worker grievance mechanisms - ipieca

Worker grievance mechanisms Guidance document for the oil and gas industry

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Advancing environmentaland social performanceacross oil and gas

www.ipieca.org

LABOUR RIGHTS SERIES

Guidance 3

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consent of IPIECA.

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(centre) Nick Eyes/Shutterstock.com; (bottom right) Noomcpk/Shutterstock.com.

This publication has been developed to support the implementation of IPIECA’s mission and vision. Whileevery effort has been made to ensure the accuracy of the information, it is intended to provide generalguidance only. It is not designed to provide legal or other advice, nor should it be relied upon as asubstitute for appropriate technical expertise or professional advice. All attempts have been made toensure that the information is correct at the date of publication. This publication does not constitute amandatory commitment which members of IPIECA are obliged to adopt. The views and conclusionsexpressed herein do not necessarily reflect the views of all IPIECA members or the individuals, companiesand institutions that contributed to this publication.

While reasonable precautions have been taken to ensure that the information contained in thispublication is accurate and timely, this publication is distributed without warranty of any kind, express orimplied. IPIECA neither endorses nor accepts responsibility for the content or availability of any websitereferred to, or linked to, in this publication. The responsibility for the interpretation and use of thispublication lies with the user and in no event will IPIECA or any of its members past, present or futureregardless of their negligence, assume liability for any foreseeable or unforeseeable use made thereof,which liability is hereby excluded. Consequently, such use is at the recipient’s own risk on the basis thatany use by the recipient constitutes agreement to the terms of this disclaimer. This disclaimer should beconstrued in accordance with English law.

Acknowledgements

Special thanks go to the practitioners from the IPIECA membership, and to the various externalstakeholders, all of whom generously contributed their time, experiences and expertise to the preparationof this guidance.

Worker grievance mechanisms Guidance document for the oil and gas industry

14th Floor, City Tower, 40 Basinghall Street, London EC2V 5DE, United Kingdom

Telephone: +44 (0)20 7633 2388 E-mail: [email protected] Website: www.ipieca.org

2 — Worker grievance mechanisms

Background 3

Introduction 4

Understanding worker grievances 5

What is a grievance? 6

What is a worker grievance mechanism? 6

Is a worker grievance mechanism the same as 6a community grievance mechanism?

Why a company should have a good 7grievance mechanism

Grievance mechanism standards 7

Overcoming common challenges 8

Entry points to worker grievance mechanisms 9

Trade unions and labour forums 10

Company hotlines 10

‘Worker voice’ apps 10

External reports and allegations 11

Review and planning 13

Handling a worker grievance 17

Overview of the grievance mechanism procedure 18

Handling a grievance 18

Handling anonymous complaints 21

Complaints from workers employed by third parties 23

Evaluating effectiveness of contractor 24worker grievance mechanisms

Receiving third-party grievances 25

Appendices 27

Appendix 1: Worker grievance mechanism 28effectiveness criteria

Appendix 2: Reviewing worker grievance mechanisms 30

Appendix 3: Template site-level grievance policy 31 and procedure for contractors

Glossary of terms 33

Contents


This guidance document is one component of a series ofpractical guidance and tools which constitute part ofIPIECA’s Company and Supply Chain Labour Rights Project.

Company and supply chain labour rights issues arecomplex and multifaceted, covering, for example, forcedlabour and human trafficking, freedom of movement,worker grievance mechanisms, supplier andsubcontractor management, working hours and pay,health and safety and welfare principles, etc. There isstrong interest from external stakeholders such asgovernments, non-governmental organizations (NGOs),the media and investors, in knowing more about whatcompanies are doing in this area, as well as an evolvingregulatory context.

The Company and Supply Chain Labour Rights Project ispart of IPIECA’s broader Business and Human RightsProject and focuses on the contracted workforce that theoil and gas industry relies on to develop and conductlarge-scale operations. It addresses the potential humanrights impacts and issues that may occur throughbusiness relationships, particularly in the industry supplychain. The project aims to:

l enable the industry to more effectively identify,prevent and mitigate labour rights risks and impactswithin projects, operations and supply chains;

l inform stakeholders of the industry’s collectivecommitment and efforts to respect labour rights; and

l support the industry in anticipating emerging trendsand challenges.

The initial focus has been on the construction of largeprojects in sensitive geographies with vulnerableworkforces, in particular with respect to the rights of thesite-based workforce, i.e. those employed by contractorsand their subcontractors.

This phase of the project includes publication of thefollowing complementary guidance and tools:

l Responsible recruitment and employment:a guidance document covering considerations onresponsible recruitment and employment in the oiland gas industry. The document outlines key labourrights issues to be addressed during a project lifecycle, and identifies risks, emerging good practice andconsiderations for effective management.

l Labour rights assessment:guidance on the design and implementation of anon-site labour rights assessment, outlining approachesfor conducting an on-site audit and assessment ofcontractors following contract commencement. Thedocument also provides examples from oil and gascompanies and other industries.

l Worker grievance mechanisms (this document):guidance on developing and implementingeffective worker grievance mechanisms acrossoil and gas workplaces and project sites. Thedocument provides examples of good practicesfrom IPIECA members and other industries, thathave enabled workers to speak up and havetheir concerns acknowledged and addressed.

l Key steps for carrying out an on-site labour rightsassessment: a quick reference tool based on thecomprehensive Labour rights assessment guidancedocument and Labour rights assessment toolkit.

l Labour rights assessment toolkit:a detailed set of tools for comprehensive on-sitelabour rights assessments (Microsoft™ Excel®

spreadsheet format).

