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Feedback Matters - Designing Effective Complaints Handling Mechanisms (Demand for Good Governance “How To” Learning Note Series)

Social Development DepartmentThe ancient Romans had a tradition: whenever one of their engineers constructed

an arch, as the capstone was hoisted into place, the engineer assumed accountability for his work in the most profound way possible: he stood under the

arch.”- Michel

Armstrong

Well designed Complaints Handling Mechanisms (CHMs) can provide Bank task teams and clients alike with a variety of benefits such as reduced corruption, improved service delivery and enhanced overall project effectiveness. For task teams more specifically, an effective CHM can help catch problems before they become more serious and/or widespread. In other words, CHMs are important because they act as an early warning mechanism that can help teams protect both the project’s funds and its reputation. Effective CHMs are typified by a number of characteristics including: multiple complaint uptake locations and multiple channels for receiving complaints; fixed service standards for complaint resolution; prompt and clear processing guidelines (including reviewing procedures and monitoring systems); and an effective and timely complaint response system to inform complainants of the action taken. By following the steps outlined in this note, task teams can design CHMs that help projects become more responsive, more accountable and ultimately more effective in achieving development outcomes.

A. BACKGROUND As the World Bank’s Governance and Anti-Corruption (GAC) agenda continues to move forward, Complaints Handling Mechanisms (CHMs) are likely to play an increasingly prominent role in Bank- supported projects. Well designed and implemented CHMs1 can help project management significantly enhance operational efficiency in a variety of ways including: generating public awareness about the project and its objectives; deterring fraud and corruption; providing project staff with practical suggestions/feedback that allows them to be more accountable, transparent and responsive to beneficiaries; assessing the effectiveness of internal organizational processes; and increasing stakeholder involvement in the project. For task teams more specifically, an effective CHM can help catch problems before they become more serious and/or widespread, thereby preserving the project’s funds and its reputation.

Box 1. The Importance of CHMs: Evidence from a Recent QAG Review

Complaints Handling Mechanisms2 are increasingly recognized as a critical tool for promoting transparency and accountability in Bank-financed operations. A recent Quality Assurance Group (QAG) led GAC Benchmarking and Learning Review,

1 Complaints handling systems can be designed to function at the project, sector, and country levels. This note focuses primarily on complaints handling mechanisms at the project level.2 The terms grievance redress and complaints handling are used interchangeably throughout this note.

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which assessed the responsiveness of Bank-supported operations to the GAC agenda, found that complaints handling mechanisms were included in only 28 percent of reviewed projects. Moreover, even among the projects that had CHMs, these structures were often inadequate as many were neither required to maintain written records of complaints nor obliged to act on complaints or provide written feedback. The report concludes that CHMs are one of the most under-utilized demand side governance tools and “…if complaints handling mechanisms are to grow into effective instruments for GAC mitigation they will need more careful design and greater attention during both preparation and supervision”. As these findings demonstrate, there is much room for Bank-supported projects to improve performance in this critical area. Source: Quality Assurance Group (2009)

The purpose of this note is to provide project teams with a better understanding of CHMs so that they can design CHMs that effectively collect and respond to stakeholders’ inquiries, suggestions, concerns and complaints. The note begins by helping project teams assess the adequacy of CHMs in their projects (Box 2). Most effective CHMs have common building blocks and common characteristics such as - multiple complaint uptake locations and multiple channels for receiving complaints; fixed service standards for complaint resolution; prompt and clear processing guidelines; and an effective and timely complaint response system to inform complainants of the action taken. Accordingly, the “How To” note is divided into three broad sections that discuss - the building blocks of effective CHMs; the CHM value chain; and the key steps in designing effective CHMs. The design of all effective CHMs takes into account the building blocks and the value chain (Figure 1). Different facets of the CHM design process are illustrated though examples from existing World Bank supported projects. The note does not discuss employee grievance procedures or external non-project grievance redress mechanisms (such as ministry-level grievance redress mechanisms, formal judicial systems, ombudsmen, etc.).

