Client Consultant Contractor

REGIDESO AECOM KEC INTERNATIONAL

GRIVENCE
MANAGEMENT PLAN
PREPARED&
CHECKED By DESIGNATION APPROVED BY DESIGNATION

ORGANISATION KEC MANAGER EHS REGIDESO&AECOM

SAJIL
NAME
AL.AS
CONSTRUCTION OF HV/MV LINES ASSOCIATED WITH THE
PROJECT NAME HYDROELECTRIC DEVELOPMENTS OF JIJI AND MULEMBWE
SIGNATURE

CONTRACT NO. 05/IA3A/KEC LTD/PHJIMU/T/2021

DOCUMENT NO

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 GRIVENCE MANAGEMENT PLAN
DOCUMENT NO CONTENTS PAGE .NO
1 INTRODUCTION 5
1.1 BACKGROUND 5
1.2.1 OBJECTIVES AND SCOPE OF THE GRIEVANCE SYSTEM 5
1.2.2 MAIN OBJECTIVES 5
1.2.3 SPECIFIC OBJECTIVES 5
2 POLICY, LEGAL AND ADMINISTRATIVE FRAMEWORK 7
3 PROJECT HEALTH AND SAFETY ORGANIZATION 9
3.1 PROJECT ORGANIZATION CHART 9
3.2 ROLES AND RESPONSIBILITIES 10
3.3 LIST OF HEALTH AND SAFETY PERSONNEL 12
4 DESCRIPTION OF GRIEVANCE MANAGEMENT SYSTEM 13
4.1 KEC POLICY FOR GRIEVANCE MANAGEMENT 13
4.2 PROJECT’S GRIEVANCE MECHANISM 13
4.3 GRIEVANCE MANAGEMENT SYSTEM PROCEDURES 14
4.3.1 PROCEDURE AT STAGE 1 14
4.3.2 PROCEDURE AT STAGE 2 15
5 GRIEVANCE MANAGEMENT SYSTEM 15
5.1 WORKERS GMS 15
5.2 PUBLIC GMS ORGANIZATION DESCRIPTION 16
6 TRAINING AND SENSITIZATION MEETINGS 17
7 GRIEVANCE MANAGEMENT SYSTEM 18
7.1 WHAT IS A GRIEVANCE? 19
7.2 LOCAL COMMUNITY? 19
7.3 WHAT IS PROJECT LEVEL GRIEVANCE MECHANISM 20
7.4 HOW DOES A GRIEVANCE MECHANISM BENEFIT TO COMPANIES 20
AND COMMUNITIES
8 GRIEVANCE MANAGEMENT SYSTEM TO CONSIDER 20
8.1 WORKERS GRIEVANCE MANAGEMENT SYSTEM 20
8.2 HOW SHOULD WORKERS RAISE COMPLAINTS / CONCERNS 20
8.2.1 INSTRUCTION PLAN TO WORKERS HOW TO RAISE COMPLAINTS 21
8.2.2 HOW TO DEAL WITH NONCOMPLIANCE WITH IMPLEMENTED 21
HEALTH AND SAFETY MANAGEMENT SYSTEM
8.2.3 HOW TO DEAL WITH COMPLAINTS IN CASES OF DISCRIMINATION 21
8.2.4 MEANS OF COMMUNICATION 21
8.2.5 RECORDING OF REPORTED COMPLAINTS / NON-COMPLIANCE 21
8.2.6 INVESTIGATION OF COMPLAINTS/ NON-COMPLAINTS 21
8.2.7 CLOSING OUT CASES WITHIN 3 DAYS 22
8.2.8 CONFIDENTIALITY 22
8.3 PUBLIC GRIEVANCE MANAGEMENT SYSTEM 22
8.3.1 REPORTING PROCEDURES TO LOCAL AUTHORITIES 22
8.3.2 IDENTIFICATION OF RESPONSIBLE AUTHORITIES AT COMMUNITY 22
LEVEL WITHIN 4 WEEKS PRIOR TO ACCESS TO SITE FOR
CONSTRUCTION
8.3.3 INVOLVEMENT OF CONTRACTORS HEALTH AND SAFETY 22

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Preface

KEC International LTD is implementing Construction of HV/MV lines associated with

the hydroelectric developments of JIJI and MULEMBWE Overhead& underground -
Lines projects where safety, health, environmental and social impacts, and grievances
are a fact of life. KEC is fully aware that how we respond and (or is perceived to be
responding) when such grievances surface is important and can have significant
implications for performance for construction activities. Our grievance management
system has been scaled to fit the level of risks and impacts of this project. We believe
that this plan flows from a company’s broader process of stakeholder engagement and
business integrity principles and integrate the various elements of engagement.