The complete set of guidance documents and tools canbe downloaded from the IPIECA website athttp://www.ipieca.org/resources/good-practice/company-and-supply-chain-labour-rights-guidance/

Background

http://www.ipieca.org/resources/good-practice/company-and-supply-chain-labour-rights-guidance/


This guidance provides readers with support indeveloping and implementing effective worker grievancemechanisms across their workplaces and project sites.

This guidance is aimed at practitioners who play a role inmanaging worker grievances at oil and gas project sites.Users of the guidance may include project directors,human resource (HR) managers, employee/industrialrelations staff, administrative staff, health, safety, securityand environment (HSSE) managers and otherprofessionals with responsibility for labour issues who areemployed by oil and gas companies or their contractors.

This guidance provides the reader with an overview ofthe key principles of managing worker grievances. It alsoprovides recommendations on how to design andimplement an effective mechanism for dealing withgrievances raised by directly-employed workers andthird-party workers.

Introduction


Section 1

Understanding workergrievances

This section sets out the context for themore detailed guidance that follows. Itexplains the need for effective workergrievance mechanisms, and provides detailsof common challenges that companies facewhen dealing with worker grievances.

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WHAT IS A GRIEVANCE?

For the purposes of this guidance, a grievance canbroadly refer to an allegation, issue, or problem that aperson has raised in relation to his/her treatment orexperience at work. This can cover a broad range ofconcerns, ranging from a complaint about canteen foodand work schedules, to more serious issues such asharassment and workplace discrimination.

Depending on the specific context, grievances may alsobe referred to as complaints, feedback or concerns.Companies should think about the most appropriateterm, and choose the one that is best suited to theircircumstances, and which will be understood andaccepted by employees and managers.

WHAT IS A WORKER GRIEVANCE MECHANISM?

A worker grievance mechanism (WGM) is a procedurethrough which a grievance can be raised, assessed,investigated and responded to. It is also a frameworkthrough which workers can gain access to remedy foradverse impacts or damage they have suffered as a resultof business activities. However, for a grievancemechanism to be effective in managing workergrievances, it must meet the effectiveness criteriasummarized in Box 1. For a more detailed breakdown ofeffectiveness criteria see Appendix 1.

IS A WORKER GRIEVANCE MECHANISM THESAME AS A COMMUNITY GRIEVANCEMECHANISM?

The principles of an effective community grievancemechanism (CGM) and that of an effective WGM are thesame, and indeed, in some contexts a CGM can beeffective in picking up on workplace issues and givingworkers a mechanism through which they can addressissues on a worksite.

However, a CGM is not typically designed in such a wayas to pick up on issues on a worksite, for example, wherethere are a large number of subcontractor workers ormigrant workers who are not from the community.Furthermore, a CGM will not normally provide the levelsof worker engagement or integration with HR systemsthat are required to effectively manage workergrievances. There will, nevertheless, be some degree offluidity between a CGM and a WGM because an issuemay sometimes fall between a workplace andcommunity issue, and may change over time.

Section 1

Undertanding worker grievances

Box 1 Worker grievance mechanism effectiveness criteria

For a WGM to be effective, it should be:l legitimate;l accessible;l predictable;l equitable;l transparent;l rights-compatible;l a source of continuous learning; andl based on engagement and dialogue with existing

stakeholders.

Further reading

IPIECA’s manual, Community grievancemechanisms in the oil and gas industry, givesmore detailed information on CGM design andimplementation.

http://www.ipieca.org/resources/good-practice/community-grievance-mechanisms-in-the-oil-and-gas-industry/

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WHY A COMPANY SHOULD HAVE A GOODGRIEVANCE MECHANISM

Engaging with workers and communities and respondingto their concerns is essential for the successful operationof any business. Figure 1 summarizes the benefits of aneffective grievance mechanism.

GRIEVANCE MECHANISM STANDARDS

Key sources of information for guidance on grievancemechanism standards include the following:

l The United Nations Guiding Principles on Businessand Human Rights (UNGPs)The UNGPs set out expectations of how a businessshould receive and handle a grievance to remediateany actual harm. The principles set out under theUNGPs for an effective grievance mechanism arewidely recognized as being international good practice.

l Investor/lender standardsWhere oil and gas projects receive project financingor are financed through export credit guarantees,companies may be required to comply with therequirements of IFC Performance Standard 2 (IFC PS2)which covers labour and working conditions, andincludes provisions on worker grievance mechanisms.IFC PS2 criteria are aligned with the UNGPs.

l National legislationIt is rare that national legislation will require anemployer to establish a WGM. However, there maysometimes be ways in which national law encouragesthe establishment of WGMs, for example by requiringemployers to set out in employment contracts howemployees can lodge grievances.

Section 1Understanding worker grievances

Further reading

Verité has developed useful guidance forcompanies wishing to establish effective workergrievance mechanisms for vulnerable workforces.

Figure 1 The benefits of an effective grievance mechanism

https://www.ohchr.org/Documents/Publications/GuidingPrinciplesBusinessHR_EN.pdf

https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at-ifc/policies-standards/performance-standards/ps2

http://helpwanted.verite.org/helpwanted/toolkit/suppliers/establishing-effective-grievance-mechanisms


OVERCOMING COMMON CHALLENGES

Table 1 sets out some of the common challengescompanies face in relation to handling workergrievances, along with some considerations to helpovercome them.

Another key challenge for companies to consider is howto approach the handling of anonymous complaints fromworkers. For more information on this topic see page 21.