Figure 1: Designing A Complaints Handling Mechanism

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Box 2: Assessing the Adequacy of Your Project’s Complaints Handling Mechanism3

Effective CHMs typically share a common set of characteristics. The following list of questions will help you assess whether the CHM associated with your project is functioning up to its full potential. If the answer to any of the questions below is a “No”, you should consider improving your project’s CHM. Does the project have clear, formal and transparent internal mechanisms for

addressing complaints (e.g. a complaints handling unit, complaints handling committees, designated complaints officers, etc)?

Do project officials responsible for complaints handling have the authority to take or demand remedial action?

Are officials responsible for complaints handling obliged to take action on all complaints?

Do project-affected people feel that they can lodge complaints without fear of retaliation?

Are project beneficiaries aware of their right to file a complaint and about the complaints handling process in general?

Are there internal processes in place to record, track and monitor the action taken on complaints?

3 Though this note does not take into account how existing legal frameworks impact the CHM design process, task teams should explore how existing in-country laws and regulations impact project level complaint resolution. For example, some countries have regulations regarding procurement related complaints which are not adequate for resolution of other types of complaints. In such cases an alternate complaint resolution system for non-procurement related complaints may be necessary.

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Does the CHM provide timely feedback (written or otherwise) to the petitioner on actions taken?

Is there an appeals process in place that complainants can access if they are not satisfied with how their complaint has been resolved?

B. FIVE BUILDING BLOCKS OF EFFECTIVE COMPLAINTS HANDLING MECHANISMS

Projects may adopt different models for effective complaints handling depending upon the services delivered, the size of the Project Management Unit (PMU) and the needs of beneficiaries. For example, some projects may successfully use a centralized complaint system, while others may decentralize or outsource the function. Or there may be separate units for different functions, such as dedicated units for handling complaints from members of parliament or complaints about a particular program area. Whatever the model, effective CHMs typically build upon five core building blocks - organizational commitment, principles, people, processes and analysis.

Figure 2: Building Blocks of Effective Complaints Handling Mechanisms

Organizational Commitment: The project’s management and staff recognize and value complaints as a means of strengthening public administration, improving public relations, and enhancing accountability and transparency. Complaints handling is integrated within a project’s core activities. Since organizational commitment at all levels of an agency is key for effective complaints handling, management makes the CHM part of the project’s “DNA” by integrating complaints handling functions into project staffs’ job descriptions and regularly reviewing complaints data and trends at project management meetings.4 Management also ensures that the CHM is properly staffed and resourced.

Principles: Effective CHMs usually embody six core principles in their functioning – fairness; objectiveness and independence; simplicity and accessibility; responsiveness and efficiency; speed and proportionality; and participation and social inclusion. These principles are discussed in greater detail in Annex 1.

People: Dedicated and passionate complaints handling personnel are essential to the success of a CHM. The project provides staff working on complaints handling with the necessary training so that they can effectively carry out their roles. Generally speaking, sound recruitment practices, continuous training and learning opportunities, and systematic review and feedback regarding staff’s performance are important to the success of CHMs. In large decentralized

4 In the case of large projects, this can also be done by having a dedicated GR unit headed by (or reporting directly to) a senior project functionary.

PrinciplesPeopleProcessesAnalysis

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projects a special Complaints Handling Unit (CHU) with field units with dedicated personnel may be required.

Processes: Complaints handling (CH) processes play an important role in project activities. The six stages of the complaints handling “value chain”—uptake; sorting and processing; acknowledgement and follow-up; verification, investigation and action; monitoring and evaluation; and feedback—are clearly outlined and publicized by project management and staff. The CHM value chain is discussed in detail in Section C.

Analysis: Project management regularly analyzes complaints reports and other monitoring and evaluation data. Complaints data provides management with insights into the effectiveness of a PMU’s programs and can be used to identify problem areas, improve internal processes and enhance service delivery (in order to minimize the number of complaints in the future).

