SUPPORTED BY
Strengthening
Grievance Mechanisms
in Georgia
CASE STUDY
Acknowledgments
This report was part of an effort to strengthen the right to Metuge Emade, Abdulaziz Faghi, Sepehr Fotovat, Bjarney
remedy in World Bank operations and beyond by building the Fridriksdottir, Sophia Georgieva, Tamir Ibragimoff, Satoshi
capacity of World Bank staff, clients, and project-affected Ishihara, David Jijelava, Michael Kent, Joseph Melitauri, and
people, especially the vulnerable and marginalized, to Margot Skarpeteig.
implement effective grievance mechanisms so that they can
improve service delivery, risk management, and development The authors would also like to thank Laura Johnson for her
outcomes. The core team, led by Sanjay Agarwal and Saki excellent editorial support.
Kumagai, comprised Harika Masud and Hélène Pfeil at the World
Bank. Finally, the authors are grateful to the Human Rights, Inclusion
and Empowerment Trust Fund (HRIETF) for supporting the
The lead author of the report is Hélène Pfeil, with invaluable activities under this initiative. The findings, interpretations,
contributions from Sanjay Agarwal. Varalakshmi Vemuru and conclusions expressed in this report are entirely those of
provided helpful and timely guidance throughout the process. the authors and should not be attributed in any manner to the
The team highly appreciates the cooperation and contributions World Bank, to its affiliated organizations, or to members of its
of Mariami Begiashvili, Nutsa Gumberidze, and Salome Mosidze. Board of Executive Directors or the countries they represent.
Valuable inputs and comments were provided by Barbara
Contents
1 Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
2 Challenges and Lessons Learned . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4
3 Diagnostic of PIU Grievance Mechanisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Georgian State Electrosystem . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
Roads Department . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14
Municipal Development Fund . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20
References . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24
Boxes
1.1 A World Bank Initiative to Strengthen Grievance Mechanisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2
2.1 Key Challenges and Insights that Emerged Out of the Initiative . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
3.1 Examples of Project-Related Grievance Resolution by the GSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10
3.2 Estimated Cost of Activities for Grievance Redress in the Georgia Energy Supply Reliability and Financial Recovery Project . . . . 12
3.3 Example of Project-Related Grievance Resolution by the Roads Department . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
3.4 Examples of Project-Related Grievance Resolution by the MDF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Figures
3.1 Number of Complaints Received by the GSE per Year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3.2 Gender Distribution of Complainants to the GSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3.3 Uptake Channel Distribution of Complaints Received by the GSE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
3.4 Number of Grievances Received by the Roads Department by Year . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
3.5 Number of Complaints Received by the Roads Department by Road Segment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.6 Distribution of Verbal and Written Complaints Received and Recorded by the Roads Department . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.7 Complaints to the Roads Department by Type . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17
3.8 Complaints to Municipal Development Fund by Uptake Channel . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
3.9 Gender Distribution of Complainants to Municipal Development Fund . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22
Tables
1.1 World Bank-financed projects implemented by the Roads Department, the Georgian State Electrosystem and
the Municipal Development Fund in Georgia, 2013–22 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
B3.2.1 Costs for GM-related Activities for the Georgia Energy Supply Reliability and Financial Recovery Project . . . . . . . . . . . . . . . . . . . . . 12
i
1
Introduction
W
hether through the rehabilitation of roads, the complaints were sent directly or escalated to the World Bank’s
construction of electricity transmission lines, or country office because complainants were dissatisfied with the
the implementation of local infrastructure, projects way their issues had been handled; resolving their concerns
led by public sector entities influence the lives of citizens in required a great deal of support from the World Bank’s social
a tangible way. It is therefore essential that project-affected team.2 Thus, there seemed to be room to upgrade the overall
people are given a chance to provide feedback on initiatives quality of grievance management and reporting, which led
from the very start of project preparation and that if elements of to the World Bank providing dedicated technical assistance
project implementation do not meet their expectations, there is to the PIUs focused on improving and better aligning their
a clear path to having their concerns addressed. respective GMs with the principles of legitimacy, accessibility,
predictability, equity, transparency, rights compatibility,
Three project implementation units (PIUs) in Georgia— the Roads continuous learning, engagement, and dialogue, as defined in
Department, the Georgian State Electrosystem (GSE), and the the United Nations’ Guiding Principle 31 on Business and Human
Municipal Development Fund (MDF)—have been implementing Rights.
11 World Bank-supported projects in their respective fields of
competence in the years spanning the period 2013–22 (see A World Bank team initiated the technical assistance initiative
table 1.1). Each of these PIUs has implemented grievance in November 2019 (box 1.1).3 Rather than taking a project-by-
mechanisms (GMs)1 allowing project-affected people to raise project approach, the team worked with more than one PIU
concerns and problems and get them resolved. However, many at a time to create synergies and economies of scale, build
TABLE 1.1. WORLD BANK-FINANCED PROJECTS IMPLEMENTED BY THE ROADS DEPARTMENT, THE GEORGIAN
STATE ELECTROSYSTEM AND THE MUNICIPAL DEVELOPMENT FUND IN GEORGIA, 2013–22
Roads Department Georgian State Electrosystem Municipal Development Fund
• Secondary and Local Roads Project III • Transmission Grid Strengthening Project • Regional Development Project II
• Secondary Road Asset Management Project • Energy Supply Reliability and Financial • Regional Development Project III
Recovery Project
• East-West Highway 4 • Second Regional and Municipal Development
Project
• East-West Highway Corridor Improvement
Project • Sustainable Wastewater Management
Project
• Integrated Local and Regional Development
Project (in the pipeline)
1. A grievance mechanism is a system that is set up and operated to receive and facilitate the prompt handling of information requests, suggestions, positive feedback, and
concerns or grievances by project-affected parties.
2. Furthermore, data provided by the World Bank’s Grievance Redress Service at the time of this writing indicate that all seven cases recorded in the system for Georgia
concerned road construction and electrification projects
3. The World Bank team included senior social development specialists. The technical assistance initiative was initiated with a mission to Georgia, followed by ongoing
conversations.
1
1. INTRODUCTION
Box 1.1. A World Bank Initiative to Strengthen Grievance Mechanisms
In 2019, a World Bank mission conducted a diagnostic These activities were instrumental in enhancing
of the grievance mechanisms (GMs) of three project government staff’s awareness and knowledge of the right
implementation units (PIUs) in Georgia—the Roads to remedy and its implications, as well as PIU staff’s
Department, the Georgian State Electrosystem (GSE), and technical capacity to effectively guarantee this right with
the Municipal Development Fund (MDF)—to support their well-functioning project-level grievance mechanisms.
preparation of action plans for GM improvement. Key
activities organized under the initiative included: Resources
• At an initial workshop with technical staff from the A note prepared in the wake of the mission to Georgia
three PIUs, the World Bank team shared international provides comprehensive guidance and templates for
best practices for grievance redress and facilitated a task teams interested in implementing similar missions.
