A grievance mechanism is a locally based, formalized way for a company to accept, assess, and resolve community complaints related to company activities. It offers a package of widely understood and effective procedures for solving problems that are culturally appropriate, in combination with specially trained personnel, and aims to help parties reach speedy, efficient, and acceptable resolutions with dignity, justice, and finality.

1.    Introduction
1.1.     Overview

The purpose of this document is to define the procedure for managing stakeholder concerns and complaints (referred to as “grievances”) in a planned, timely, and respectful manner.
This grievance mechanism helps PIMK Holding Group JSC (PHG) measure and (if need be) update and improve its:
•    Environmental, Social and Health Impact;
•    Operational Excellence;
•    Legislative and Regulatory Abidance;
•    Human Rights Policy
This grievance mechanism also ensures PHG alignment with international best practices in stakeholder engagement.
A management process to effectively and proactively manage a community’s feedback, grievances or concerns is frequently used to allow communities a chance to have twoway dialogue with a company about its operations. A grievance mechanism can enhance outcomes by giving people satisfaction that their voices are being heard and that their issue was subject to formal consideration within the company.
This grievance mechanism does not impede access to other judicial or administrative remedies that might be available under domestic law or through existing arbitration procedures, or substitute for feedback mechanisms provided through collective agreements.

2.    Objectives and Scope
2.1.    Objectives

The objectives of the grievance mechanism are to:
•    Provide accessible avenues for all external stakeholders to contact PHG;
•    Provide a mechanism for stakeholder concerns to be addressed effectively, in a timely manner and by the most appropriate department;
•    Identify and monitor stakeholder concerns to support effective stakeholder and risk management;
•    Enhance PHG’s reputation as a transparent company and a leader.

2.2.    Scope

The grievance mechanism will manage grievances from external stakeholders internationally. It applies to all grievances that arise as a consequence of any PHG activity. This Process is designed to provide a system for managing grievance from the general public, and does not replace existing employee grievance systems, normal business-to-business dialogue, or other management procedures already in place.
There are no restrictions on the type of issue a stakeholder can raise under this procedure. However, when a complaint is received that would be more appropriately handled under a separate company process established for that purpose (such as employment or business integrity related issues), it will be re-directed so as to prevent parallel processes being followed. All complaints received under this procedure shall be tracked until close out, regardless of the process under which they are handled.
Company reserves the right not to address a complaint which it reasonably considers amounts to no more than general, unspecified, and therefore un-actionable dissatisfaction with the company, is otherwise malicious in nature, or concerns a matter for which the company has no formal responsibility (for example, a matter that the government controls).

2.3.    Confidentiality

The personal details of Complainants should only be made available to those involved in the resolution of the grievance in question.
PHG will accept, log, and seek to address grievances contained in anonymous grievance forms, but, due to the anonymous source of the grievance, will not be able to respond directly to the Complainant.

3.    Grievance Mechanism Process

PHG has appointed a team of well-prepared specialists to handle any reasonable complaint which may be administered under the grievance mechanism. Complaints will be administered by providing resources to handle correspondence, coordinate internal resolutions, manage a log, and report (both internally and externally).

3.1.    Grievance Mechanism Process

The key tasks in implementing the grievance mechanism are summarized in Figure 1 and elaborated below.

3.1.1.    Receive and Register Grievance

3.1.1.1.    Methods for Receiving Grievances Stakeholders can submit grievances through a number of methods, including:

•    Via post: To PHG Grievance Officer at the following address:
4008 Plovdiv, Bulgaria
36 Rogoshko Shose
PIMK Holding Group JSC
Attn: Kalina Kiskinova  
•    Email: through e-mail address: [email protected]

PHG is responsible to ensure that any personnel and contractors that could potentially receive claims will be knowledgeable about the grievance mechanism process and ready to accept feedback. PHG will stress that there will be no costs or retribution associated with lodging grievances.

3.1.1.2.    Registering Grievances

Grievances will be logged in the Grievance Register within three business days of receiving the grievance. A grievance owner will be assigned to each grievance when they are logged. The grievance owner may delegate responsibilities to other staff, but is ultimately responsible for:
•    Defining and implementing resolution actions;
•    Investigating the grievance;
•    Consulting relevant departments or persons within the organization;
•    Making sure resolution actions are completed;
•    Tracking progress of individual grievances;
•    Aggregating and forwarding feedback to Complainants;
•    Documenting resolution actions;
•    Gaining necessary approvals from, and reporting to, management.
While no response is necessary for anonymous grievances, these will be logged and reported with other grievances to facilitate continuous improvement.

3.1.2.    Acknowledge Grievance

The Grievance Officer will formally acknowledge grievance within 5 working days of the submission of the grievance, informing the Complainant that PHG’s objective is to respond within 20 working days. Written feedback will be provided so that a record of correspondence is retained and recorded.
Acknowledgement should include a summary of the grievance, PHG’s approach to responding to the grievance, and an estimated timeframe in which the final response will be issued.
If grievance is considered out-of-scope for the grievance mechanism (please advise section 3.2.3 on Screening), the Grievance Officer should draft a response explaining why it is out-of-scope and providing any guidance of where to go to get the issue addressed (if possible).

3.1.3.    Screen Each grievance will be screened from Level 1 to 3, per definitions provided in Table 1, in order to determine the appropriate response.

Chevron Myanmar Grievance Mechanism Procedure

Table 1: Grievance Screening Categories Category Issue Description Issue Type Management Approach

Category Issue Description Issue Type Management Approach
Level 1 A grievance for which there is already a PHG managementapproved response and an answer can be provided immediately. This level also includes grievances that are out of scope.

 

 

 

 

 

Routine

Inform PHG management and then utilize approved answers to handle response.
Level 2

 

Grievances characterized by being a one-time situation, local in nature, and that will not impact PHG’s reputation. Define grievance response plan and draft a response for PHG and other management approval.
Level 3 Repeated, widespread or high-profile grievances that may result in a negative impact on PHG’s business activities and/or reputation. Level 3 grievances indicate a gap in a management plan or procedure, or that a serious breach in PHG policies or (inter)national law has occurred. Potentially significant Prioritize through Issues Management/Legislative and Regulatory Advocacy Process and define appropriate management strategy

3.1.4.    Investigate

The Grievance Owner will lead grievance investigation, when needed, which could include collecting relevant documents, making site visits, consulting appropriate internal staff, contacting external stakeholders, and other activities. Investigation findings will be used to document decision making process and inform proposed remedy.

3.1.5.    Respond

Response will be granted according to the above-defined rules in 3.2.2

3.1.6.    Follow-up and Close Out

If the Complainant accepts the proposed resolution, the agreed actions are implemented.
The Complaint Owner is responsible for assigning action parties, actions, and deadlines to implement the resolution.
After resolution, the grievance should be formally closed out. This includes requesting the Complainant sign a completion form to document satisfaction with resolution actions, documenting actions taken, and closing out in the Grievance Register.

3.1.7.    Appeal

In cases where a Complainant is unsatisfied with and/or unwilling to accept the resolution actions proposed, the grievance may be resend with the specific note that a prior decision is being appealed. The procedures which follow mirror the once already listed with the exception that further investigation may be conducted. Any appeal may or may not be honored depending on the reasons previously given for the initial resolution of the grievance.