In fact, to complement this system, we have a good overall community engagement,

social and gender integration, environment and health and safety plans in place and
providing access to information on a regular basis and hope this will substantially help
to prevent grievances from arising in the first place, or from escalating to a level that
can potentially undermine our productivity and performance. We, therefore, believe
that, from a basic risk-management perspective, spending the time and effort up front
to develop a well-functioning process is a good investment and hence this plan.

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1. Introduction

1.1 Background

Grievance Management System (GMS) is the handbook that will guide conflict
management to settle grievances that may arise between employees and the public
and KEC. Construction of HV/MV lines associated with the hydroelectric developments of JIJI
and MULEMBWE Overhead& underground -Lines KEC will attempt to resolve the
grievance in a manner, which is acceptable to the employee(s) and or
public/communities concerned and the Company by mutual understanding within
stipulated time. Our experience over the years KEC has been in operation in many
different countries can be categorized into main ones –employees/workers and the
local communities.

1.2.1 Objectives and scope of the grievance management system

1.2.2 Main Objective

The main objective of the grievance procedure is to resolve an employee’s or local

community dis-satisfaction and or feeling of injustice in respect of workplace or
relating to KEC or concerning an official or construction act or omission that may
adversely affect the employment and or community relationships.

1.2.3 Specific Objectives

The specific objectives of the Grievance Management System are to:

 Explain KEC’s policy for GMS.

 Provide GMS procedures.

 Describe Public/community GMS.

 Highlight benefits of GMS to both employees and the public/community.

 How to monitor and evaluate GMS.

 Conduct trainings and sensitization meetings.

Scope

The GMS will cover all employees of the company and sub-contractors and the
public/communities (project affected persons) for the entire period of construction
activities on all matters that may require consensus and constructive buildup of
relations.

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 Project Information

Brief description of the project

Engineering, Procurement & Construction of 220kV S/c OHTL, 220kV D/c OHTL, 110kV S/c OHTL, 110kV S/c
UGTL, 30kV S/c (monopole) OHTL, 30kV S/c (lattice) OHTL, 30kV S/c UGTL, 133km (OHTL + UGTL,7Lines of
Various voltage level) OHTL 126.059Km: UGTL :5.00 Km
KEC’s was awarded the contract, Contract No: 05/IA3a/KEC LTD/PHJIMU/T/2021
Overhead lines from REGIDESO with understanding that social and gender issues will be
implemented during construction of the lines.

This was well informed through the Environment and Social Impact Assessment
studies and Social and Gender Situation Analysis along the project corridor. The critical
areas highlighted in the assessment which need mitigation measures include

Table 1: KEC’s Overhead Lines

Voltage KV START DESTINATION Distance Km

220kV KABEZI S/S HOREZO S/S 73km

30kV HOREZO S/S ITABA S/S 17.3km

110kV MULEMBWE JIJI POWER PLANT" 4.4km

POWER PLANT
110kV HOREZO S/S JIJI POWER PLANT 5.1km

110kV HOREZO S/S MULEMBWE POWER PLANT 2.3km

110kV KABEZI S/S RN1 SUBSTATION 20.8km

110kV KABEZI S/S BUJUMBURA S/S 8.2km

This GMS will stay valid after the approval from the Contracting Engineer- AECOM
(CE) and any review thereafter will be done on special conditions, requests from CE
accordingly.

This GMS is part of fulfilment of KEC obligation and plan of action expected to be
developed before the construction works begin.
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 The KEC has been awarded contract from valuable client JIJI and MULEMBWE Overhead&
underground -Lines to be executed for owner, REGIDESO are appointed as consultants to
control quality, health and safety, environment, social and gender issues.

The project execution needs access roads for transportation of construction material to
sites spread along the length of line.

Project Name : JIJI and MULEMBWE OH& UG Lines

Contract Number : 05/IA3a/KEC LTD/PHJIMU/T/2021

Client : REGIDESO

End User : REGIDESO

Consultant : AECOM

Contractor : KEC.