Section 1Understanding worker grievances

Table 1 Handling worker grievances—the challenges and how to overcome them

OVERCOMINGBARRIERS TO ACCESS

ENSURING THAT THIRD-PARTYWGMS ARE EFFECTIVE

BUILDING TRUST WITH WORKERS

l Allow workers to raise grievances intheir own language.

l Reflect other socio-culturalconcerns related to vulnerableworkers (this could include, but isnot limited to, female workers,migrants, illiterate workers, youngworkers, etc.).

l Allow workers to raise concernsanonymously (although note thatthis restricts ability to responddirectly).

l Reinforce the policy ofconfidentiality and non-retribution,along with ability to raiseanonymous grievances, duringinductions to the site and othertrainings.

l Reduce physical barriers toaccessing the mechanism bylocating in places that workers feelcomfortable visiting or by receivinggrievances by phone, message, etc.

l Review third-party capacities andsystems to implement an effectiveWGM.

l Include specific clauses in contractswith third parties addressingspecific gaps identified in theirsystems and practices.

l Require that third-party WGMs areimplemented in line with theeffectiveness criteria (see Box 1 onpage 6 and Appendix 1 on pages28–29).

l Require third parties to report ongrievances raised, and outcomes, atregular intervals. Reserve the rightto monitor the third party’s WGMand outcomes.

l Where there are clear gaps, buildcapacities of third-partymanagement staff involved ingrievance handling.

l Regularly communicate to workersthe availability of the mechanismand how to use it.

l Have a regular presence on aworksite that all workers (includingthird-parties) know they canapproach to raise concerns (similarto the role of a Community LiaisonOfficer in a community).

l Place posters across the project site(and other areas frequented byworkers) which include WGM point-of-contact details. Includeinformation on performance of themechanism.

l Provide timely feedback to workersabout grievances raised and theresponses of the company.

l Consider engaging a trusted thirdparty to receive complaints andmanage communications withworkers.

Further reading

The Compliance Advisory Ombudsmen hasdeveloped a number of tools to help enhanceexisting grievance mechanisms and create newmechanisms in line with international bestpractice.

https://www.cao-grm.org/tools-and-resources


Section 2

Entry points to workergrievance mechanisms

This section looks at the various means bywhich a worker grievance may be raised.

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The most conventional, company-controlled routes forworkers to raise grievances on a worksite are directcontact with HR management or written notes incomplaints boxes. However, various other means areavailable to provide workers with the ability to raiseconcerns, as set out below.

TRADE UNIONS AND LABOUR FORUMS

Site level agreements

Where a trade union is present at the workplace andthere is a collective bargaining or labour agreementbetween the company and the union, grievanceprocedures will often be referenced in collectiveagreements. When functioning properly, this can be aneffective means of providing a grievance process andremedy to workers. Site-level collective agreements canestablish a means for individual workers to raise anemployment-related grievance, potentially through thetrade union or with trade union assistance.

Where such agreements and mechanisms are in placethere may be less need for a company to supplementthis with an additional internal procedure, as long as themechanism provided through the collective agreement:

l accommodates individual grievances;

l is accessible for all workers on the site, regardless oftrade union membership; and

l is accessible to vulnerable workers, and others suchas agency workers, contractors, etc.

If this is not the case, supplementary grievance routesare recommended.

However, in many jurisdictions there may be restrictions ontrade union rights or low levels of trade union membership.In such cases, alternative means of raising grievances willbe necessary. One option in these circumstances can befor companies to engage with labour forums or workercommittees. These can provide a company with a useful,non-adversarial means of consulting with the widerworkforce on issues related to the workplace, and allowindividuals to raise particular concerns.

Global framework agreements

Some companies have also chosen to enter into GlobalFramework Agreements (GFAs) with Global UnionFederations. These GFAs will usually contain provisionsfor the joint investigation and resolution of complaintsand disputes related to the agreement, and for regulardialogue on labour issues between the company and theunion. Two examples of GFAs signed by oil and gascompanies include those that Eni and Total have signedwith the Global Union Federation IndustriALL.

COMPANY HOTLINES

Worker hotlines are a common entry point for workers toraise grievances in the oil and gas sector. Mostcompanies will have specific telephone numbers and/oremail addresses that complainants can use to raise anyconcerns related to their working conditions. These willoften be operated at a global level rather than by aspecific project site’s management, but they can also bedeveloped for the needs of a specific project, or in aspecific geography where companies may have multipleprojects.

Some companies also choose to use an independent thirdparty to operate hotlines and to act as an intermediarybetween the complainant and the company. If this route ischosen, providers need to be selected on the basis of arange of issues, including their experience, ability to dealwith sensitive issues, their systems for protectingconfidential information, and their response times.

‘WORKER VOICE’ APPS

An alternative, additional resource for the receipt ofworker complaints may be available online throughtechnology-based applications and other digitalchannels. In a world where most workers have access tothe internet through mobile phones and computers—and where companies have large supply chains andoperations across the world—it makes sense to try toharness the technology to give a larger number ofworkers an additional entry point to raise workplaceconcerns.

Section 2

Entry points to worker grievance mechanisms

https://www.eni.com/docs/en_IT/enicom/sustainability/GFA_ENG.pdf

https://www.total.com/sites/default/files/atoms/files/total_global_agreement_va.pdf


Many companies are beginning to think about how theycan use technology-driven platforms to betterunderstand worker sentiment across their businessactivities. Such an approach can provide companies withimproved opportunities for identifying and remedyingnegative impacts on workers.

