in any and all interactions. Any cases of SEA/SH brought through the GRM will be documented but remain closed/sealed and filed in a safe location to maintain the confidentiality of the survivor. SEA/SH cases will be reported to the WB, while ensuring confidentiality A list of GBV service providers will be kept updated and made available to the survivor by the project. The NRPB will inform the complainant of available services that might be applicable to the individual circumstances, such as the Police Department, Governmental social services, such as the Women’s Desk13 , and relevant NGO’s, such as the women‘s shelter Safe Haven. Where needed, the Complaints Officer will provide assistance in establishing communication between the complainant and the relevant service provider, in order to ensure a proper transition of the case. In case the complaint is inadmissible, the complainant will be referred to the local authorities, if so desired by the complainant and/or if so mandated by law. In case of a suspicion of a serious violation of relevant criminal law, the complaint will be reported to authorities. The NRPB reports to the police when this is legally required and when the complainant wishes for the authorities to be reported to. The local authorities have a mandate to investigate and, if applicable, prosecute any GBV-related criminal offenses. If a complaint falls within the scope of the mandate of the Inspectorate of Labor of the Ministry of Public Health, Social Development and Labor, the complaint will be shared with the Inspectorate for further handling, while maintaining the anonymity of the complainant, if so desired. In this case, the NRPB will proceed to follow up on the resolution of the complaint and closure thereof, as described in Chapter 7 of the GRM. 9.12 Roles and Responsibilities Internal Roles and Responsibilities The resolution of a complaint is a joint effort between NRPB team members, and where applicable, Contractor’s team members and the Government of St. Maarten as an implementing partner. The GRM requires the description of the internal process between these internal stakeholders, with clear communication, monitoring and reporting lines. Table 3 below provides an overview of the roles and responsibilities. NRPB Internal Operation for Complaint Handling For the internal operation of the GRM, at least one staff member is designated as Complaints Officer and, as such, this person is responsible for operating the GRM. The Complaints Officer coordinates the steps described in the GRM process. A second Complaints Officer may be designated if the volume and complexity of the incoming grievances require this. 50 Mental Health Project (P177679) Potential conflicts of interests, whether actual or perceived, will be managed responsibly. The person handling the complaint is different from any staff member whose conduct or service is related to the complaint. Individual team members may be requested to contribute to ad-hoc tasks in the process, depending on the requirements of the specific complaint. The project team members, project managers, program managers and legal officer might have a role in the investigation and implementation of the resolution of a complaint. Furthermore, individual team members of the NRPB and external individuals may be requested to take part in an ad-hoc or permanent Review Panel, which is described in Chapter 7 of the GRM. In case resolution of a complaint cannot be reached through the regular GRM process, the complaint may be escalated to the Review Panel. In this capacity, individual senior team members may have a role in designing and implementing the resolution of an escalated complaint. Table 13: Roles and Responsibilities Role Responsibility Complaints Officer • Monitor the various channels for the receipt of grievances • Acknowledge receipt of the complaint • Investigate the grievance and liaising with stakeholder/s. • Develop resolutions and actions to remediate any issues • Inform the respective project manager of the submission of a complaint within the respective project •Draft advice for the respective project manager; assessment of the complaint and proposed resolution, accompanied by a draft letter to be sent out to the complainant to formally offer the resolution. •Coordinate inter-departmental communication on the proposed resolution •Follow up and track progress of grievance •Document any interactions with stakeholders. •Monitor the grievances and assign a safeguard specialist to support when necessary. •Facilitate meeting(s) with complainant in case there are any challenges in finding agreement on a proposed resolution • Call to form a GRM Review Panel or SEA/SH committee when needed •Make sure the grievance mechanism procedure is being adhered to and followed correctly. •Maintain grievance register and monitor any correspondence •Socialization of GRM; raise internal awareness of the grievance mechanism among contractors, employees and consultants of contracted firms and relevant stakeholders. •Provide training to the Contractors on the Grievance Redress Mechanism, to include use of the Grievance Forms • Prepare reports on the GRM implementation to NRPB’s management Second Complaints Officer •Take note of incoming complaints •Take over handling of complaint in the event of a conflict of interest on the Complaints Officer’s end Environmental and Social •Provide information and assistance in developing