2.0 Policy, Legal and Administrative Frameworks

As stated above, KEC being a construction contractor responsible for implementation,

which is a reflect The Social and Gender Integration and other Safeguard Documents have
been considered to guarantee that the Project is legally responsive to both Burundi and
international practices and environmentally sustainable, at the same time it respects
communities, workers, women, children, and minorities’ rights’ and needs. Some of the
international policy frameworks used are the following: - Performance Standards, KEC
Environmental Guidelines, KEC Health and Safety Manual, Global Gender Integration
Guidelines and Global Social Gender Integration Plan.

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The laws, policies, and regulations of. BURUNDI have also been considered when developing
this plan and these include the following:

 Employment Act, 2020,

 ILO guidelines
 Burundi Government Act on Labor Work Conditions (November 24 ,2020) Any issues
remained unsolved by Grievance Committee may be taken to concerned legal authorities of
Burundi Government. In addition to KEC Corporate HSE Policy will be applied.

KEC will also comply to:

 International Guidelines and Standards as:
KEC guidelines,
Health and Safety in Construction Guide, HSG150, 3rd revision, 2006, by Health and Safety
Executive,
Workplace Transport Safety: An Employers’ Guide, HSG136, 2nd revision, 2005, by Health
and Safety Executive,

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3.0 Project Health and Safety Organization

3.1 Project Organization Chart

8022I02/FICHT-1632

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All the Subcontractor Safety Officers and Stewards Environment and Social Officers
shall report to H & S Head in matrix to employing subcontractor head person. The
details of sub- contractors Party head and designation and name of officers and
stewards as under: -

NAME NAME HEAD OF DESIGNATION NAME OF

SUBCONTRACTOR SUBCONTRACTOR OFFICER/
STEWARD

3.2 Roles and Responsibilities

The overall responsibility of project safety as well about resolving grievances shall be
vested with Country Head. He shall be responsible for:

Resolving all grievances by appointing staff and committee under his leadership and if
necessary, attend the case in person to ensure justice and objectives of GMS

 He shall be responsible on H and S related issues as

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The H&S Plan drawn up during the proposal is followed, developed where necessary and that all
significant health and safety risks are identified, eliminated or minimized.
Planning and scheduling of activities identifies significant health and safety risks and
eliminates or minimizes them.
 Project Health and Safety performance is monitored and reported.
 Only competent contractors and employees are appointed.
 A site manager who is competent to perform the health and safety duties is appointed.
 Contractors conduct Risk Assessments and submit their written safe working methods for
approval before start of work. If this is not possible then the contractors are to be issued
a copy of the
 Method Statements finalized by the KEC management and signed copies of the same are to
be retained in the documents.
 Contractors work in accordance with their written and approved safe working
methods.
 Compliance on Duties and Responsibilities Provisions as per safety codes of ILO, KEC,
IEA, and other such acts as applicable are complied with in respect of all labor at site
whether directly / indirectly employed.
 All the incidents are reported to the Divisional head and Safety Head immediately.
 The safety team is assisted to investigate all incidents.
 All safety rules and regulations are followed at all his work sites.
 Monthly safety meetings are conducted and proper records of the same are maintained.
Details of the safety meeting are mentioned in HS Document
 Risk assessments are carried out at work site and feedback given to the crew working
under his control
 Daily Toolbox Talks are being carried out in his area and proper records of the same are
being maintained.

Project Manager Responsibilities:

In capacity of chairman of grievance committee to resolve the issues brought forward by H and
S Manager or otherwise.
 All aspects of health and safety in his project and accountable to the Country Head. He
must ensure that:
 The Hand S Plan is implemented, monitored, and maintained and that everyone on site
follows the plan’s requirements.
 Unsafe activities are immediately stopped, and safe operations restored.
 Contractors work in accordance with their written and approved safe working
methods.
 There is a defined health and safety site organization for the co-ordination and
authorization of all activities, including daily Toolbox Talks and health and safety
coordination meetings.
 All incidents and near misses are reported, investigated and corrective actions taken.
 Carry out weekly site health and safety inspections / audits and maintain records of the audit

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 H and S Responsibilities:

Discharge the duties to resolve grievance issues register the case and maintain the records.