To meet this growing demand, an increasing number ofapplications and platforms are becoming available forcompanies to use. However, their use is still relativelynascent, and companies are still exploring how best toimplement them and harness their potential as tools forrunning an effective grievance mechanism. In responseto a number of identified issues and a growing number ofservice providers, a set of common guidelines known asthe WEST Principles have been developed to helptechnology provide a meaningful and positive impact onworkers’ lives. These guidelines consist of eight principlesthat companies should consider when thinking aboutwhich applications could be useful; these principles arebroadly aligned with the effectiveness criteria for WGMsas set out in the UNGPs.

One example of an application to enable workerreporting is the ‘Worker Connect’ mobile app, whichoffers foreign migrant construction workers employed inGulf countries a means of raising anonymous complaintsabout how they were recruited and are employed andhoused. The app supports multiple languages andprovides the company with a communications tool thatcan be used to respond directly to complainants, as wellas to the wider workforce about broader issues anddevelopments.

If companies are using, or thinking about using, suchapplications, it is important to evaluate whether theyadhere to the WEST Principles and meet theeffectiveness criteria set out in Appendix 1 on pages28–29.

It is also important to note that, although thesetechnology-based mechanisms are aimed at enhancingthe ‘worker voice’, they should not be seen as equivalentto, or replacements for either:

a) the role of legitimate trade unions that represent theinterests of their members; or

b) a manager or other on-site liaison that is responsiblefor acting as a point of contact.

EXTERNAL REPORTS AND ALLEGATIONS

Some WGMs allow for grievances to be raised through anexternal party and to be received by a person other thana worker or their representative. This could, for example,include allegations made in the press or in reports fromNGOs. Additionally, in countries with a large number ofmigrant workers, allegations or information about poortreatment may be brought to a company by a labourattaché in the diplomatic representative body of acountry where migrant workers are employed.

When a WGM includes these avenues for raisinggrievances, it is important that the grievances areassessed, investigated and responded to in the samemanner that they would have been if they had beenraised directly by the affected workers.

For example, Wilmar International—a leading globalagribusiness group—have a Grievance Unit that is taskedwith managing grievances raised directly by workers, butalso those raised by third parties. The Unit is tasked withmonitoring media for news related to Wilmar and itssuppliers to identify potential grievances which will thenbe investigated in the same manner as other grievances.

Section 2Entry points to worker grievance mechanisms

Further reading

ACCESS has created a database of differentcompany grievance mechanisms. This includesboth WGMs and CGMs in the extractives sector andgives an overview of their scope and how they work.

https://westprinciples.org/start-with-integrity-and-purpose/

https://www.workerconnect.org/

http://www.wilmar-international.com/sustainability/wp-content/uploads/2017/03/Grievance-Procedure-Updated.pdf

http://accessfacility.org/mechanisms/all?keys=&field_mechanism_industry_tid=4&field_mechanism_type_tid=35

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Section 3

Review and planning

This section sets out the activities thatcompanies should consider when designingan effective worker grievance mechanism.

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Table 2 on page 15 sets out the activities that companiesshould consider when designing an effective WGM. Notethat while these activities are presented sequentially,they include overlapping activities.

While this provides a broad overview of the steps to takewhen planning and designing a WGM, many of theactivities are similar to those required when developing aCGM. For more a more detailed overview of theseactivities, refer to the IPIECA manual, Communitygrievance mechanisms in the oil and gas industry.

Section 3

Review and planning

http://www.ipieca.org/resources/good-practice/community-grievance-mechanisms-in-the-oil-and-gas-industry/


Section 3Review and planning

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Section 4

Handling a workergrievance

This section offers step-by-step guidanceon managing worker grievances. Details ofhow to handle anonymous complaints arealso included.

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OVERVIEW OF THE GRIEVANCE MECHANISM PROCEDURE

Figure 2 gives an overview of the different channelsthrough which grievances may be raised, along with theoverarching steps that may be needed to resolve thegrievance.

More details on the considerations that need to be givento each of these steps are provided under Handling agrievance, below.

HANDLING A GRIEVANCE

Figure 3 on page 18 sets out the considerations thatcompanies may take into account at the different stagesof handling a grievance. While acknowledging thatcompanies will have different processes for handlingworker grievances, Figure 3 sets out the key activities thatshould be considered for any grievance to be handledeffectively. Some of these considerations may be differentin cases where a grievance is raised anonymously (seepage 21 for further information). Key to designing andoperating a system is that the worker should be able tochoose which approach he or she feels happiest with.

Section 4

Handling a worker grievance

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Section 4Handling a worker grievance

Figure 3 The different stages of handling a grievance

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If workers have a grievance or complaint regarding their work,they should, wherever possible, raise their concern with asupervisor or manager as it may be possible to find a solutioninformally. This makes it more likely that disputes can beresolved quickly, closer to the source of the problem, making itless likely that the issue escalates into an intractable problem.The issue and response should still be logged and trackedfrom the perspectives of checking outcomes and monitoring.

If discussions with supervisors/managers fail to resolve theissue, it is still possible to pursue an informal approach withouttriggering a formal procedure. For example, a further optionwould be for the HR manager to facilitate an informal meetingor discussion about the grievance. Any such options takenshould be logged.

If the matter is serious and/or the worker wishes to raise thematter formally, the worker should set out the facts of thegrievance in writing to the nominated manager under themechanism.

If there is a trade union at the workplace, the worker may wishto ask a union representative for advice and support.

Once a grievance has been raised, the company shouldprovide an acknowledgement to the complainant that it is inreceipt of the details. An early assessment of the complaintshould identify the key issues that have been raised, togetherwith any root causes, and should determine the outcome thatthe worker is looking for from the process. Any additionalinformation should be gathered to allow a full assessment.