GM assessment exercise. Resources provided include a GM desk review worksheet, a
GM self-assessment checklist, sample agendas for mission
• Responding to a request from the PIUs, the World
launches and validation workshops, indicative questions
Bank team organized a presentation on management
that can be used to gather information from national
information systems for effective GMs.
or subnational PIU representatives or GM users during
• The mission team conducted field visits to field visits, a GM action plan template, and a proposed
communities in Rikoti and Khevi with the Roads standardized way of reporting project-level grievance data.
Department, in Khashuri with the MDF, and in Persa See Assessing Project-Level Grievance Redress Mechanisms
with the GSE. Meetings were conducted with municipal using a Human-Rights-Based Approach (World Bank 2022).
focal points, local-level PIU staff, contractors, and
selected project-affected persons to learn about their A GM self-assessment checklist is available for download
experiences. here.
• The World Bank team held a validation workshop with
A checklist to assess a GM’s level of inclusiveness
the three PIUs to share and validate key observations
and alignment to the effectiveness criteria of the
and findings and to assist their technical staff
United Nations Guiding Principles and Human Rights is
in preparing action plans for strengthening their
included in Fostering the Inclusion of Disadvantaged and
respective GMs. These plans were later presented and
Vulnerable Individuals or Groups in Project-Level Grievance
endorsed by senior management—a crucial step to
Mechanisms (World Bank 2021).
ensuring the effort’s sustainability. The PIUs agreed to
implement their action plans in the six-month period
following the mission.
2
1. INTRODUCTION
in-country capacity, and maximize impact. As part of this communication efforts, and grievance-related data. Efforts taken
initiative, the PIUs crafted their own GM action plans outlining to strengthen the GMs since the 2019 technical assistance until
key areas for strengthening, which they have since been late 2021 are highlighted,1 and areas for growth are explored.
diligently implementing.
This note is intended for World Bank task teams and PIUs
This note offers an overview of challenges and lessons to show how a rapid diagnostic can lead to significant
learned from the 2019 effort, then reviews each of the PIU’s improvements in the design and implementation of GMs and
GMs, including the respective GM complaint uptake channels, a marked enhancement of social accountability in projects
overall GM architecture, registration and categorization financed by multilateral development banks.
processes, investigation and resolution mechanisms, related
1. The Covid-19 pandemic slowed down the pace of project implementation overall, significantly reduced opportunities for in-person interaction for an extended period, and
limited the uptake of grievance submissions.
3
2
Challenges and Lessons Learned
T
he challenges faced and lessons learned from the griev- reporting these grievances to the PIU. Another has been to
ance mechanism (GM) diagnostic of the three selected train contractors, supervisors, field-level staff, and municipal
project implementation units (PIUs) in Georgia—the Roads representatives and to set up regular communication channels
Department, the Georgian State Electrosystem (GSE), and the to keep the PIU well informed with an accurate overview of
Municipal Development Fund (MDF)—are discussed below. the entirety1 of inquiries, feedback, and complaints voiced
by project-affected parties. The sensitization of contractors
Documenting, acknowledging, and tracking unwritten griev- appears to be particularly important because the quality of
ances is often challenging, but dedicated efforts can help. their relations with communities often influences the ease and
Complainants to the GSE’s grievance mechanism (GM) generally speed with which complaints can be submitted, recorded, and
preferred to convey their grievances verbally—rather than in satisfactorily resolved, especially in spatially dispersed projects.
writing—to the municipality, field, and/or PIU GM focal points. In
the past, the GSE’s GM did not systematically document verbal It is easy to overlook the potential of gender-based violence,
requests and responses (in-person or by phone), making esti- sexual exploitation and abuse, and sexual harassment in
mating their number difficult. Similarly, the Roads Department’s the absence of actual claims. But preparation and prevention
GM did not previously capture or track a great deal of verbal work—such as developing specific protocols and communication
and informal communication at subproject sites. In addition, materials for appropriately dealing with these complaints—
the Road Department’s hotline receives thousands of calls is essential. Dedicated procedures for dealing with such
every day—especially during the winter—mostly concerning road allegations should be set up, including referral systems, and
conditions, blockages, and the like. Such concerns are referred possible cooperation with relevant actors (e.g., the ATIP Fund in
by phone to various departments, but no documentation of Georgia) should be explored—and is often required of new World
such referrals exists, and assuming some of these calls are Bank-financed projects, depending on the risk level determined
grievances, they may not be recorded in the grievance database. during project preparation. Projects that have already been
In terms of the MDF, the Khashuri Municipality reported receiv- under implementation for several years are strongly advised to
ing approximately 280 phone calls per month—some related introduce such considerations and retrofit their GMs to account
to donor-financed projects and others not—up to 10 percent for the risk of gender-based violence, sexual exploitation and
of which may be grievances—but systematic recording is a abuse, and sexual harassment.
challenge.
GMs in practice can differ from how their structure is
However, the PIUs have found ways to improve the uptake described in relevant resettlement action plans and other
and recording of such grievances. One avenue has been to rely safeguard documents. In terms of projects implemented by
on trusted interlocutors at the local level, such as community the three PIUs in Georgia, their respective resettlement action
liaison officers, who realize the importance of tracking and plans foresaw the establishment of municipal grievance redress
1. If not the entirety, then PIUs should at least capture serious verbal grievances and then improve the recording system over time.
4
2. CHALLENGES AND LESSONS LEARNED
committees, which were either never established or only set up Prior to the technical assistance, GM procedures were usually
temporarily because their structure, composition, and mandate informal and relied significantly on the tacit knowledge of
would not have added value to the grievance resolution key players along the GM value chain. The initiative has shown
process. In fact, the GMs organically evolved into a structure that it is important to formalize and document these procedures
with individual municipal focal points either recording and to establish a common understanding of GM processes for all
solving complaints or transferring them to the PIU level, where relevant staff. Sometimes, this step is postponed or ignored
a Grievance Redress Commission can deal with complex and because of capacity issues. A clear GM manual can enhance the
cross-sectoral complaints. For example, for the MDF’s projects, coherence and reliability of the GM and ensure that in the event
while municipal committees existed that gathered the heads of staff turnover, knowledge and practices related to handling
of all municipal units, the MDF got directly involved from feedback from project-affected people remain consistent
the outset in the grievance receiving and reviewing process, and can be effectively and uniformly communicated to all
especially regarding resettlement action plans, to ensure a more stakeholders. It can also encourage the wider adoption of the
immediate response and resolution. And although not initially GM. For example, after the Roads Department developed such a
envisaged under the resettlement policy framework, the GSE guide, the procedures were applied to both donor- and state-
decided to empower the Grievance Redress Commission at the funded road construction projects.