Box 3: Common Misconceptions about Complaints Handling Mechanisms

o CHM users know how to lodge complaints. Most potential CHM users are not aware of how they can access the CHM. This often occurs because complaints handling standards are not well publicized and/or the roles and responsibilities of complaints handling staff are not clearly defined.

o CHMs only address corruption complaints. While CHMs are useful for curtailing corrupt practices, they are also useful for collecting other types of data. For example, out of 2,300 complaints received by KDP’s (Kecamatan Development Program) complaints handling unit, 40% were related to corruption while the other 60% were queries, comments or complaints related to the project’s general performance.

o One size fits all. Given that there is no “one size fits all” CHM, CHMs should be tailored to the project context—including the size of the PMU, types of services delivered and beneficiaries’ needs—to operate most effectively.

o CHMs are costly, complex and resource intensive. Not all CHMs are complex and resource intensive. Indeed, projects in low resource settings (e.g. in project contexts where capacity, funds and technology are limited) can also design and adopt customized and sustainable CHM models that are simple and inexpensive. For example, teams could place locked complaint boxes at different project locations and local staff members could check the boxes every two weeks. Project staff could then assess the complaints and publicize the results of the investigations on community notice boards.

C. THE COMPLAINTS HANDLING MECHANISM VALUE CHAIN

The complaints handling process itself, is a critical facet of any effective CHM. The complaints handling process, which has been consolidated into a value chain to facilitate understanding, comprises of six steps – complaint uptake; complaint sorting and processing; acknowledgement and follow-up; complaint verification, investigation and action; complaint monitoring and evaluation; and feedback (Figure 3). It is important to consider all of these stages in detail during design of the CHM.

Figure 3: The Complaints Handling Mechanism Value Chain

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Uptake refers to the methods by which the project will collect complaints. Taking into account technology, funding and capacity constraints, the project should have multiple uptake locations (at the community, village, district, provincial/regional and PMU levels, etc) and multiple uptake channels (mail, email, telephone, project website, project staff, text messaging (SMS), strategically placed complaints boxes, etc). Since the cost and complexity of CHMs increase with the number of potential uptake locations, teams should choose uptake locations strategically based on the goals of the project.

Project Insight 1. National Community Empowerment Program (NCEP), Indonesia - Innovative UptakeNCEP has a wide variety of complaints uptake locations including: complaints books in community secretariats, phone, email, text messages (SMS), project website, project staff, the news media and reports from the Inspector Board of Development Performance. The SMS uptake point has proven particularly effective, with an average of over 250 complaints per month being logged through this method. In a testament to its effectiveness, NCEP’s CHM has logged nearly 16,000 complaints with a resolution rate of over 99%.Click here for the NCEP PAD

Sorting and Processing refer to the internal policies that guide how different types of complaints are categorized, who they are referred to, and how they are addressed. Various types of complaints typically require different follow up actions. For example, some complaints can be resolved by means of a simple explanation or apology while others may require more extensive investigations. As such, complaints need to be categorized, assigned priority and routed to the appropriate entity. Moreover, standardized internal processes need to be in place to guide how complaints are logged. Complaints can either be logged manually or, if resources allow for it, by using a computer based system that will allow the project to identify trends in the data across time and geographic locations.

Project Insight 2. Kalahi-CIDSS, Philippines – Categorizing ComplaintsSince projects receive a wide range of complaints ranging from allegations of corruption to simple suggestions and queries, it is important to accurately categorize different types of complaints. In the Kalahi-CIDSS Project the CHM is designed to respond to four types of complaints: (i) comments, suggestions or queries; (ii) complaints relating to non-performance of project obligations; (iii) complaints referring to violations of law and/or corruption; and (iv) complaints against project staff or community members involved in project management.Click here for the PAD for this project

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Acknowledgement and Follow Up refers to the processes by which complainants are informed of the receipt of their complaint and provided with periodic progress updates. Clearly defined timetables for acknowledgement and follow-up activities need to be established. Moreover, these timetables should be disseminated widely to various stakeholder including communities, civil society and members of the media to enhance accountability. The initial acknowledgement should: outline the complaint process; provide contact details and preferably the name of the contact person that is responsible for handling the complaint; and note how long it is likely to take to resolve the complaint. Complainants should periodically be updated on the status of their complaints according to a clearly defined timetable.