As part of this process, managers will need to determine theappropriate next steps. A key consideration will be whether ornot the grievance raised falls within the scope of themechanism. If it does not, the management may choose notto proceed further with the investigation as there may beother more appropriate means of handling the complaint, forexample if a case of forced labour is alleged, it is usually betterto refer the complaint to relevant authorities or experts.

The appropriate form of investigation will depend on the typeof grievance and the seriousness of the allegation. In generalterms, managers handling grievances should try to understandthe key issues and interview the individuals involved in acomplaint, e.g. those managing the workers, or thoseresponsible for the activity or service that is raised in thegrievance.

If the grievance is substantiated, a designated manager willinvite the worker to a meeting, within a determined periodafter receiving the complaint, to discuss the worker’sgrievance.

Ideally, raising a formal grievance should be alast resort. If a company is implementing goodHR management practices where there are clearavenues of communication betweenmanagement and workers, it should be able tohandle most issues in an informal manner.

However, informal arrangements andprocedures should not be made a pre-requisitefor commencing more formal complaints. Forexample, it may be that the complainant has acomplaint about the behaviour of his/her ownsupervisor or manager, in which case it wouldnot be appropriate for the complainant to raisethe matter informally with that person.

Where a worker has a grievance against his/hersupervisor or manager who is also the nominatedcontact for reporting grievances under themechanism, it would not be appropriate for theworker to raise the complaint with that person. In sucha case, the worker should raise the grievance throughanother entry point. See the examples in Section 2.

If there is potential for disciplinary proceedings tobe started against another worker or manager asa result of the grievance, it may be appropriate tosuspend the grievance procedure.

Where there are allegations of harassment ordiscrimination, or other particularly sensitive issues,the manager involved should handle these issueswith care and sensitivity; this may require specialtraining and protocols. It may be that anindependent investigation is required, requiringexternal expert input.

The worker should have the right to be accompaniedby a colleague or trade union representative at themeeting upon request. After the meeting thegrievance manager will give the worker a decisionin writing, within a determined period.

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Box 2 Communication and appeals

Companies should always acknowledge receipt of agrievance at the outset, and should aim to provideworkers with regular updates on the progress of theirgrievance. This information should be sufficiently clearto allow the worker to understand the reasons behind alldecisions taken at each stage. When a final decision ismade, companies should also set out what a worker cando if they disagree with the decision and wish to appeal.

If the worker is particularly unhappy with the decision inrelation to his or her grievance and wishes to appeal, heor she should notify the grievance manager. Theworker should be invited to an appeal meeting within adefined period of time, and the appeal will be heard bya more senior manager. Some companies establish anappeals committee, which operates independentlyfrom company management, to fulfil the functions ofhearing an appeal, deciding on the outcomes,undertaking mediation and finding a resolution. Everyeffort should be made to secure a resolution that is inthe best interests of the worker(s) and the company.After the appeal meeting, the senior manager/committee will give the worker a decision in writing.

Box 3 Understanding the root causes of an issue

If a company wants to address an issue and preventfuture complaints about the same issue, it is critical thatthe root causes of the issue are understood. Simplytaking the complaint at face value may not actually leadto a resolution of the underlying factors that arecausing the problem. For individual complaints—orwhere there are particular trends in types ofcomplaint—time should be taken to analyse thecomplaint and the situation in which it has been raised.

Further reading

The International Code of Conduct Association (ICoCA) has developed a manual that companies can use tohelp them develop an effective grievance mechanism. This also includes guidance on how to operate themechanism, along with details of the different activities that should be carried out at different stages of thegrievance process.

https://www.icoca.ch/en/guidance



HANDLING ANONYMOUS COMPLAINTS

Companies should provide a means by which all workersare able to raise anonymous complaints. This gives themost vulnerable workers confidence that they will not beretaliated against for raising concerns, and can befundamental to shifting power dynamics in theworkplace.

However, the normal practice a company takes wheninvestigating a complaint—i.e. meeting with the affectedworker and responding to them directly—may not bepossible when anonymous grievances are raised. Thiscan make it harder for a company to verify whether thecomplaint is genuine, but more importantly it is alsodifficult to ensure that the outcomes are satisfactory forthe affected worker.

It is important to maintain anonymity, unless disclosure isrequired by law. Efforts should be made to protect thesource from retaliation, in collaboration with nationalauthorities or experts (where authority involvementcould lead to retaliation or retribution against theworker).

It may be appropriate for anonymous complaints to behandled by independent third parties, which allows forthe complainant’s confidentiality to be maintained.

Alternatively, where a worker is willing to disclose his/heridentity to individuals within the company that are notclosely associated or affiliated with the accused parties—for example a committee at headquarters—thecompany can engage directly with the worker duringinvestigations without disclosing anyone’s identity tothose being accused.

Box 4 Responses to receiving an anonymousgrievance

Where a worker wishes to remain completelyanonymous, and no independent third party is actingon behalf of the affected worker, the company is ableto do much less to investigate the specific issue(especially if there is a lack of information) and respondto the complainant directly. Nonetheless, there aresome useful approaches that can be taken that canenable a company to investigate, demonstrate thatthey are acting, and potentially prevent further harmwhile maintaining the anonymity of the worker.