a response and Specialists close out of a grievance upon request of the Complaints Officer • Ensure all safeguards documents for all projects implemented by NRPB, are in accordance with the GRM 51 Mental Health Project (P177679) • Monitor the operation of the GRM, to ensure environmental and social impacts are addressed properly. • Support the Complaints Officer in identifying and managing any trends in social risks emerging from the GRM Project Manager with support • Identify any complaints regarding the project and refer the of project team complainant to the NRPB’s GRM. Provide assistance where needed, e.g. provide the webpage or phone number. • Provide information and assistance in developing a response and close out of a grievance. •Develop resolutions and actions to rectify any issues. •Complaints Officer consults the Program Manager at a later stage to ensure the proposed resolution fits within the framework of the project, unless this is required sooner due to the level and nature of the complaint Program Manager •Provide information and assistance in developing a response and close out of a grievance. •Develop resolutions and actions to remediate any issues, based on the Complaints Officer’s advice. •Receives and follows up on guidance from the WB, in case a complaint is submitted at the GRS •Update the Complaints Officer on the resolution of the complaint • Assume role as GRM Review panel member or SEA/SH committee member when needed Internal experts (e.g. Legal, •Provide information and assistance in developing a response and Procurement - or Finance close out of a grievance. department) •Develop resolutions and actions to remediate any issues. Review Panel •Review escalated complaints by assessing documentation, events and actions leading to and following the escalation, legal requirements •Call meeting(s) when necessary, to finalize review • Provide a report to Senior Management of NRPB containing the proposed course of action Monitoring and Evaluation • Support in creating a Case Management System (including the Specialist ability to digitally produce reports) • Support in analyzing the collected data and interpreting with the Complaints Officer Contractors • Report grievance to the project manager or complaint officer. • Understand the process and communicate to stakeholders when asked. • Explain the mechanism to their employees and consultants and ensuring they all understand how to receive and report grievances and how to submit grievances themselves. • Operate the Contractor’s GRM; receive and respond to complaints. Maintain a grievance register. • Report regularly, in accordance with respective safeguards tools, to NRPB’s Complaints Officer • Consult NRPB’s complaint officer when complaints can not be resolved through the Contractor’s GRM • Socialization of the GRM; raise internal awareness of the grievance mechanism among employees and consultants of contracted firms and relevant external stakeholders. • Provide information and training to their employees on the Contractor’s GRM, to include use of the Complaint Form. 52 Mental Health Project (P177679) 53 Mental Health Project (P177679) 10 World Bank Grievance Redress Service The Grievance Redress Service (GRS) of the World Bank is an avenue for individuals and communities to submit complaints directly to the World Bank if they believe that a World Bank- supported project has or is likely to have adverse effects on them, their community, or the environment. The GRS enhances the World Bank's responsiveness and accountability to project-affected communities by ensuring that grievances are promptly reviewed and addressed. At any point, a complainant may also approach the World Bank's Grievance Redress Service. The World Bank procedures require the complainants to express their grievances by writing to the World Bank office in Washington DC with the completed GRS complaint form which can be found at the following URL link: http://www.worldbank.org/en/projects-operations/products-and-services/grievance-redres-sservice5 Complaints will be accepted by email, fax, letter, and by hand delivery to the GRS at the World Bank Headquarters in Washington or World Bank Country Offices. Email: grievances@worldbank.org Fax: +1-202-614-7313 By letter: The World Bank, Grievance Redress Service (GRS), MSN MC 10-1018 NW, Washington, DC 20433, USA 11 Budget for the SEP Table 14: Budget For SEP Implementation Priority group Engagement method Location Budget High Weekly meetings focal NRPB, government $ 2000 (food/drinks if point and internal needed) workgroup, monthly meetings monitoring committee, and Tripartite. Workshops, presentations, monthly board meetings MHF Medium High Meetings mental NRPB, government $ 2000 (food/drinks if health task force, needed) presentations, consultations $ 3000 documents, every 6-8 (assessment/surveys if weeks. Presentations, not part of component) advisory committee, assessments surveys, focus groups monthly 54 Mental Health Project (P177679) during implementation activity. Medium Consultations Online, news outlets, $ 3500 documents, meetings meetings in community when required, information via newsletter or factsheets and website, quarterly. Presentations, public meetings. Focus groups. Survey, opinion polls. Low Information via Online, news outlets $ 3500 newsletter or factsheet, (if not published on meetings when website, via separate required. distribution) Total $ 14000 55