Verification, Investigation and Action refers to the processes of gathering information about the complaint to determine its validity and resolving the complaint. The merit of complaints should be judged objectively against clearly defined standards. Complaints that are straightforward (such as queries and suggestions) can often be resolved quickly by contacting the complainant. Complaints that cannot be resolved at one level of the system should be referred to a higher level and/or outside entity for verification and further investigation according to a clearly defined timetable. Project staff should ensure that investigators are neutral and do not have any stake in the outcome of the investigation. Potential actions include responding to a query or comment, providing users with a status update, imposing sanctions or referring the complaint to another level of the system for further action. Generally speaking, the project should take some action on every complaint.

Monitoring and Evaluation is critical to the success of any CHM. Monitoring refers to the process of tracking complaints and assessing the extent to which progress is being made to resolve them. Projects that serve a large number of citizens or beneficiaries—such as in community driven development, rural roads, water and sanitation, health, education, or social protection projects—are likely to receive a large number of grievances. In these projects, there should ideally be an electronic system for entering, tracking and monitoring grievances. The existing project monitoring and evaluation information system should also include a few fields for complaints monitoring and resolution.

Evaluation refers to the analysis of complaints data so that policy and/or process changes can be made to minimize similar complaints in future. As mentioned previously, analyzing complaints data helps management reorient project processes in order to increase project effectiveness. As such, reports on complaints data and trends (e.g. average time taken to resolve complaints, percentage of complainants satisfied with action taken, number of complaints resolved at first point of contact)5 should be submitted on a regular basis. Senior project management should regularly monitor complaint resolution data and grievance trends in their progress review meetings and randomly call complainants from different areas and groups to get feedback on whether/if the CHM is functioning effectively.

5 Reports to management also typically include information on the number of complaints about a particular issue, spikes in complaints, geographical spread of complaints, characteristics of the complainants, etc.

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Project Insight 3. NCEP, Indonesia - Real Time Monitoring and EvaluationNCEP staff members input monitoring and evaluation data directly into a website so that the project management unit and World Bank staff can access “real time” data about the CHM. The web-based management information system contains data such as complainant information, details of the case, an assessment of the problem, potential follow up actions and how the complaint was resolved. As such, the database contains a virtual “library” of past complaints along with the feedback reviewers provided on these complaints. Having access to this real time data allows project management to more easily identify problem areas, quickly analyze suggestions and comments about the project’s performance, and devise strategies about how to reallocate resources and upgrade processes to enhance operational efficiency. Click here for the NCEP PAD

Feedback refers to the process of informing CHM users and the public at large about the results of investigations and the actions taken. Providing feedback about how complaints are resolved is critical as it enhances the visibility of the CHM among beneficiaries and increases users’ trust in the system (which makes it more likely that they will lodge complaints). Projects can provide feedback by contacting the complainant directly (if his or her identity is known) and/or posting the results of cases in high profile locations and conveying the results through radio broadcasts and other media. The project should also inform CHM users about their right to an appeal if they are dissatisfied with the decision and specify both internal and external (such as judicial review, ombudsman, line ministry, etc.) review options.

Project Insight 4. Rural Competitiveness Project, Honduras - Providing Useful FeedbackIn order to increase trust in its CHM, the project uses a number of mechanisms to provide feedback about complaints handling including: a) maintaining a complaints register and publishing complaints received and disposed of annually; (b) providing the Bank with semiannual reports on complaints handling; and (c) creating stakeholders consultation mechanisms at the regional level that can be used to provide updates on the project’s performance on complaints handling. Click here for the PAD for this project

Some of the most important “do’s and don’ts” that project teams should keep in mind while designing the processes encompassed in the CHM value chain are given in Figure 4.

Figure 4: CHM Value Chain Do’s and Don’ts

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C. DESIGNING AN EFFECTIVE COMPLAINTS HANDLING MECHANISM

This section of the note outlines a six-step process that will assist project teams in designing effective CHMs for their projects (Figure 5). The steps take into account the essential CHM building blocks discussed above. Special attention must be taken to integrate design features that make CHMs participatory and socially inclusive (Box 5) since poor and marginalized communities often face the most obstacles in accessing and using CHMs.