 Reporting to country Head for providing health, safety and environment advice and
guidance to their Project Managers, Site Managers, Site Engineers, Supervisors,
Contractors, Contractor’s supervisors in the
project.
 Ensure implementation of all instructions on OHS as directed by the KEC
management from time to time.
 Report all the Incidents / Near Misses to the Project Manager and corporate safety dept.
 Conduct investigations in the event of any incident at any site and assist in
investigation of incidents when called upon to do so.
 Interact with all site engineers, contractors, contractor’s supervisors, and workers to
ensure that all safety rules and regulations are followed at all work sites.
 Conduct safety induction for all new Joiners including KEC staff, contractors,
contractor’s staff and workers and maintain proper records of the same.
 Carry out regular site visits and explain the safety rules and safe practices to all
contractors’ staff.
 Ensure proper and effective conduct of the Toolbox Talks daily at the sites.
 Keep a proper record of all Daily Toolbox Talks conducted by all the site engineers / site
supervisors of his project.
 Conduct mock drills for the emergencies identified. A minimum of two mock drills are to be
carried out each month.
 Conduct demonstrations of various activities associated with the type of work at site and
maintain proper record of the same.
 Ensure that adequate PPE as are required are made available at all sites.
 Ensure that all labourers are using proper PPE as are required for the specific task at site.
 Report any issue affecting health, safety and environment at the work site to the
Country Head.
Ensure that all records as are required for audit compliance are maintained.
 Ensure that the basic first aid facilities are available at the sites.
 Ensure that no unsafe act is performed at any site.
 Ensure that any unsafe condition observed at site is eradicated at the earliest.
 Ensure no nuisance is caused to the public in performance of any tasks at any site. He
may issue safety memos in the event of minor safety violations.
 He may issue ‘Stop Work’ in the event of any serious safety violation.

Site Engineer Responsibilities

 The Site Engineer is responsible for all aspects of health and safety on site and
accountable to the Site Manager / Project Manager. He must:
 Carry out labor deployment in consultation with the sub-contractors and ensure that all
laborers are in possession of proper PPE as are required for the specific task at site.
 Carry out day-to-day co-ordination with the erection contractors.

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 Always ensure the quality of job without any compromise on safety.
 Be responsible for safety of all laborers and public at the work sites.
 Report any issue affecting safety, health, and environment at the work site to the Site
Manager / Project Manager immediately.
 Carry out site safety survey and report violations to the Site Manager / Project
Manager immediately.
 Ensure that no child labor is employed by the contractors.
 Carry out Toolbox Talks appropriately to ensure workers are aware of all hazards at the
work site.

3.3 List of Health and Safety Personnel

 The key personnel on Health and Safety are as follows:

HSSE Manager… SAJILAL.AS

4.0 Description of Grievance Management System

4.1 KEC Policy for Grievance Management

An employee/s or the person, who lodges a grievance, will not be prejudiced in his/her
employment with the Company. All grievances should be recorded and resolved at the earliest
possible stage as expeditiously as is practically possible at the point where the grievance
originated. It is line with management’s responsibility to ensure that the grievance procedure is
adhered to. The employee/s shall be entitled to be assisted by a fellow employee in the
grievance procedure.

If the grievance concerns a group of employees or group of local community, the group will
select its employees or representative to act on its behalf.

4.2 Project’s Grievances Mechanism

Procedural Stages

The following participants will be involved at the following stages of the procedure: -

Stage 1: Immediate Direct Report of the aggrieved employee/s

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Stage 2: Direct Report of the person who considered the grievance at the first stage/hearing.

Procedure at Stage 1:

The employee/s concerned should approach his/her/their immediate Direct

Report and verbally convey the grievance. The same may be noted in the grievance register
also.

The grievance should be resolved as soon as practically possible but in any event addressed
within 3 working days from the time after it being raised with the Direct Report.

The grievance related to local community shall be resolved with close consultation and
communication (Grievance meeting) with their representatives.

If the grievance is not resolved or addressed within the period of 3 working days, the
employee/s may

Proceed at Stage-2

The aggrieved employee/s should request a meeting with the Direct Report of his/her /their
immediate superior, indicating the nature of the grievance on aggrievance register form.