Examples of actions that the company can take:

l Launching a broad campaign about appropriateworkplace behaviours, providing some focus on theissue that was raised and on the area from whichthe complaint was generated.

l If there are a number of reports against the sameperson or workplace practice, the company caninstigate its own independent investigation or auditobserving all general labour issues in addition to theone that has been raised.

l HR management might initiate a 360 review in anarea where no formal complaints have yet erupted,but in which anonymous reports suggest grievancesare being harboured.

l A small number of similar complaints from the samearea might justify timetabling some targetedtraining.

l Surveys might be used to further test concernswhere a flow of reports suggest abiding issues ofconcern.

It is also possible that those responsible forperpetrating the issues begin to stop the practice onceit is known that workers have access to an anonymouscomplaints mechanism.

Further reading

The Australian Human Rights Commission hasdeveloped useful guidance on handlinganonymous complaints, applying learnings fromcases of workplace sexual harassment.

https://www.humanrights.gov.au/our-work/sex-discrimination/publications/change-course-national-report-sexual-assault-and-sexual


Section 5

Complaints fromworkers employed bythird parties

This section considers how companies shouldtreat grievances raised by third-party workers.

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Third-party workers would usually be expected to raisetheir grievances with their employer, rather than thecompany that has a commercial relationship with theiremployer.

While this is a valid expectation, there are risks associatedwith it. For example, business activities which have lessvisibility are often the ones where labour rights risks tendto be greatest. This may, in part, be due to insufficiently-developed management practices on behalf of acontractor or supplier.

EVALUATING THE EFFECTIVENESS OFCONTRACTOR WORKER GRIEVANCEMECHANISMS

Many third parties, especially contractors operating at anoil and gas site, are likely to have some form of grievancemechanism in place. However, it is possible that they donot have one, or that they have one which is noteffective in addressing worker complaints. Therefore,when engaging with a contractor, either at the beginningof a commercial relationship or as part of the ongoingmonitoring of their practices, it is important to determinewhether or not they have a grievance procedure in place,and if they do, whether it is an effective mechanism foraddressing worker complaints.

To achieve this, practitioners can request specificinformation from the contractor, or speak with theirmanagement and workers during monitoring, to helpbuild a clear picture of whether a mechanism is, or islikely to be, effective.

As a part of this process, practitioners should askthemselves the following questions, and where theanswer is ‘No’, they should look to work with theircontractors to build capacities to handle grievanceseffectively.

Section 5

Complaints from workers employed by third parties

Box 5 Questions for practitioners

l Are written materials available which explain thegrievance mechanism, and are they available inlanguages understood by the workers?

l Are workers aware of the process for raisinggrievances?

l Are workers able to raise grievances anonymously?

l Are designated members of the management teamresponsible for the mechanism?

l Are complaints and corresponding resolutionslogged?

l Are grievances acknowledged by the contractor, andare updates provided to the workers withinproposed deadlines?

l Are a high percentage of grievances resolvedthrough mutually-agreed outcomes?

l Has there been a decline in similar types ofgrievance over time?

l Has the contractor demonstrated improvedcompliance with labour standards over time?

l Has there been a reduction in absenteeism/staffturnover, or an increase in productivity?

l Has there been a decline in the number of industrialdisputes?

l Can the contractor explain the application of theirgrievance mechanism?

See Appendix 2 for examples of what to do whentrying to assess the effectiveness of acontractor’s grievance mechanism.


RECEIVING THIRD-PARTY GRIEVANCES

Where there are significant gaps in a third-party’sgrievance procedures, companies can try to build acontractor’s capacity to manage grievances.

Where a third party is either unwilling or unable to put inplace a WGM of the desired standard, a company mayhave to provide assistance to develop and/or provideaccess to a WGM. If deemed acceptable, a company canalso extend its own grievance mechanisms to includethird-party workers.

Where a WGM is extended to include third-party workers,companies need to work with the third party to defineand agree upon:

l how the WGM will be communicated to third-partyworkers;

l which grievances are within the scope of the WGM,and which are not, for complaints raised by third-party workers;

l which complaints should be dealt with by thecontractor, and which should be processed by thecompany;

l the process for handling the grievance, and thedefined inputs from both the company and thecontractor; and

l the mechanisms that will be used to monitor thecontractor’s handling of grievances (reporting, audits,etc.).

These should be clearly set out in agreements withcontractors.

Section 5Complaints from workers employed by third parties

Box 7 Managing a complaint from a third-partyworker

When a complaint about a contractor or subcontractoris received, the company should review the complaintinternally, without the contractor’s involvement inaccordance with the steps set out in Section 4. Thepurpose of this assessment is to determine whether thecomplaint is within the scope of the WGM, and toassess the seriousness of the issue being raised.

l If a grievance does not fall within the scope of theWGM, this should be communicated back to thecomplainant, along with an explanation of why thecomplaint is out of scope. It may be that thegrievance is referred back to the contractor who isthen asked to report back on actions and outcomes.

l Where a grievance falls within the scope of theWGM, but the issue is not deemed to be of seriousconcern with regard to the affected workers, effortsshould be made to resolve the issue and provideliaison between the contractor and individual ifnecessary.

l Where a grievance is assessed and deemed to be ahigh risk in terms of the seriousness of theallegations or potential impact, the receiver shouldrefer the case to the personnel within the companythat handle higher-risk grievances.

l In cases where the complaint is not referred back tothe contractor, the company should assist theperson handling the complaint to ensure that it ismanaged and resolved in a timely manner.

In all instances, the process and decisions taken shouldbe documented so that these can be shared withrelevant stakeholders if necessary.

Box 6 Key performance indicators

Key performance indicators (KPIs) can be used toevaluate the effectiveness of a WGM. KPIs could include:

l the number of grievances raised, broken down byemployee type and concern;

l the percentage of grievances closed within anagreed time frame; and

l the number of grievances repeated.