Figure 5: Six Steps in Designing an Effective Complaints handling Mechanism

Step 1: Survey existing formal and informal in-country CHMs and build upon them In most countries there are formal governmental complaints handling systems (complaints handling cells within ministries or departments, access to information centers, judicial systems, etc.) and/or informal traditional conflict resolution

1. Survey existing formal and informal CHMs 2. Estimate users and assess available resources for CHM3. Develop standard operating procedures/flowcharts4. Develop and publicize CH policies5. Assign CH tasks and train staff6. Stimulate external demand for CHM

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structures (council of village elders, tribal chiefs, etc.) in place that can take on the responsibility for complaints handling and resolution in projects. For example, in recent years more and more countries world-wide are passing access to information6 laws and setting up systems for facilitating citizens’ access to information. Teams should take advantage of these systems and build upon them. The project team should survey and assess these mechanisms while considering project CHM design. The social assessment undertaken during project preparation can help identify such mechanisms and provide an understanding of the complaint resolution processes at the local level. If the analysis reveals that existing systems are weak or inadequate, the project should attempt to build upon existing CHMs while addressing existing weaknesses. To the extent possible, teams should attempt to build upon existing country systems as opposed to creating a stand-alone mechanism.

In instances where capacity, resource and/or political economy considerations (e.g. where the existing complaints handling mechanisms are not perceived to be impartial or fair) make it unfeasible to draw upon existing CHMs, project teams need to consider the creation of a stand-alone CHM. If the project ultimately decides to create its own dedicated CHM then the team has three design options – (i) it can delegate responsibilities for complaints to a dedicated internal staff member or team; 2) it can outsource the work to an external entity, or 3) utilize a combination of internal staff and external monitoring entities.7 Whatever form the CHM takes, the project should attempt to use the stand alone CHM to demonstrate the value and importance of CHMs to other stakeholders in government. Moreover, there should be a plan in place to build technical capacity on complaints handling so that CHM can be integrated into government programs when the project ends.

Where CHMs are new and understanding of these systems is limited, it is best practice to allow the CHM to grow organically as awareness increases. Indeed, putting in place a very comprehensive CHM when the understanding and experience with CH is limited can create an ineffective system that is not sustainable. As such, it is often better to start the CHM in a strong region and only focus on a few issues initially. After the project demonstrates that the CHM is successful, it will be easier to scale it up and persuade the government to provide additional resources for CH.

Project Insight 5. Tamil Nadu Irrigated Agriculture Modernization and Water-Bodies Restoration and Management Project, India - Building on formal CHMsWhile the project has its own processes in place to handle grievances related to the tendering process, it also builds upon Tamil Nadu State’s existing CHM. Since the Tamil Nadu Government already has a streamlined CHM in place in project areas, tender participants and civil society groups can lodge complaints at designated government offices. For grievances that cannot be resolved on the spot, each petition is numbered and the petitioner is given a receipt with the date

6 Access to information is also referred to as right to information or freedom of information in some countries. 7 World Bank (forthcoming). The project team’s decisions about which structures to ultimately adopt will also be dependent on available resources and the nuances of the operating environment including the capacity of civil society and other non-governmental organizations to play watchdog roles, technological constraints and cultural attitudes towards lodging complaints.

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by which a reply will be given. By building upon the existing CHM the project not only provides additional outlets through which stakeholders can lodge complaints, but also helps the government continue to develop its capacity in this area.Click here for the PAD for this project

Step 2: Estimate users and assess available resources for CHM At the outset, project teams should estimate the number of citizens that are likely to use the CHM and assess the resources—human, financial and technological—that are available (and required) for the CHM. Given that CHMs for projects which serve a large number of beneficiaries–such as community driven development, rural roads, water and sanitation, health, education, and social protection projects—tend to be more complex and costly, teams should conduct a needs assessment to determine the CHM’s scope and scale and to identify resource gaps. It is important to note that CHMs can be relatively simple, operate effectively in low resource settings, and/or be decidedly low tech. Moreover, CHMs can be designed in a modular fashion (with fewer uptake locations, complaint receiving channels, languages, etc.) so that they can be scaled up gradually as additional resources are mobilized.