The responsible person to whom the grievance is directed shall address the grievances as soon
as is practically possible but in any event, not later than 7working days after being notified of
the grievance.

The responsible person to whom the grievance is directed may address the grievance in writing
or request that a grievance meeting be held. At such a meeting, the following persons may be
present: the employee/s concerned, the employee/s representative and such witnesses as may
be necessary.

The person presiding over the grievance hearing/meeting shall attempt to resolve the
grievance within 5 working days from the date of the grievance meeting.

This is the final stage in the grievance procedure. The decision of the responsible person to
whom the grievance is directed will be final.

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If the grievance remains unresolved after this stage, the employee may invoke procedures
provided for by employment legislation or the common law. The aggrieved employee/s may
only resort to an external dispute resolution mechanism if the Company has failed to resolve
the grievance.

4.3 Grievance Management System Procedures

There are two main Procedural Stages in this GMS: -Stage 1: Immediate Direct Report of the
aggrieved employee/s, and Stage 2: Direct Report of the person who considered the grievance at the first
stage /hearing.

4.3.1 Procedure at Stage 1:

 The employee/s concerned should approach his/her/their immediate Direct supervisor.

 Report and verbally convey the grievance.
 The same may be noted in the grievance register also.
 The grievance should be resolved as soon as practically possible but, in any event, addressed
within 3 working days from the time after it be ingrained with the Direct Report.
 The grievance related to local community shall be resolved with close consultation and
communication (Grievance meeting) with their representatives.
 If the grievance is not resolved or addressed within the period of 3 working days, the
employee/s may proceed to stage 2.

4.3.2 Procedure at Stage 2

 The aggrieved employee/s should request a meeting with the Direct Report of his/her
/Their immediate superior, indicating the nature of the grievance on aggrievance register form.

 The responsible person to whom the grievance is directed shall address the grievances as soon as is
practically possible but, in any event, not later than 7working days after being notified of the grievance.

 The responsible person to whom the grievance is directed may address the grievance in
writing or request that a grievance meeting be held. At such a meeting, the following persons may be
present: the employee/s concerned, the employee/s representative and such witnesses as may be
necessary.

 The person presiding over the grievance hearing/meeting shall attempt to resolve the grievance within
5 working days from the date of the grievance meeting.

 This is the final stage in the grievance procedure. The decision of the responsible person to whom
the grievance is directed will be final.

 If the grievance remains unresolved after this stage, the employee may invoke procedures provided for by
employment legislation or the common law. The aggrieved employee/s may only resort to an external
dispute resolution mechanism if the Company has failed to resolve the grievance.

5.0 Grievance Management System Organization

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 Grievance management system organization is simple structure. First step report shall be made by grievance
lodger to Community and Social and Gender Manager (CSGM). The CSGM shall make efforts to solve the issue
between parties at his/her level- firstly at verbal discussion and if no solution resulted the matter should be
brought to H and S Manager. H and S Manager shall record the case in register and put efforts to resolve at
his/her level however, if not succeeded, the case shall be forwarded to Committee.
The Committee shall have 5 members. GMS Committee shall be Chaired by Project Manager
and Secretary H and S Officer, CSGM and two members from work group one male and one
female. This committee shall resolve the case with mutual understanding between parties. In
case of failure, the case shall be presented to President Ex officio Country Head. The minutes of
GMS meeting (MoM) shall be recorded by secretary and all members shall endorse by their
signature. The copy of MoM shall be made available to parties on demand.

5.1 Workers GMS

The grievances with employed persons about issues related to appointment letter, dismissal
letter, warning letter, disciplinary action, salary wages rate, time of payment, overtime,
provident fund, government taxes and deductions, food allowance if any applicable, pay slips,
attendance, work hours, timing of lunch break, holidays, leave, sick leave, medical facilities and
leave, insurance, gender issues of employment, matter of abuses, sex abuses, providing safe
work environment, instructions of safe work, training on hazards and precautions, providing
personal protective equipment, basic facilities as per labor law on drinking water, toilets and
washrooms, first aid and transportation to work site and return. Apart from above any other
issues as covered under jurisdiction of Burundi labour law acts.

GMS Complaint Box and Notice Board

This box shall be installed at common approach place. If any worker/shave hesitation to come
up with any deviation issue he may put the written note on valid points. This box will be
checked by H&S Manager at month end and any valid points shall be considered to initiate the
action for closing the issues. The notice board of H & S shall display regularly updated H&S
management system. Announcements of better performance and awards shall be displayed on
notice board.