headquarters level to make binding decisions with significant
cost implications linked to resettlement compensation, which There is scope to improve grievance data disaggregation and
proved instrumental in allowing for faster and more successful analysis. Grievance logs tend to be considered a “tick-the-box”
grievance resolution. bureaucratic reporting duty rather than a tool that can help
shed light on aspects of project implementation and potentially
The new Environmental and Social Framework invites a more make improvements. Refining the way grievances are logged
intentional focus on GMs because of their prominent place could make grievance data more useful to the PIU, for example,
in stakeholder engagement plans. This has led some project adding columns to the grievance database to indicate when the
teams to plan, budget, and develop dedicated GM brochures complaint was received; when it was acknowledged; when it
with information that would previously have only existed as a was resolved; what uptake channel was used; the complainant’s
simple document attached to the resettlement action plan and gender, age, disability, and/or other possible vulnerability
therefore would have remained much less visible. According markers; and the complainant’s level of satisfaction. Automizing
to some PIU staff, under previous safeguard policies, the certain simple calculations could also help, such as the average
scope of the GM was narrower and not generally considered a time between receiving and resolving a complaint and the
primary tool for community engagement, while Environmental percentage of complaints that are related to a particular issue.
and Social Standard 10 on Stakeholder Engagement and Far from an unwieldy database, a well-designed, lean grievance
Information Disclosure gives the GM a broader role interfacing log could potentially become a part of the PIU’s day-to-day
with project-affected people. The findings from the technical project management tools and enhance the quality of projects
assistance confirm a well-known point: dedicating adequate by flagging issues requiring attention so measures can be taken
time and resources to meaningful consultations with affected to prevent them from arising in the future. Such a grievance log
communities can significantly reduce the number and severity of could also aid in the detection of systemic, recurring issues as
received grievances. 1
opposed to isolated grievance cases.
1. For instance, in one energy project, due to a tight implementation timeline, the construction was rushed, consultations were carried out superficially and hastily, land was
not fully compensated prior to the start of the construction, and some grievances submitted to the contractor were not given adequate attention (with a view toward not
halting construction). All this led the World Bank to issue a notice threatening disbursement suspension. In addition, the contractor and implementing agency went through
an adjudication process.
5
2. CHALLENGES AND LESSONS LEARNED
Box 2.1. Key Challenges and Insights that Emerged Out of the Initiative
Key insights that emerged out of the grievance mechanism plan—including the possible allocation of financial and
(GM) strengthening exercise include: human resources to project-level GMs—are essential to
optimizing the effectiveness of grievance handling and
• Dedicated efforts and trusted interlocutors at the local overall project implementation quality.
level can improve the systematic uptake and reporting
• There is value to systematizing a GM’s procedures in
of verbal grievances.
manuals and policies to enhance its consistency and
• There is scope to strengthen communication and effectiveness.
awareness raising around gender-based violence,
• Most projects have room to improve grievance data
sexual exploitation and abuse, and sexual harassment
disaggregation and analysis by capturing more detailed
as part of project-level GMs.
data on complaint handling and complainants and by
• Effective GMs must reflect the on-the-ground reality of identifying trends in the grievance data.
project implementation and be based on existing social
• Grievance outcomes should be publicized to inform
accountability dynamics.
people of the GM’s actions and results. Such informa-
• The focus of the Environmental and Social Framework’s tion can and should be communicated internally to the
Environmental and Social Standard 10 on stakeholder management of the public agency involved as well as
engagement, information disclosure, meaningful externally to the general public to build their trust in
consultations, and effective GMs, as well as its the GM. Such reporting does not often occur, however,
formalization through the stakeholder engagement suggesting that further efforts are needed.
While it is commonly understood that high-level management (for example, in terms of updating grievance logs), and the
endorsement and widespread public awareness account degree to which they have been able to implement changes
for a significant portion of a GM’s success, institutionalized independently—or if progress depended on other actors,
reporting of grievances and other feedback to PIU senior man- such as management, the public relations department, or a
agement and the public is often lacking. Regularly reporting contracted consultant.
findings of grievance data analyses to senior management and
disclosing grievance-related information to the public can boost 3 Some delays in putting action points into practice can be
the usefulness of the collected grievance data by allowing deci- attributed to contextual restrictions linked to the Covid-19
sion makers to identify trends and needed remedial actions, and pandemic, for example, delays in planned in-person activities
by building public trust in the GM’s effectiveness, transparency, such as trainings. Some activities may have required a
and oversight. Integrating grievance data into a project’s standard timeframe exceeding six months (see areas for growth in the
progress reporting thus seems like a good practice to adopt. following sections for each individual PIU).
Factors that have impacted implementation of the three PIUs’ 3 How well the changes have and will be implemented
GM strengthening action plans that were endorsed by their is also linked to the intensity and intentionality of the
respective management, include: follow-up provided by the World Bank. This suggests that the
systematic monitoring of grievance data by the respective
3 The speed of progress has been driven largely by the task team specialists will be warranted to ensure the
personal commitment of the GM focal points at headquarters sustainability of the initiative.
6
3
Diagnostic of PIU Grievance Mechanisms
Georgian State Electrosystem
The Georgian State Electrosystem (GSE), Georgia’s Architecture
electricity transmission system operator, Contractors and field-level GM focal points, including community
provides power transmission and dispatch liaison officers hired for the recent World Bank-financed Georgia
services throughout the country. It is owned by Energy Supply Reliability and Financial Recovery Project, receive
the National Agency of State Property, part of the Ministry and manage grievances. Grievances that cannot be resolved at
of Economy and Sustainable Development. The GSE plans the local level are escalated to the PIU-level GM focal point.
and coordinates electricity generation and consumption and
provides access to, maintains, and develops the transmission Grievances received by the GSE are assigned to the appropriate
network, including constructing new cross-border and internal team (environmental, social, or technical). The Grievance Redress
transmission lines and substations. The GSE’s grievance Commission is called into session for complex grievances,
mechanism (GM) was designed under the World Bank’s during which a complainant’s case and all relevant information
Environmental and Social Framework, which was introduced in and documentation, including photographs, are presented
2018 and was therefore included in the project’s stakeholder and discussed, after which the GSE issues its final decision.
engagement plan to address any concerns related to the The commission comprises the board of directors and the
project’s environmental and social performance. various department heads. Community liaison officers are also
sometimes invited to attend its meetings. Since 2019–20, the
GSE’s director general has been heading the commission. The
An Overview of the GSE’s Grievance Mechanism involvement of the GSE’s highest level of management on
Uptake channels the commission is vital to its ability to work efficiently and
3 Verbally to a contractor, community liaison officer, or local reach conclusions that have the political backing required for
municipality representative who can help the complainant implementation.