Box 4: Integrating Text Messaging (SMS) into CHMs

With the rapid spread of mobile phones in the developing world, text messaging represents an increasingly viable, and potentially important, conduit for collecting complaints and grievances. First, SMS systems provide beneficiaries with an easy and cost effective way to engage with project staff and management. Second, SMS systems can allow staff at the local level and/or in remote areas to rapidly transmit complaints data to a central database using their mobiles phones. Though projects have the option to design their own SMS uptake system, there are a variety of open source SMS platforms (including Frontline SMS and RapidSMS) that projects can customize based on their unique needs and priorities. These platforms are designed to not only transmit the text message data to a web site so that project staff can have access real time complaints data statistics, but also to send users a reply acknowledging that their complaint has been received. Given that the costs associated with implementing an SMS platform continue to fall, the technology represents an innovative tool that project teams can draw upon to improve the effectiveness of their CHMs.

Step 3: Develop standard operating procedures and flowcharts that codify how complaints will be redressed for all stages of the complaints handling processProject management should develop operating procedures, guidelines, and flowcharts detailing how the complaints handling process will unfold within the project’s operating structures. Taking into account the CHM value chain outlined in the previous section, procedures should also clearly establish complaints monitoring reporting lines and processes. Complaints handling processes should be outlined in the project’s operational manual or compiled as a stand-alone publication to be distributed to project staff and CHM users.

Project Insight 6. NCEP, Indonesia - Flowchart for Complaints Handling

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In NCEP complaints that cannot be resolved at one level of the CHM are typically reassigned to actors at higher levels. As depicted in the flowchart below, higher levels of the project are also responsible for monitoring the complaints handling performance at lower levels.

Click here for the NCEP PAD

Step 4: Demonstrate management’s commitment to the CHM by developing and publicizing project complaints handling policies and guidelines Project management should issue and publicize a complaints handling policy which clearly states that it embraces complaints and views them as opportunities for improvement. The policy should: identify guiding principles (preferably the ones enumerated above); define the scope and types of complaints to be addressed; state a user-friendly procedure for lodging complaints; outline a complaints handling structure; describe performance standards; spell out internal and external complaints review mechanisms, etc.8

The key to the overall success of CHM is organizational commitment. Since generating this commitment among government partners is easier said than done, it is often useful to have discussions and/or workshops with counterparts to enhance knowledge about the benefits of, and activities associated with, effective complaints handling. For example, in the Urban Poverty Project (UPP), Indonesia one of the real turning points in relation to CH happened when the PMU realized that those areas that were not recording complaints were performing relatively poorly in comparison to those that received more complaints. Given that even the best performing areas will have some complaints, staff began to understand that complaints are not equal to problems. Moreover, staff found that while greater transparency generates more complaints it also improves overall performance.

Project Insight 7. Social Action Fund, Malawi (MASAF) – The Code of Ethics and Ethics DatabaseIn collaboration with the police department and the Anti-Corruption Bureau

8 For large and/or decentralized projects, it is often useful to set up a 2-3 person grievance facilitation unit at the PMU level (which could be housed in the M&E department) that can oversee the roll-out of the CHM. At lower levels of the project, existing project staff can be assigned complaints handling functions. Moreover, communities can also be trained to undertake complaints handling activities.

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(ACB), MASAF has launched a number of initiatives to prevent and combat unethical practices within the project. MASAF’s Code of Ethics, which is widely publicized, defines “unethical conduct” as behaviors or actions associated with fraud, corruption, misuse of resources, deliberate misinformation, circumvention of procedures, or any other similar behavior likely to bring disrepute to MASAF, its board, management or employees. MASAF’s own internal ethics code encourages the public to lodge complaints anonymously either with MASAF, the ACB, the Police or using the judicial system. Accordingly, MASAF, in collaboration with the ACB, has also established a grievance hot-line to collect complaints. Village-Based Anti-Corruption Clubs are also being established to lodge corruption complaints, thereby facilitating collective community action against corruption. The MASAF Ethics Database acts as a memory center to facilitate analyses of unethical practices; follow-up on cases involving fraud, corruption and unethical practices; and for reviews of ethics policies instituted under MASAF. Accordingly, MASAF’s ethics database contains a record of all cases of unethical practices that have come to the attention of MASAF. Most cases deal with fraud, theft, misappropriation, armed robbery, forgery and impersonation and have been handled by the ACB, the police or MASAF internally. A number of MASAF personnel have been prosecuted and dismissed after investigations on the basis of these complaints. Source: Governance and Anti-Corruption (GAC) Benchmarking and Learning Review, 2009