GMS have a “No retribution Policy” for the workers however the management may issue
warnings to defaulters in following safety norms and indiscipline behavior as well misbehavior
with coworkers and others, intoxication on duty, any unethical act like theft etc.

5.2 Public GMS Organization description

GMS Provide opportunity to public for registration of following issues.

Local community grievances issues covered aspects related to land compensation (Delete if
under scope of client), representation in employment to nature of clan and gender, use of
roads, water resources, quarrying, damage to agriculture or vegetation, dust pollution, noise
pollution, incidents caused attributed to project work related activities harming human,
animal or damaging property, discharge of waste material in solid, liquid or garbage status of

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both hazardous and nonhazardous categories. Issues of water resources contamination, soil
erosion and land contamination caused by project related activities. Issues related to prayer
places, graveyards animal grazing zones and any other traditional community owned places.
Disputes on property rental / hiring for project execution cause. Issues related to wildlife

disturbance or hunting and churning of natural resources under public ownership without paying and obtaining
approval of community. Issues on contempt, abuse or sex abuse with local habitats. Any disputes over trading,
sale, and purchases of goods.

CSGM shall bear the responsibility to communicate with recognized authorities at community level within 4
weeks prior to access to site for construction. He shall arrange the meetings with the local authority be face-to-
face and if necessary, H and S officer may accompany him for these kind of meetings.

The public complaints may be considered if projected to Community Relations, Social and Gender Manager
through public authorities like GVH (Cluster Leader) and or VDC but the Police should be the last resort if there is
life threatening incident.

Public cases of GMS shall be handled by CSGM at his/her level. In case the issue is not resolved the case shall be
reported to H and S Manager. He shall register the case and provide solution at his level. However, if the case is
not resolved the 5 Member Committee shall be convened under chairmanship of Project Manager. In case no
solution is obtained, the case shall be presented in front of President Ex Officio Country Head. The minutes of
GMS meeting shall be recorded by secretary and all members shall endorse by their signatures. The copy of MoM
shall be made available to parties on demand.

6.0 Training and Sensitization Meetings

H and S and CSGM shall conduct quarterly training program and sensitization meetings to workers on grievance
redress and encourage use of it if necessary. The process of training needs analysis shall be a three tire:
 Step one fixed and planed programs such as First aid training Mock drill, grievance management system.
 Step two activity relative training decided on base of newly upcoming activity like material
handling, foundation, height work etc. And
 Step three urgent requirements such as learning from incidence/ near miss and any kind of
Evident hazard possibility
 Training needs shall be analyzed by H and S Manager for next month at every closing month day.
 Details of the training schedule.

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 Training calendar shall have marked dates for classroom training and for onsite training.

Induction training shall be imparted in first two weeks of starting the project for all the persons and
further continued for all new joining prior to reporting for work. Induction training shall be
consisting of grievance management system chapter.

 Special training and demos shall be covered by H & S Manger during his site visits on safety and
technical aspects
Care for regular needs of training shall be catered through detailed sheets of TBT prepared by H and S
manager and training departed by site supervisors and engineers

 Few of the training programs shall be conducted by project managers, site managers and engineers. The
training material shall be prepared by H and S Manager, Environment Manager, Community, Social and Gender
Manager shall be conducting training programs on their relevant subjects and topics Providing
sensitization and contents

Referring with training schedule - step two is designed to cater the needs of sensitization.

Sensitization shall have contents related to upcoming activity providing details on related hazards, precautions,
Do’s and Don’ts covering activities like rock blasting, spacer fixing a particular selected section HIRA details shall be
considered, and the listed important points shall reflect in TBT of related activity. Social and environment related
issues and GMS matters
The contents and subjects of toolbox talks are as under:

 Head count / attendance maintenance

 Details of work for the day - Activity

 Safe working procedures / work instructions

 Emphasis of Do’s & Don’ts

 Demonstration of any special application of work / safety if necessary

 Ensure understanding of safety requirements

 Potential safety hazards and the control measures to be followed

 Proper use of PPE

 Visual check of each worker’s health and attend grievance if any

 Health check of PPE

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 Visual inspection of chain pulleys and lifting appliances if being used at site