write down and formalize the complaint
3 Grievance registration form available at municipal city halls Registration of grievances
3 Letter addressed to the GSE’s headquarters Grievances received from different sources are documented
(Tbilisi, St. Baratashvili N2, 0105) and shared with the PIU-level GM focal point, who records all
3 Email: info@gse.com.ge grievance information in a log, tracks and updates grievance
3 Facebook: https://www.facebook.com/electrosystema/ data, and maintains hard and soft copies of case files. The
3 Hotline: +(99532) 2 510 202 grievance log is an Excel spreadsheet that classifies grievances
by project, topic, answer dates, proposed resolution dates,
7
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Photos 3.1 and 3.2. Public and private consultations held in
2020 in the villages of Gori (left) and Paposhvilebi (above) to
provide residents with project- and GM-related information.
and so on. Upon receipt, an acknowledgment is sent to the to resolve grievances, which could involve the technical team
complainant, including a copy of the recorded grievance. going on field visits, involving the parties as needed. The final
proposed resolution of the grievance is communicated to the
The GSE uses an e-document system, which allows for the complainant in writing. Complainants are informed of the
uploading of paper documents (e.g., handwritten letters) and decision within a maximum of 30 days, in accordance with the
logs all relevant information and materials about a complaint response time stipulated in the Administrative Code of Georgia.2
(e.g., GIS imagery). The e-document system also allows the If complainants are not satisfied with the resolution proposed
GSE’s chairman to delegate grievances to responsible managers by the GM focal point or the community liaison officer, they can
(department heads), who then assign their resolution to division appeal to the Grievance Redress Commission. Complainants
heads (e.g., the GSE’s environmental and social division). are systematically informed of their right to appeal in court
at any time if they do not agree with the proposed grievance
Categorization of grievances resolution.
For the upcoming Jvari-Tskaltubo project, grievances are
categorized along the following categories: construction-related Communications
issues, land-related issues, occupational health and safety Information regarding the GM has been shared primarily during
issues, social issues, road safety issues, environmental issues,
1
initial project consultations, which allow project-affected people
and financial issues. to raise any questions or concerns they may have, for instance
regarding the right of way, buffer zones, or safety of overhead
Investigation and resolution of grievances lines (see photos 3.1 and 3.2). During such consultations, the
The PIU’s GM focal point oversees the completion of the functioning of the GM is explained in detail, and GM forms are
grievance resolution process. If needed, a dedicated person is distributed to community members.
assigned to follow-up with complainants and work with them
1. Examples of social issues include disruption of public services (e.g., hospitals, schools, water, and electricity supply), historical sites, cultural sites, child labor, sexual
harassment, sexual exploitation and abuse, staff misconduct/disrespect of the code of conduct, and issues related to local committee members.
2. The Administrative Code of Georgia (articles 178–201) provides an overall frame of reference that applies to all public sector entity GMs. Article 183 specifies that “an
authorised administrative body shall be obliged to review (an) administrative complaint and make a respective decision within one month.” The timeframe may be extended
“by no longer than one month,” but the complainant must be “immediately notified” in such cases.
8
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
FIGURE 3.1. NUMBER OF COMPLAINTS RECEIVED BY THE GSE PER YEAR
140
124
120 110
100
80
60
40 34
21
20
5 5 1
0
2015 2016 2017 2018 2019 2020 2021
Community liaison officers play crucial roles in the ongoing FIGURE 3.2. GENDER DISTRIBUTION OF
provision of information about the GM and in liaising with the COMPLAINANTS TO THE GSE
GSE’s headquarters about any potentially problematic issue
related to project implementation. They set up information
desks in the affected municipalities in easily accessible places,
where they can meet and share information about the project Women: 17%
with project-affected parties and other stakeholders. Men: 83%
Monitoring and Evaluation of Grievance Data
By the time of the 2019 mission, the GSE had recorded
256 grievances in its database regarding the Akhaltsikhe-Batumi
FIGURE 3.3. UPTAKE CHANNEL DISTRIBUTION OF
Project, covering the years 2015–19. The average resolution COMPLAINTS RECEIVED BY THE GSE
time was about 15 days; 48 grievances were closed in less than
one day.
Since 2020, 44 grievances were received by the GSE regarding Mail/letter: 92%
the Akhaltsikhe-Batumi Transmission Line project and two
By hand to GSE
headquarters: 1%
regarding the Jvari-Tskaltubo project. All grievances have been
Email: 2%
resolved. Figure 3.1 shows the number of grievance numbers
Verbally: 5%
received by year; figure 3.2 illustrates the gender distribution of
complainants; and figure 3.3 reveals the distribution of uptake
channels used to file complaints with the GSE.
9
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Box 3.1. Examples of Project-Related Grievance Resolution by the GSE
Examples of complaints received by the Georgian State While the Covid-19 pandemic slightly delayed these
Electrosystem’s Grievance Mechanism (GSE’s GM) about the activities, which were supposed to have begun in the fall
Akhaltsikhe-Batumi Transmission Line Project are outlined of 2020, they nevertheless appear to have yielded positive
below. results, convincing project-affected parties of the low risks
associated with the EMF radiation caused by overhead
In 2020, project-affected parties in the Skhalta section lines outside the safety/buffer zones. Furthermore, this
raised a collective concern regarding the perception experience led to the GSE proactively communicating
that the transmission line’s electromagnetic field about this issue with project-affected parties in other
(EMF) presented risks that could endanger their health, municipalities—an upstream communication effort that
agriculture, and the environment in general. The GSE seems to have effectively reduced fears and enhanced
adopted a multipronged approach in response. understanding of the project’s impact.
First, the GSE reiterated that the project was being planned In February 2021, the GSE received a grievance from a
and implemented in accordance with national legislation, project-affected person with a plot of land, real estate,
World Bank requirements, and all applicable international and perennial cultures situated inside the overhead
regulations and recommendations set up by the World line protection zone. The complainant refused to sign
Health Organization. the servitude agreementa that was proposed in the
resettlement action plan but instead requested a full
In addition, the GSE worked closely with community relocation. The GSE’s social affairs division submitted this
liaison officers and developed a partnership with the complaint to the Grievance Redress Commission. After
nongovernmental organization EcoVision to elaborate discussion, members of the commission decided to satisfy
an information and awareness-raising campaign for the request. The GSE communicated the resolution to the
project-affected parties. The program included educational complainant who expressed satisfaction with the outcome.
sessions for teachers and local communities; a “transmit
energy” campaign for students, including informational In February 2021, the GSE received a verbal grievance
meetings, paintings, and a video competition; the from a complainant whose plot of land had been
distribution of educational resources for children, impacted by the transmission line project. A particular
e.g. comic books and age-appropriate leaflets; and an tower located near the complainant’s house was
invitation to project-affected parties to participate in contributing to a landslide. The case was submitted to
EMF-level measurements at various locations, such as the GSE’s Grievance Redress Commission, which decided
around project sites directly under transmission lines, at that a relevant working group should gather additional
the nearest substation, inside their own homes, and near information and send a team to the location to investigate.
refrigerators, computers, televisions, and other electrical Based on this research, the team concluded that the tower
items. This cooperation helped convince project-affected did indeed need to be reinforced.
parties that all norms were being observed, giving them
more confidence of their personal safety. a. A servitude agreement is specific form of land expropriation that allows
investors to use the public interest as a means of gaining access to other
people’s lands while the owners retain ownership of them.
