Grievance Policy

The project provides multiple culturally appropriate methods for submitting a grievance using a form accessible on its stakeholder’s web page, with options for a self-identified, confidential, or anonymous submission. Through the public consultation process, the project ensures that all stakeholders are made aware of which is publicly available and will designate a central point of contact to compile all letters received.

• A grievance is defined as a written complaint about any action that results in perceived unfairness or wrongdoing toward one or more local stakeholders. Unless otherwise indicated in writing, routine correspondences, negotiated legal documents and legal notices do not constitute formal grievances.

• Where grievances are filed as confidential or anonymous, the stakeholders’ contact information will be withheld from public disclosure.

• All grievances received will be publicly available on the project’s proponent’s website after submission, and the complainant will receive confirmation of receipt if contact information is available.

• Any written complaint will be screened and evaluated for eligibility if it has standing with the project. The written complaint will be deemed non-grievance and ineligible for treatment under this procedure if it does not meet the definition of a grievance, is not project-related, the complainant has no standing to file, or is not submitted by a local stakeholder.

• If another company or community procedures are more appropriate to address the issue, the complainant will be referred to as appropriate. The project will classify the grievance as minor or major and one-time or repetitive to inform the approach to resolution.

• Once a grievance has been received and screened, the project proponent will attempt to resolve the grievance following stages approach:
  • The project proponent will attempt to amicably resolve the grievance and provide a written response to the grievance in a manner that is culturally appropriate.
  • Following classification and evaluation, a project representative will formulate a response and select the most appropriate local resolution approach. There are several different local approaches that can be implemented to resolve the grievance (CAO 2008):
    • Internal decision-making process: The project develops and proposes a solution in response to the grievance and allows an appeals process.
    • Joint problem solving: The project and stakeholder work together to develop a solution acceptable to both parties.
    • If there are any grievances received that cannot be resolved internally or via amicable negotiation, then the grievance shall be referred to the Consensus Building Institute for third-party mediation (https://www.cbi.org/).

• Once the project representative and stakeholder agree to a proposed solution, the project will implement the approach in a timely manner and periodically check in with the complainant to ensure satisfaction. The project will also develop performance metrics (when applicable) to track progress, review feedback, and refine the solution.

• Post-implementation, the project representative will review resolution metrics to see if targets are being met. The project proponent will also communicate the results of the metrics with the stakeholder and the general public via email and the project ‘s website. To evaluate success, the project will ask the following questions (CAO 2008):
  • How well is the solution accomplishing its purpose and goals?
  • Is the system making a difference?
  • What actions would increase effectiveness?

• The project will make modifications to the proposed solution or develop a new solution based on several local approaches until the grievance is resolved.

• When the grievance is resolved, the project will post the resolution and results on the website for public accessibility and exhibit steps taken to avoid similar feedback in the future.
•  Finally, if the mediation does not resolve the grievance, it shall be referred to the appropriate, competent jurisdiction within the United States of America Court System without prejudice to a party’s ability to submit the grievance to a competent supranational adjudicatory body, if any.