 Lessons learnt from accidents

 Any other instructions likely to affect safety

 Any other instructions related to social or environmental issues

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and Minutes of Meetings for Grievance Committee for employees and public.
No grievance is considered the better in evaluation and resolved issues are also indicative of
better performance. Number of cases registered and resolved data could be other parameter of
evaluation of GMS performance. The documented record shall indicate the GMS success in keeping
the stipulated time limits to resolve the issues and follow up of registered cases. The grievance
management component shall reflect in the monthly reports of Community Relations, Social and
Gender Manager. Monthly report of Social and Gender Manager shall furnish details on grievance
cases handled in month

7.0 Grievance Management System

7.1 What is a grievance?

Employees/Workers

KEC’s labour force will be categorized into two- permanent and temporary employees. We anticipate that most
grievances for both categories. The grievances with employed persons about issues related to appointment letter,
dismissal letter, warning letter, disciplinary action, salary wages rate, time of payment, overtime, provident fund,
government taxes and deductions, food allowance if any applicable, pay slips, attendance, work hours, timing of
lunch break, holidays, leave, sick leave, medical facilities and leave, insurance, gender issues of employment, matter
of abuses, sex abuses, providing safe work environment, instructions of safe work, training on hazards and
precautions, providing personal protective equipment, basic facilities as per labor law on drinking water, toilets and
washrooms, first aid and transportation to work site and return. Apart from above any other issues as covered under
jurisdiction of Burundi labour law &acts.

7.2 Local community

Local community, KEC anticipates grievances issues related to land compensation, representation in employment to
nature of villagers in a cluster and gender, use of roads, water resources, quarrying, damage to agriculture or
vegetation, dust pollution, noise pollution, incidents caused attributed to project work related activities harming
human, animal or damaging property, discharge of waste material in solid, liquid or garbage status of both
hazardous and nonhazardous categories. Issues of water resources contamination, soil erosion and land
contamination caused by project related

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activities. Issues related to prayer places, graveyards, animal grazing zones and any other traditional community
owned places. Disputes on property rental / hiring for project execution cause. Issues related to wildlife
disturbance or hunting and churning of natural resources under public ownership without paying and obtaining
approval of community. Issues on contempt, abuse, or sex abuse with local. Any disputes over trading, sale, and
purchases of goods.

KEC will attempt to resolve the grievances to both employees and local communities in a manner, which is
acceptable to the community company management by mutual understanding within stipulated time.

7.3 What is Project Level Grievances Mechanism?

7.4 How Does a Grievance Mechanism Benefit Companies and Communities Benefits of the Grievance
Management System?
The tangible benefits accrued from the system are:

 Providing equal opportunity of work irrespective of gender, clan, religion etc.

 Offering respectable life to all workers.
 Maintain confidentiality of workers.
 Ensuring .BURUNDI Government Labor Acts and Law implementation.
 Ensuring KEC HSE Policy and Grievance Policy implementation is adhered to.
 Providing Justice to all workers by fair dealing assurance.
 Resolving any disputes by mutual understanding and to the satisfaction of involved parties.
 Saving staff from court approach and avoiding mental harassment.
 Creating healthy and trust atmosphere between employer and employees.
 Maintain cordial relationship with communities.

GMS provide opportunity to all employees to register below mentioned issues and provide information of any kind
of deviations or bring out to notice the harassment by any person.

8.0 Grievance Management System to Consider:

8.1 Workers Grievance Management System

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8.2 How Should Workers Raise Complaints / Concerns?

KEC will comply with request to implement a grievance management system to enable the workers to raise
complaints and to inform about non-compliances with the implemented Hand Staff Management System. The
grievance management system should provide the possibility as well to issues complaints in case of discrimination
and/or the non-consideration of equal opportunities.
It is KEC open door policy that will accommodate both employees and local communities to freely lodge a complaint
or concern through verbal and or anonymous box to be placed at the Camp site. The grievance management system
shall consider the possibility to directly contact a member of the H&S Staff.
Thus, KEC will accommodate either written or verbal channels of communication in both English or vernacular
language to provide the possibility as well for the workers to notify a complaint or non-compliance in a confidential
way.