10
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Photo 3.3. GSE’s brochure about the grievance mechanism
As figure 3.2 illustrates, a much larger proportion of grievances section based on issues that emerged out of consultations
are submitted by men (83 percent) than by women (17 percent) and a specific brochure that provides information about the
possibly because men are twice as likely as women to be GM in simple, understandable language with illustrations and
documented owners in Georgia, and 1.4 times as likely as photographs to ensure its universal accessibility (photo 3.3).
women to be documented owners of agricultural land (see In addition, in January 2021, the GSE’s website added a page
Joshi and Martinez 2017). Other potential contributing factors outlining the GM’s basic functioning and various channels for
are sociocultural norms and stereotypes, such as the much submitting grievances.
stronger representation of men in professions linked to the
project, including engineering, construction, and energy, and Written guidance was prepared by the PIU GM focal point
the underrepresentation of women in local government, which for community liaison officers and local staff. This guidance
could explain their being less willing than men to approach local explains the procedures surrounding project-related activities,
municipality representatives with feedback (ADB 2018). timelines, and required actions, and provides detailed
information about the GM, including how contractors should
address worker grievances and how the project will address GSE
Achievements staff grievances.
The progress made toward strengthening the GSE’s GM since
November 2019 is summarized below. The GSE trained community liaison officers and field staff.
The relevant topics covered in the training include the GM,
Communications regarding the GM have been enhanced. communications, implementation of the resettlement action
The PIU developed and disseminated communication materials plan, and land registration. In addition, the GSE now holds
to raise community awareness of the GM, including a general weekly meetings to address any social issues that arise.
brochure about the projects with a frequently-asked-questions
11
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Box 3.2. Estimated Cost of Activities for Grievance Redress in the Georgia Energy Supply
Reliability and Financial Recovery Project
The costs associated with GM-related activities for the project-impacted municipalities—at a cost of US$500 per
GSE’s Georgia Energy Supply Reliability and Financial month. The total cost over a five-year period is US$150,000,
Recovery Project are outlined in table B3.2.1. In addition, with an additional US$50,000 budgeted for travel-related
the stakeholder engagement budget presented in the costs. While these budget estimates are specifically
project’s stakeholder engagement plan foresees the hiring tailored to the Georgian context, they may serve as a
of five community liaison officers—one for each of the useful benchmark for other projects.
TABLE B3.2.1. COSTS FOR GM-RELATED ACTIVITIES FOR THE GEORGIA ENERGY SUPPLY RELIABILITY AND
FINANCIAL RECOVERY PROJECT
Grievance Redress Activities Quantity Unit Cost (US$) Frequency Per Year Total Cost (US$) Remarks
Communication materials 5,000 0.5 2 5,000
(e.g., pamphlets and posters)
Guidebook/manual 500 10 1 5,000
Suggestion boxes for every 30 50 1 1,500
municipality and village
Management information 1 20,000 1 20,000 Included in procurement
system/database plan
Training of municipal-level 5 100 5 2,500 One training per year in
grievance redress committees each municipality
Internal training for GSE and 1 500 5 2,500 One training per year
contractor staff
Contingency (10 percent) 3,650
Subtotal 40,150
GM = grievance mechanism; GSE = Georgian State Electrosystem.
Source: GSE 2019: 24.
12
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
The PIU made efforts toward minimizing the risk of of the resolution for each grievance nor the complainants’ level
incidents related to gender-based violence (GBV), sexual of satisfaction with the overall grievance handling process. The
exploitation and abuse, and sexual harassment. For example, number of days between the receipt and acknowledgment of
the PIU created GBV-related communication materials to the complaint and the number of days between the receipt and
raise awareness, and the World Bank conducted a GBV- resolution of the complaint is not automatically calculated.
related training/information session for relevant PIU staff and Improving the categorization of entries and the ability to filter
representatives of all GSE departments. them by uptake channel would allow a more nuanced analysis.
Produce a training manual. Such a tool could enhance the
Areas for Growth capacity of multiple actors in the GM value chain, both at the
Based on the activities enumerated in its November 2019 GM local and headquarters levels, and enumerate the specific
action plan that have yet to be implemented, areas that the GSE procedures for various types of grievances.
could pursue to further enhance its GM are discussed below.
Develop a GBV training module. This could help train workers
Diversify the approach to communicating about the project. on the code of conduct and raise community awareness of this
The potential of short videos to enhance communications about topic.
projects could be explored, for example, as could cooperation
with local and central media outlets to increase awareness of Use technology to enhance the quality of grievance redress.
project activities among affected parties. Coordinating with The use of smartphones and tablets could be considered
the GSE’s public relations department to utilize their outreach for data collection and grievance validation purposes. And
channels could prove beneficial as well. developing a grievance management information system could
decrease the time spent writing reports for every grievance and
Improve grievance recording, disaggregation, and analysis. allow field staff and municipal authorities to enter data into the
The relevant spreadsheet does not include a detailed description database directly.
13
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Roads Department
In coordination with the Ministry of Regional These focal points are aware of a partner NGO operating across
Development and Infrastructure, the Roads the country to whom they may refer cases and are cognizant of
Department implements major road infrastructure the importance of dealing with cases confidentially. At the time
development projects and maintenance measures for of this writing, no GBV-related cases had been received. During
international and domestic roads. The Roads Department’s weekly site visits, the PIU’s GM focal point always asks female
grievance mechanism (GM) was set up based on definitions workers at construction sites and work camps about their
put forth in the relevant projects’ resettlement action plan, experiences and lets them know that they can raise GBV-related
a document required for all World Bank-financed projects grievances with her directly.
triggering Operational Policy 4.12 on Involuntary Resettlement. 1
At the PIU level, the Grievance Redress Commission, set-up
over ten years ago and guided by specific terms of reference,
An Overview of the Roads Department’s convenes at least once a month to discuss and resolve cross-
Grievance Mechanism sectoral grievances and any grievances that have escalated to
Uptake channels it. This commission includes the head of the Roads Department
3 Grievance boxes attended to once or twice weekly in the and all deputy heads, including the legal, design, and roads
vicinity of construction sites, which the civil works contractor construction division, among others. Consultants working
is responsible for setting up on resettlement action plans and environmental and social
3 24/7 hotline: +995 32 2 31 30 76 management plans, design companies, and others can be invited
3 Resettlement unit hotline: +995 32 2 31 30 76 (34–08), to participate in the commission.
9:00 a.m.–6:00 p.m.
