DBG Grievance Redress Mechanism (GRM)
DBG, in collaboration with PFIs, has developed a Grievance Redress Mechanism (GRM) for DBG Funded Projects that is accessible to the public. The DBG GRM is a crucial part of DBG’s Environmental and Social Management System (ESMS) and aims to address grievances or claims from individuals, groups, and communities affected by DBG-supported projects through participating financial institutions (PFIs).
DBG’s goal is to ensure that our targeted investments, interventions and initiatives do not cause any harm. To achieve this, the Bank has established comprehensive policies, procedures, and strategies for identifying and mitigating environmental and social risks. We understand that our work can have a significant impact on marginalized and vulnerable populations, and therefore, we have a responsibility to listen to the concerns of the communities where we operate. The DBG GRM provides a direct channel for individuals, groups, and communities to submit complaints or grievances to the DBG if they believe that a DBG-supported project or MSME has or will have adverse effects on them, their community, or their environment. Complainants who feel affected by DBG investments or guarantee facilities or operations through participating financial institutions (PFIs) have the right to report their concerns and be heard through this mechanism.
The DBG’s GRM serves as a platform for stakeholders to engage with our PFI and DBG on issues that affect their communities and livelihoods. The development of our GRM is based on our Environmental and Social Policy for DBG Funded Projects, ensuring that stakeholders can easily access the mechanism and participate in a thorough, fair, equitable, and transparent process. We believe that a robust GRM strengthens our impact by demonstrating our commitment to community input, safety, and trust. This GRM will be made available to parties who have grievances arising from activities related to the implementation of DBG Funded Projects and programmes.
These grievances could be related, but not limited to:
- Environmental, social, community health, safety, and security;
- Gender bias and harassment;
- Labour, compensation, and any issues that may arise due to interactions between the labor workforce and host communities;
- Resettlement-related grievances, such as the valuation of assets, amount of compensation paid, level of consultation, non-fulfilment of contracts, and timing of compensation, amongst others, will also be handled by this process.
Grievances will be deemed non-eligible if:
- Complaint is submitted 2 years after the DBG- funded MSME or program has been closed;
- Complaint is submitted 2 years after the date that the complainant became aware of the negative impacts by a DBG Funded Projects or program.
Guidelines for Complainants or Affected Parties
Any affected persons, groups, living in the area of operations or who has an economic or other defined interest in the area may submit a complaint as long as he or she can demonstrate to be affected by the activities or impacts of operations financed by DBG. This can include workers of DBG-financed investment or guarantees, local communities or those whose livelihoods are derived from the area of operations.
Yes. When an individual or an organisation files a complaint on your behalf, that organization or representative should provide written evidence that you have given them authority to represent you.
The complaint could be about: Rights abuses, negative environmental, social and corporate governance effects or other detriments, which affect a complainant and are linked to the operations financed by DBG. The Grievance Redress Mechanism cannot investigate:
- Grievance with the objective of gaining a competitive economic advantage or that are excessive, repetitive (i.e., covering the same aspects), clearly frivolous or malicious in nature.
- Anonymous complaints. Nevertheless, without prejudice, a complainant has the right to request for confidential treatment of the complaint.
- The procedure will not apply to complaints related to unsuccessful funding outcomes.
- Anonymous complaints or concerns aspects like fraud, bribery, corruption and/or money laundering
- Complaints from unsuccessful bidders in any DBG procurement process. Bidders who wish to submit queries/complaints pertaining to outcomes of procurement processes should refer to the DBG Procurement related complaints guidelines;
- Reports of suspected crime including fraud, corruption, and gender-based violence or sexual exploitation, should please make use of DBG whistleblower platforms.
- A grievance or complaint to gain competitive advantage;
- A grievance or complaint regarding matters relating to the DBG’s activities which are unconnected to a DBG funded project or programme, such as matters relating to administration and human resource management; and
- A grievance or complaint solely regarding the adequacy of the DBG operational policies and procedures.
Grievance and Complaints Process
- A complaint is received (via website (DBG GRM portal), phone call, email, or mail.
- The complaint is recorded in DBG’s Grievance Redress Mechanism Tracker and the complainant is notified of receipt and informed of next steps.
- Involved parties are informed (an initial assessment may be required to understand who the involved parties are). On occasion, an involved party, particularly the complainant, may be informed later in the assessment phase, to preserve information and review baseline facts before notice.
- The complaint is assessed by DBG’s Grievance Redress Committee (GRC) as it is made. This may involve interviewing additional parties to collect more information or bringing in third parties to support the investigation and assessment. The investigation is conducted by someone independent of the program execution. The complainant is notified when the investigation ends.
- A response/resolution is decided on by the Chairperson of the GRC,
- Response is communicated to the complaining party (where possible) and to any involved parties.
- Resolution is recorded in our Grievance tracking mechanism.
- Any lessons are applied internally as appropriate (e.g., updating policies or processes).
Affected persons of SEAH who seek to utilize the DBG grievance mechanism will have a survivor-centered and gender-sensitive lodging mechanism, investigation, and resolution. SEAH victims will have the option of maintaining anonymity and will receive assurances of absolute confidentiality if so desired in the lodging process. SEAH victims will have the opportunity to request a thorough investigation if they choose. Victims also have the right to lodge a grievance and not request that it be investigated. Victims will have the right to work accommodations to ensure their privacy and distance from perpetrators.
DBG aspires to make any effort to report a grievance easily accessible through a variety of communications channels. DBG believes that any stakeholder who has a legitimate grievance should be able to access the Grievance Redress Mechanism via the communication style that best fits their needs.
We seek to ensure that grievances can be shared by any population including youth, women, and marginalized and vulnerable populations like indigenous populations. We also seek to ensure that lodging grievances does not harm the populations that may participate by ensuring anonymity if the complainant requests anonymity or we believe that identification could lead to harm, intimidation, or fear. The following Channels of communication are available for lodging a grievance:
Channels for Filing a Grievance or a Compliant
Any Individual, institutions or community who believes that a DBG-financed or guaranteed project has or is likely to, adversely affect them can submit a complaint using any one or more of the following channels:
E-mail address: grievances@dbg.com.gh
In person or by letter to:
The Grievance Manager
Development Bank Ghana
Office Address: 8th Floor, Accra Financial Center
Liberia Road, Accra, Ghana
Online Grievance or Complaints Report Form
Where this format is used, a unique reference number will be assigned to each reported complaint or grievance and recorded on a Grievance Redress Form.