See Appendix 3 for a model grievance policy andprocess that companies can use to support theircontractors.


Appendices

Appendix 1: Worker grievance mechanism 28effectiveness criteria

Appendix 2: Reviewing worker grievance 30mechanisms

Appendix 3: Template site-level grievance 31policy and procedure for contractors

Table A1 Worker grievance mechanism effectiveness criteria

EFFECTIVENESS CRITERIA GUIDANCE

Legitimate

Accessible

Predictable

A worker grievance mechanism should be perceived to be legitimate by those who mayneed to use it. It should be a clear, transparent and equitable process that is designedand implemented in accordance with the effectiveness principles, and which shouldencourage trust.

The extent to which a WGM is perceived to be legitimate can be assessed only by directengagement with the workers themselves, unless such employees are represented by aunion or other employee representative.

As a general rule, the procedures for using a WGM should be kept as simple as possible,avoiding unnecessary administrative stages.

All workers should be informed about the grievance mechanism at the time they arehired. Details about how the mechanism operates should be easily available (e.g. includedin employee handbooks or on bulletin boards in the workplace). All communicationsregarding grievance procedures should be available in the main language(s) spoken bythe workforce. Any other issues that may impede a particular worker group’s access tothe WGM should be considered. These could include gender, disability, literacy levels, etc.Worker understanding of the process should be measured via surveys or interviews.

Typically, there should be more than one point of contact or reporting channel for thegrievance mechanism. This is particularly important where there are geographicallyseparate sites; in this situation, there should be a contact person or point at each site, or agrievance hotline.

A WGM should also be made available to third-party workers (see Receiving third-partygrievances on page 25).

Management should provide a clear and known procedure for using the WGM, togetherwith an indicative time frame for each stage; for example, a maximum time between agrievance being raised and the arrangement of a meeting to investigate it.

Procedures should allow for time to investigate grievances fully, but should also aim forswift resolutions. It is important to verify that applicable legislation and collectiveagreements do not establish specific timescales.

Managers should be trained and given guidance so that grievances are handled in aconsistent, systematic and impartial manner.

Appendix 1: Worker grievancemechanism effectiveness criteria

Appendices


continued …

Table A1 Worker grievance mechanism effectiveness criteria (continued)

EFFECTIVENESS CRITERIA GUIDANCE

Equitable

Transparent

Rights-compatible

A source of continuouslearning

Based on engagement anddialogue with stakeholders

Workers and management should have reasonable access to sources of information,advice and expertise necessary to engage in a grievance process on fair and informedterms.

Where there are language barriers, it may be necessary to provide written materials indifferent languages and to engage interpreters. Additionally, support may need to beprovided to ensure that all workers understand how the WGM is used, in non-technicallanguage through advice, training, etc.

If there are low levels of literacy among workers, provision should be made to enablethose workers to lodge complaints verbally in their native language(s), or assistanceshould be provided to lodge written complaints.

Every complaint should be treated seriously, and dealt with consistently and in animpartial, confidential and transparent manner. This builds the credibility of themechanism among workers and ensures that it will be used.

A procedure should be in place to enable workers to monitor the status of complaints, aswell as the implementation of outcomes.

The outcomes or findings of any investigation should be explained clearly to all parties.Note that this will be difficult in situations where grievances have been raisedanonymously. See Handling anonymous complaints on page 21 for guidance.

Outcomes and remedies should be in line with internationally-recognized human rightslegislation and national law.

No aspect of the mechanism should prevent workers from enforcing their legal rights.Workers should be protected against retaliation for having raised complaints.

It is important that the HR or other relevant department conducts regular reviews of allcomplaints and actions taken, to evaluate the effectiveness of the grievance procedureand resolutions. The results of these reviews should be reported to senior management.Monitoring can also reveal whether initial grievances are being responded to inaccordance with stated timelines. Note that it is often not appropriate to set timelines forgrievance resolutions as they may require more time than initially anticipated to reachthe appropriate outcome.

The types of grievances that are being lodged should also be monitored by employers(e.g. to determine whether the same issues are recurring on a regular basis) to enhanceongoing human rights due diligence and worker engagement strategies.

Engaging with workers on the design and performance of a grievance mechanism canhelp to confirm that it meets their needs, that they will use it in practice, and that there isa shared interest in its success.

Appendix 1Worker grievance mechanism effectiveness criteria



Appendices

Appendix 2: Reviewing workergrievance mechanisms

Table A2 Reviewing worker grievance mechanisms

INFORMATION SOURCE WHAT TO REVIEW

Documentation review

Management interviews

Worker interviews

l Check that written information is provided to each worker explaining the mechanism.

l Check whether there are any written notices or posters in areas commonly used byworkers (e.g. canteen, break room) which outline the process for raising grievances inappropriate languages.

l Review worker files and/or grievance logs to confirm that grievances are beingsystematically acknowledged and recorded, and that workers are informed of theproposed course of action in a clear and timely manner. Records should also be keptof worker responses, and/or appeals in cases where workers are unsatisfied with theproposed solution.

l Review the grievance log to check the types of grievances raised. If the number ofsimilar grievances has decreased, this may indicate that the company is enhancingperformance in this area.

l Check HR reports and records to gather information about absenteeism or staffturnover and assess whether there have been any positive changes that couldindicate increased worker satisfaction.

l Review periodic aggregated information about grievances.

l Ask management to explain the procedure they have in place to raise grievances, andunderstand how they report outcomes to their customers/project leads.