3 Local municipal representatives (e.g., head of municipality) Registration of grievances
3 Project managers implementing resettlement action plans, The PIU’s GM focal point, who is based in the environmental and
environmental and social teams of civil work contractors, and social issues division, coordinates the recording, processing, and
engineering teams resolution of grievances, and maintains a spreadsheet database
3 Environmental, social, and registration division managers of of grievances. All actors receiving grievances must report them
the Roads Department to the PIU’s GM focal point, except contractors, who report to
3 Facebook: https://www.facebook.com/georoad.ge/ the supervision engineer who then informs the PIU’s deputy
3 Email: info@georoad.ge department head and the environmental and social issues
division team in a monthly summary report. The PIU’s GM focal
Architecture point then consolidates these reports in an electronic format.
There are two dedicated focal points for complaints involving
gender-based violence, sexual exploitation and abuse, or sexual The PIU uses an e-document system for formal letters and
harassment: the PIU’s GM focal point (a woman) and a female communication. This online system relies on creating individual
lawyer who works closely with highway civil work contractors. case files and scanning and uploading printed letters and
relevant documentation to each file. Once a new case file is
1. For more information on the World Bank’s Operational Policy (OP) 4.12, see https://policies.worldbank.org/en/policies/all/ppfdetail/1584. While OP 4.12 has been replaced
by Environmental and Social Standard 5 (Land Acquisition, Restrictions on Land Use and Involuntary Resettlement) since the entry into force of the Environmental and
Social Framework in October 2018, projects approved prior to this date still apply OP 4.12.
14
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
created, the deputy head of the Roads Department receives Investigation and resolution of grievances
a notification and assigns it to a person in the relevant Simple grievances (e.g., regarding the removal of stones or
department who will oversee the complaint process through its excess water during road construction) can often be resolved
resolution. quickly by the civil works contractor. If the civil works contractor
cannot solve the issue independently, the supervision engineer
Categorization of grievances and PIU become involved. If external expertise is required to
The grievance log clearly captures the following data for most resolve the complaint, an independent expertise bureau can be
complaints: name of road segment linked to the grievance, included in the investigation process (for example, to examine
whether the grievance was submitted in writing or verbally, cracks in houses). After such a bureau shares its findings, the
name of the community from which the complaint emanated, Roads Department presents the investigation’s conclusions in a
the type of complaint, a description of the complaint and final document, which is then scanned and attached to all other
proposed resolution, the date the complaint was received, relevant materials in the e-document system.
the date it was resolved, the status of the complaint, and the
number of days the complaint was open. The proposed grievance resolution is sent in writing to the
complainants and must be delivered by hand by the postal
Grievances are assigned to one of the following categories: service with proof of receipt. If the postal service cannot
(1) compensation rate; (2) crop compensation; (3) damage to reach the complainant, the letter is returned to the Roads
infrastructure/assets; (4) disturbance: noise/vibrations /dust; (5) Department, and the project manager must then deliver it to
health, safety, and environmental concerns; (6) inclusion in land the complainant. Grievances at the local level must be resolved
acquisition and resettlement plan; (7) inclusion in resettlement within 7–10 days, and those escalated to the Roads Department
action plan; (8) registration/ownership status; (9) restriction or must be resolved within 10 days; the total maximum period
loss of access; or (10) other. allowed for the resolution of a grievance is 30 days.
Box 3.3. Example of Project-Related Grievance Resolution by the Roads Department
During an upgrade to a road section between the was based on official statistical data on livestock and
Agara and Gomi Bypass as part of the Fourth East-West veterinary status provided by the Scientific-Research
Highway Improvement Project, implemented by the Roads Center of Agriculture in the Shida Kartli region (Khashuri
Department, Agarebi village residents complained about municipality), official data and prices, and the estimated
a permanent restriction of access to pastureland that loss of livestock calculated over a one-year period. In August
significantly reduced the number of cattle in their village— 2020, the determined amount—GEL 6,143.97 (US$1,905)—
and the related income. According to a representative was transferred to each of the 32 affected households,
of Khashuri’s mayor, before the start of the highway regardless of whether they had encountered a full or partial
construction, there were about 90 livestock, later dropping loss of cattle. Later that month, and again in October 2020,
to only 35. In response, the Roads Department proposed the municipality of Khashuri shared additional information
a livelihood restoration approach to compensate affected with the Roads Department, identifying and confirming
households by providing sufficient compensation to restore additional affected households who then also received the
their livelihoods and economically empower them. The agreed compensation amount.
compensation package elaborated for each household
15
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Photo 3.4. Construction of Rikoti Pass Road Photo 3.5. Road rehabilitation in the community of Gremiskhevi
Communications submissions (23 and 77 percent, respectively). Figure 3.7
Information about the grievance uptake channels and details demonstrates how most received complaints are linked to
about where grievances can be filed are communicated to damage to infrastructure or assets (43 percent), followed
the public during consultations. There are printed GM forms by restriction or loss of access to land (18 percent) and crop
available at municipal-level information desks. Municipal halls compensation (12 percent).
display flyers with general project information and keep onsite
hard copies of the resettlement action plan, including annexes.
FIGURE 3.4. NUMBER OF GRIEVANCES RECEIVED BY
Signs and banners with the GM focal point’s contact information THE ROADS DEPARTMENT BY YEAR
are posted and grievance boxes are installed at contractors’
60
camps. The Roads Department’s hotline number and website
address are posted on all construction site billboards.
50
Monitoring and Evaluation of Grievance Data 40
Between 2015 and 2022, the Roads Department’s GM received
60 complaints about six World Bank-financed projects
30 28
concerning the following road segments: Agara-Gomi-Zemo
Osiauri, Khidistavi-Ateni-Boshuri, Bakurtsikhe-Gurjaani
Bypass, Tianeti-Akhmeta, Zemo-Osiauri chumateleti F0, and 20
Chumateleti-Khevi.