8.2.1 Instruction plan to workers how to raise complaints

During trainings, sensitization, and subsequent meetings all employees will be orientated on how to raise
complaints as outlined on the training schedule.
8.2.2 How to Deal with Non-Compliance with Implemented Health and Safety Management System

The contacted staff members must take a note of the reported complaint or non- compliance and must report it to
the site manager and the H and S Manager. The project management or project Hand S Management is requested to
solve the complaint or non-compliance within 3 working days. In case the problem could not be solved an action
procedure specifying the needed activities together with a final deadline until the problem is expected to be solved
must be prepared and submitted to the general manager.

8.2.3 How to Deal with Complaints in Cases of Discrimination

KEC will remind all employees that in the workplace, there no room for any form of discrimination. Any reported
incident will therefore attract punitive disciplinary action on the part of the perpetrator. The warning will highlight
non-acceptance by the company and any resistance will be dealt with human resource management procedures.
8.2.4 Means of Communication

To simplify life to both employees and local communities both formal and informal modes of communication will be
acceptable. However, for records and reporting purposes all incidences will be written and filled.

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 8.2.5 Recording of reported Complaints / Non-Compliance

In line with KEC management policy all reported complaints and grievances and how each complaint was resolved
will be recorded by Hand S manager and the Project manager for references in confidential files.
8.2.6 Investigation of Complaints / Non-Complaints.

Investigation of complaints will be handled with care to avoid jeopardizing the outcomes to both employees and
local communities. In case of the perpetrators on discrimination punitive disciplinary action will commence and be
resolved within the three days.

8.2.7 Closing out Cases within 3 days

The three days target is mandatory to all staff working on grievances unless prior recommendation and priority
sourced from the project general manager in writing explaining the reasons why this mandatory cannot be achieved
on time.

8.2.8 Confidentiality

Unless it is violent grievance in nature and where law enforcement agents will be required to assist resolving the
matter all matters will be treated in confidence/

8.3 Public Grievance Management System

Public GMS Organization description. The public complaints may be considered if projected to Social & Gender
Manager through public authorities like police or Admin

Public cases of GMS shall be handled by Social & Gender Manager at his level in case issue is not resolved the case
shall be reported to H & S Manager. He shall register the case and provide solution at his level however if case is not
resolved the 7 Member Committee shall be appointed under chairmanship of Project Manager. H & S Manager shall
act as Secretory and Social and Gender Manager, Environment Manager, Commercial representative with two
members of working staff one male and one female shall put efforts to resolve the issue. Incase no solution obtain
case shall be presented in front of President Ex Officio Country Head. The minutes of GMS meeting shall be recorded
by secretory, and all members shall endorse the signature. The copy of MoM shall be made available to parties on
demand

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 8.3.1 Reporting Procedure to Local Authorities

8.3.2 Identification of Responsible Authorities at Community Level within 4 weeks prior to access to site for
construction
KEC has already clustered the communities along the project corridors. Each cluster is headed who is Group Village
Head, by the recognized District Council and local government act. This structure has active sub committees headed
by Village Development Committees (VDC). The structures have respected leaders with high level of acceptance and
authority to assist in grievance management.

8.3.3 Involvement of Contractors Health and Safety Representative and Project Implementation Consultant
Health and safety is very body’s responsibility at the work place/site especially for this highly demanding tasks. KEC
has engaged full time H and S Manager who will be responsible for coordinating Healthy and safety issues including
grievances. He will be working in liaison with Sit managers and CSGM and greatly involve other relevant contractors
and consultants.
Involvement of Third Parties where applicable

It is KEC’s open policy to allow natural justice to take effect in grievances and other disputes. Where all efforts by
our designated staff have failed to yield better results to the employees and communities and therefore decides to
engage third parties for litigation, it will be acceptable.
Appropriate protection, transparency and accountability

All grievance lodgers are not in any way treated as enemies but compatriots who need and deserve conducive
environment to to boost productivity of the company, hence the company will accord them with appropriate
protection in the course of grievance and or discrimination.
The designated staff on grievance management and the company as a whole will deal GMS in the most transparent
way possible. We will do this because we are accountable to our employers and the communities we work with. We
protect and highly value our reputation in accordance with business laws and practices.

Monitoring, Evaluation and Report

H and S Manager shall be responsible to Country Head for monitoring and evaluating performance of GMS he shall
maintain the records as Grievance Register

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