l Confirm that there are clear reporting lines and responsibility among managementpersonnel for handling grievances.

l Gather information about the process for resolving grievances. Resolutions shouldpreferably be reached through dialogue rather than investigation.

l Ask the management team whether they have a process in place for recording andtracking grievances, and how they monitor their progress in addressing specificand/or recurring issues.

l Enquire about past industrial disputes or issues in the workplace, and askmanagement whether they think there have been any notable changes since thegrievance mechanism was established.

l Check that workers are aware of the process for raising grievances and are able toidentify who is responsible for handling them. If the mechanism’s existence and scopehas been appropriately and regularly communicated to workers, the majority ofworkers should be able to describe it.

l Assess workers’ perception of the grievance mechanism by asking them for examplesof issues they may have raised and how they were resolved. Workers’ use of themechanism indicates that they trust it as a credible avenue for addressing grievances.

l Verify that workers are aware of, and are satisfied with, the time frames within whichgrievances are addressed. The process should be predictable and transparent.

l Enquire about any notable changes in the workplace that have taken place since thegrievance mechanism was established, or about particular issues that have beenraised through the mechanism.


The text below can be included within existing contractor HR policies:

l [ Contractor ] is committed to a transparent process for workers to express concerns andfile grievances, including anonymous complaints.

l [ Contractor ] will ensure that there will be no retaliation or discrimination against thosewho express grievances, and that grievances will be treated with confidentiality.

l [ Contractor’s ] management will treat grievances seriously and take prompt andappropriate action.

l [ Contractor’s ] grievance mechanism does not replace other channels as defined by lawor collective agreements.

The process below can be included within the policy:

Informal discussion

l Managers and workers are encouraged to use informal methods of resolving disagreementsor disputes. If workers have a reasonable grievance or complaint regarding the workplace orthe way they have been treated at work they should, where possible, start by discussing itwith their manager. It may be possible to agree a solution informally between worker andmanager.

l Every effort will be made by both management and workers to resolve complaints,grievances and disputes at the earliest possible opportunity and with the minimumopportunity for tension or conflict.

Formal grievance

l If the worker wishes to raise the matter formally, he/she should set out the grievance,preferably in writing, to his/her supervisor/manager. The worker’s statement should befactual in nature and avoid language that is insulting or abusive.

l Where the grievance is against the worker’s direct supervisor and the worker feels unable toapproach that person, the worker should address the grievance to the Designated Managerat [ the Contractor ]. This is [ insert name of manager ].

l If there is a trade union at the workplace, the worker may wish to ask a union representativefor advice and support.

l If a worker does not wish to identify themselves, they may submit a written anonymouscomplaint to the Designated Manager (see below) detailing the nature of the problem.

continued …

Appendices

Appendix 3: Template site-levelgrievance policy and procedurefor contractors


Investigation and response

l [ The Contractor ] will appoint a Designated Manager who will investigate the worker’sgrievance. This is [ insert name of the manager ].

l The Designated Manager will call the worker to a meeting within 10 days after receiving thecomplaint to discuss the worker’s grievance.

l The worker has the right to be accompanied by a colleague or trade union representative atthis meeting if the worker makes such a request.

l After the meeting, the Designated Manager will give the worker a decision in writing withinfive days.

Appeal

l If the worker takes exception to the decision on a grievance and wishes to appeal, he/sheshould notify the Designated Manager. The worker will be invited to an appeal meeting withina defined time period, and the appeal will be heard by a more senior manager.

l The worker has the right to be accompanied by a colleague or trade union representative atthis meeting if the worker makes such a request. Every effort should be made to secure aresolution in the best interests of the worker(s) and the company. After the meeting thesenior manager/ombudsman will give the worker a decision in writing.

l This decision is final within the terms of the company’s internal grievance mechanism.However, this does not prevent the worker from pursuing the matter through other legalprocesses.

Record keeping

l [ The Contractor ] will keep a record of grievances lodged and outcomes, and report these ona regular basis to [ the Company ].

Appendix 3Template site-level grievance policy and procedure for contractors


Glossary of terms


Complainant An individual, or group, that has submitted a grievance. Complainants may includeindividuals who allege harms against themselves, or who allege harms against others as aresult of business activities.

Contractor An individual or company that has entered into a contract with an oil and gas company toprovide a service.

Grievance Used interchangeably with complaints. Refers to an allegation, issue or problem that aperson has related to their treatment or experience at work. This can cover a broad rangeof concerns, ranging from a complaint about the quality of food provided in the canteen, toserious and potentially illegal actions such as harassment and workplace discrimination.Can also be referred to as feedback or concerns.

Designated manager Staff member(s) assigned with the responsibility of receiving grievances and handling thegrievance process.

Direct employee A worker directly contracted by an oil and gas company to carry out work.

Supply chain Refers to the chain of suppliers providing materials, components, goods or products for usein the activities of companies. This includes suppliers of raw materials and suppliers ofspecific pieces or components for assembly/production.

Third-party worker A worker performing work for a contractor, labour agent, supplier or other business partnerthat is providing a service or goods to an oil and gas company.

Remediation The process of providing remedy for adverse impacts on workers’ rights. This may take arange of forms including apologies, ceasing the activity causing the alleged adverseimpact, compensation, rehabilitation, punitive sanctions, as well as the prevention of futureharms.

Worker grievance A procedure through which a grievance can be raised by a worker, assessed, investigatedmechanism and responded to. It is also a framework through which workers can gain access to remedy

for any adverse impacts or damage they have suffered as a result of business activities.

Glossary of terms

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