11
10
6
The number of grievances received by the Roads Department 4 5
2 3
every year is illustrated in Figure 3.4. Figure 3.5 shows the 1
number of complaints received about each road segment;
0
2015 2016 2017 2018 2019 2020 2021 2022
and figure 3.6 illustrates the verbal versus written complaint
16
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
FIGURE 3.5. NUMBER OF COMPLAINTS RECEIVED BY THE ROADS DEPARTMENT BY ROAD SEGMENT
40
35
35
30
25
20
15
10
10
4 5 4
5
2
0
Agara-Gomi- Khidistavi- Chumateleti- Zemo-Osiauri Tianeti- Bakurtsikhe-
Zemo Osiauri Ateni-Boshuri Khevi chumateleti F0 Akhmeta Gurjaani Bypass
FIGURE 3.6. DISTRIBUTION OF VERBAL AND WRITTEN COMPLAINTS
RECEIVED AND RECORDED BY THE ROADS DEPARTMENT
Verbal complaints: 23%
Written complaints: 77%
FIGURE 3.7. COMPLAINTS TO THE ROADS DEPARTMENT BY TYPE
Compensation rate: 2%
Crop compensation: 12%
Damage to infrastructure/assets: 43%
Disturbance: noise/vibrations/dust: 5%
HSE concerns: 11%
Inclusion in LARP/RAP: 3%
Registration/ownership status: 4%
Restriction or loss of access: 18%
Other: 2%
HSE = Health, Safety, Environment LARP = Land Acquisition and Resettlement Plan RAP = resettlement action plan.
17
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Achievements
The progress made toward strengthening the Roads
Department’s GM since November 2019 is summarized below.
An internal GM policy and manual were prepared. They cover
all projects implemented by the Roads Department and include
a summary of good practices. Intended for staff and consultants
of the Roads Department, the policy outlines ways to deal with
verbal and written complaints, the timeline for internal and
external responses, the categories of grievances, and project
managers assigned for each project. At the time of this writing,
the policy and manual were under management review.
Communications about the GM were developed. Leaflets,
flyers, and posters were created and community meetings held
that included information about the GM (see photos 3.6 and 3.7).
Various grievance logs were consolidated. The separate
grievance logs that had existed for different donors, including
the World Bank, the Asian Development Bank, and the European
Investment Bank, were reorganized and consolidated into one
spreadsheet.
Capacity-building trainings were conducted. Despite the Photos 3.6 and 3.7. Meetings held by the Roads Department
with local communities in 2020
Covid-19 restrictions, which limited in-person meetings to a
maximum of 12 people at one time, trainings that included
information about the GM were carried out in 2019 and 2021 for GBV prevention strategies were implemented. To prevent
contractors, supervisors, local staff, and project workers. gender-based violence, sexual exploitation and abuse, and
sexual harassment, a separate GBV incident communication
A new management information system was developed. document was created, and GBV trainings and information
A private company developed the system for the Roads sessions were conducted for PIU staff and local communities.
Department; its beta version was being tested at the time of A GBV module on the code of conduct for workers was included
this writing. The system will allow for the inclusion of legal in trainings and in awareness raising sessions targeting local
and financial logs, as well as environmental and social logs for communities. Special guidelines for cases of gender-based
projects financed by international donors. Civil works contractors violence, sexual exploitation and abuse, and sexual harassment
can also provide inputs. A color-coding system will flag issues have been developed and distributed to highway project
that are not being handled in the allotted timeframe to the contractors. The PIU’s social and environmental safeguard
Roads Department’s deputy chairman. The PIU and the World specialists also developed and provided special training to
Bank will have digital access keys allowing for a real-time check women employees in workers’ camps.
of open and closed grievances related to their projects.
18
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Efforts were made to ensure the quality of grievance collection. Examples include capturing the uptake channel;
resolution. Periodic spot checks were conducted in 2020, and logging information about the complainant’s gender, disability
feedback was collected periodically on the experiences of status, and age cohort; and more consistently exploiting existing
complainants with the GM as well as their level of satisfaction data points by systematically calculating grievance resolution
with the outcomes. timelines.
Expand GM-related communications. Options for publicizing
Areas for Growth the GM among affected communities include making
Based on the activities enumerated in its November 2019 GM information and grievance forms—and possibly suggestion
action plan that have yet to be implemented, areas that the boxes—widely available in municipal offices and public spaces
Roads Department could pursue to further enhance its GM are and coordinating with the public relations department to share
discussed below. information about the GM on the Roads Department’s website,
its Facebook page (which has about 42,000 followers), and
Enhance GM processes. Examples include improving the YouTube channel (which has about 200 subscribers). Information
practice of sending written acknowledgments to GM users upon about the GM could also be presented on the website in a more
receipt of written grievances and collecting feedback from straightforward way. There is information about resettlement
complainants about their experiences and level of satisfaction action plans but there is not a dedicated section on grievance
in a more systematic manner. redress or any detailed information on the scope of the GM.
The website could also feature an annual report on grievance
Improve the categorization, monitoring, and analysis of redress, providing an overview of progress made, grievance
grievance data. Richer grievance data analysis could be statistics, and other issues.
achieved by expanding the granularity of grievance data
19
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Municipal Development Fund
Established in 1997, the 3 The MDF’s beneficiary relations specialist—also its GM focal
Municipal Development point—whose direct phone number continues to be widely
Fund (MDF), under the communicated (calls made to the MDF’s main number are
supervision of the government and the Ministry of Regional redirected).
Development and Infrastructure, cooperates with all the
large investment banks and financial institutions operating Architecture
in Georgia. The MDF aims to enhance the institutional and Depending on the complexity of the received grievance, local
financial capacities of local self-governmental bodies, invest in municipality representatives can try to solve the issue on their
local infrastructure and services, and improve the economic and own or in cooperation with the contractor, or they can involve
social well-being of the local population. The MDF implements the MDF’s GM focal point in the investigation and resolution
infrastructural projects such as urban renovation, arrangement process.
of infrastructure at tourist and cultural heritage monuments,
construction and rehabilitation of schools and kindergartens, Registration of grievances
and improvement of infrastructure to make it resilient to After receiving a complaint, local municipal representatives
natural disasters. The MDF’s GM relies heavily on cooperation contact the MDF directly, keeping a grievance log (a spread-
with municipalities due to the nature of the project activities— sheet) that can be shared with the MDF upon request. An
primarily small municipal-level infrastructure development. acknowledgment of the receipt of the complaint must be sent
within five working days. At the contractor level, the company’s
appointed grievance focal point inspects and responds to the
An Overview of the MDF’s Grievance submissions filed via grievance box and maintains a log of all
Mechanism complaints and their resolution. The log is shared monthly with
Uptake channels the engineer appointed by the MDF/supervision company, which
3 Email: feedback@mdf.org.ge is obliged to notify superiors as appropriate.
3 Letter addressed to municipal representatives or the MDF
3 Grievance boxes with grievance forms, accessible to the Categorization of grievances
public in the vicinity of construction sites (these boxes are Grievances are filed under one of the following categories:
checked daily by the contractors and supervision contractors, access, additional works, changes in project design,
to see if any grievance has been received, and can also be compensation, damage, noise, quality of work, request for
opened/checked during unscheduled site visits by persons information, slow progress of the works, and appreciation.
with the relevant authority)1
3 A designated GM focal point for each municipality, often Investigation and resolution of grievances
the head of the municipal infrastructure unit or the mayor, The resolution process typically includes site visits and
who serves as the public’s primary contact for feedback, additional meetings with the complainants or relevant
questions, and concerns actors with a view toward collecting all needed information
and proposing an adequate solution. In accordance with
1. It is the contractor’s responsibility to arrange a complaint box on the construction site. Complaints submitted through this channel can be anonymous. Because World
Bank-financed projects fall under the old operational policies, a separate workers’ GM is not required.
20
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Georgia’s Administrative Code, the time between the receipt
and resolution of a grievance should not exceed 60 days.
Complainant satisfaction with the outcomes is collected
informally by the MDF’s GM focal point following the closure of
the process, whether in person or by phone.
Communications
The MDF PIU disseminates information about the GM through
initial public consultations convened during project preparation
(see photos 3.8–3.10). Slide presentations are used during these
consultations, and brochures that include contact information
for municipal GM focal points are circulated among project-
affected people. At the subproject level, information banners and
signboards with relevant contact information, such as the GM’s
phone number and email address, are posted at construction
sites.
Monitoring and Evaluation of Grievance Data
The MDF’s GM received a total of 29 entries for issues related to
World Bank-financed projects from 2017 to 2021: 14 in 2017, 2 in
2018, 11 in 2019, 1 in 2020, and 1 in 2021.
Following the technical assistance mission, the MDF’s GM focal
point revised the complaint log to provide more granular data on
entries received by the GM and to allow for the easy extraction
of relevant information. For example, the log now makes it
simple to determine that over the 2017–21 period, the average
time between the receipt and acknowledgment of a complaint
was 3.7 days, and the average time between receiving and
resolving a complaint was 15.4 days. The revised log also shows
that most (34 percent) complaints are received verbally, followed
by via phone (28 percent) and mail (28 percent); email accounts
for only 10 percent (figure 3.8). Interestingly, the complaint-
related data reveals that over half (52 percent) of complainants Photos 3.8–3.10. Public consultations conducted by the MDF In
person (prior to the Covid-19 pandemic) and online
are men, while only 24 percent are women; the remaining
24 percent involve group complaints (figure 3.9).
21
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Box 3.4. Examples of Project-Related Grievance Resolution by the MDF
In 2019, a landowner and contractor in Telavi Municipality In February 2021, a female resident of the municipality of
could not agree on the arrangement of a sidewalk as Gori voiced concerns about the type of drainage channels
part of a local infrastructure project focused on the being used for the Samepo road rehabilitation project: she
rehabilitation of a road and gas supply routing. The wrote two letters asking why closed drainage channels
landowner was adamant that construction materials had been chosen rather than open ditch drainages and
should not pass through his yard and that his fence had requesting a change in project design. The MDF called the
been damaged by the construction works. The Municipal resident to inform her about the stage and process of the
Development Fund (MDF), who was implementing the project and organized a site visit that included the mayor,
Second Regional and Municipal Infrastructure Development project manager, project engineer, contractor, and the
Project that the sidewalk project was under, mediated supervision company to explain the reasons behind the
and proposed a technical engineering solution that suited choice and why changes could not be made, notably due
both parties. A follow-up meeting was conducted with the to engineering concerns. The resident later wrote a letter
complainant a month later, who confirmed that he was saying she was satisfied with the detailed explanation
satisfied with the resolution and had no further complaints provided.
or concerns about the project.
FIGURE 3.8. COMPLAINTS TO MUNICIPAL FIGURE 3.9. GENDER DISTRIBUTION OF
DEVELOPMENT FUND BY UPTAKE CHANNEL COMPLAINANTS TO MUNICIPAL DEVELOPMENT FUND
Call: 28% Men: 52%
Letter: 28% Women: 24%
Verbal: 34% Group (mixed): 21%
Email: 10% Group (women): 3%
22
3. DIAGNOSTIC OF PIU GRIEVANCE MECHANISMS
Achievements Areas for Growth
The progress made toward strengthening the MDF’s GM since Based on the activities enumerated in its November 2019 GM
November 2019 is summarized below. action plan that have yet to be implemented, areas that the
MDF could pursue to further enhance its GM are discussed
The grievance log was improved. The log was revised to below.
better record, categorize, and analyze all types of inputs
received by project-affected parties. For example, the revised Create a separate GM webpage on the MDF’s website.
log distinguishes between types of received feedback (e.g., The webpage should include detailed information about GM
grievance, inquiry, appreciation, and request). The log is procedures, steps, channels, and timelines; there should be
now capturing data about a complaint’s date of receipt, an online grievance receipt form; and an annual report on
acknowledgment, and resolution. Another improvement is the grievances should be posted. Such a dedicated webpage is
inclusion of the complainant’s disability status. Finally, the likely to be included in a broader redevelopment of the MDF’s
grievance log now consolidates inputs received by project- entire website, which the Ministry of Regional Development and
affected parties for all donor-financed projects. Infrastructure would need to validate.
A grievance manual was drafted. The GM focal point developed Engage in additional capacity-building. Capacity-building
a grievance manual that includes written guidance on GM opportunities have been severely restricted by the Covid-19
standards and procedures for MDF staff, municipal focal pandemic. As a result, the PIU’s beneficiary relations specialist
points, the Grievance Redress Commission, contractors, and and gender and social specialist have not yet been able to
the supervision company. The manual must be validated by the organize in-person trainings for the local representatives and
MDF’s unit head before it can be shared with civil contractors, mayors of Georgia’s 63 municipalities on issues such as the GM,
the supervision company, and project-affected parties at future gender, and environmental and social management plans.
consultations.
Conduct GM trainings for contractors and supervisors. Such
Anonymous grievance boxes were set up. To improve trainings were postponed due to pandemic restrictions. However,
the accessibility of the GM and reduce fears of retaliation, once the new GM manual is validated, it will be presented to
complainants can now submit their grievances anonymously the supervision company and, prior to the commencement
using grievance boxes located at the MDF and in project-affected of any new subproject, the contractors will be trained by the
municipalities. supervision company, including on GM-related procedures. The
supervision company will be required to issue a report about the
GM-related training for contractors in its monthly monitoring
table, which it submits to the PIU.
Develop new communications. Subject to the MDF
management’s approval of the draft GM manual, new
communication materials will be produced, such as brochures
with detailed information about GM procedures, steps, channels,
and timelines.
23
References
ADB (Asian Development Bank). 2018. Georgia: Country Gender Assessment. Joshi and Martinez. 2017. Filling the Gender Gap on Asset Ownership Data. Asian
Development Bank.
GSE (Georgian State Electrosystem). 2019. Stakeholder Engagement Plan for
World Bank. 2022. Assessing Project-Level Grievance Redress Mechanisms using a
the Construction of 500 KV Jvari-Tskaltubo Overhead Transmission Line and
Human Rights Based Approach. Washington, DC: World Bank.
Associated 500 KV Substation Tskaltubo. Energy Supply Reliability and Financial
Recovery Project.
24
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