Step 5: Assign complaints handling responsibilities and train staff to handle complaintsStaff in charge of complaints handling should be skilled and professional. As such, project management should identify high caliber staff at all levels of their projects and assign them responsibility for handling complaints. Projects should implement a complaints handling training program to sensitize staff (and community members if applicable) about how to handle complaints and why the CHM is important to the project’s success. This training should include information about how to interact with beneficiaries about complaints, the organizations’ customer service standards, and internal policies and procedures in relation to CH. If applicable, it is also useful to establish or build upon local and community based CHMs by providing complaints handling training for stakeholders at the local level (doing so greatly reduces CH costs while enhancing beneficiary satisfaction and ownership of the complaints handling process).

Project Insight 8. Java Reconstruction Fund, Indonesia – Integrating Complaints Handling into Project DNAFacilitators in this community driven development project are required to 1) ensure all community members understand where and how to lodge a complaint concerning any aspect of the project; 2) ensure that all complaints are followed-up at the appropriate level and assist in their resolution 3) support parties lodging complaints and parties seeking the resolution of complaints at the community level.Click here for the PAD for this project

Step 6: Stimulate external demand for the CHM through disclosureEven the best-designed CHMs cannot function effectively in isolation. Projects should publicize the existence of the CHM, its procedures, the levels/officers which

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different types of complaints are supposed to be addressed to, the operating service standards and other relevant information as part of a comprehensive communications strategy. The communication should also reach out to the poor and marginalized, who often cannot access the CHM (Box 5). Information about the CHM can be provided through various channels including

the project website, text message campaigns, mail correspondence with clients, pamphlets, bulletin boards in communities, outreach campaigns by staff and facilitators, etc. Communication materials should be translated into as many local languages as resources permit.

There are several important messages that need to be conveyed and reinforced over time by project authorities and staff, namely: o There is no financial charge for making a complaint; o Complaints are welcome because they help improve project policies, systems

and service delivery;o Complaints will be treated confidentially and complainants will not be

punished for complaining. Essential details about a project’s CHM that should be conveyed to

beneficiaries include: o The types of complaints that can be submitted;o How to submit a complaint and where to access the complaints form; o The project’s standards and timeframes for complaint resolution; o The options available to a complainant if s/he is dissatisfied with the CH

process or outcome.Ensuring that people are aware of the CHM and how it functions is critical. For example, the NCEP, Indonesia has over 10,000 operators and 200,000 beneficaries who are working on the project. As such, the project designed special brochures and crafted a publicity strategy to ensure that stakeholders were aware of the system. The project also uses a web-site to provide information and data about the CHM.

Project Insight 9. Water Sector Support Project, Yemen - Spurring Demand for the CHMIn an effort to reduce corruption in the water sector, Yemen’s Water Sector Support Project (WSSP) is designing a complaints handling hotline program. The hotline program will encompass a variety of uptake locations including: the hotline itself (staffed 24 hours a day, seven days a week), fax, email, post office box and a web page linked to the relevant ministry’s website. The uptake locations will be managed by a single, independent operator who is responsible for routing complaints to the proper authorities. In order to increase awareness about the hotline program, the project has planned an advertising campaign targeted at government officials, private sector contractors, suppliers, consultants, civil society and the communities in which the projects will be implemented. In addition to increasing the likelihood that beneficiaries will access the CHM, this strategy also publicly demonstrates the project’s commitment to curbing corruption. Click here for the WSSP PAD

Box 5: Making CHMs Work for the Poor and Marginalized

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Poor and marginalized communities face numerous barriers in accessing CHMs. Some of the reasons why people from poor and marginalized groups do not complain are – illiteracy; lack of knowledge about their rights; mistrust in government and fear of retribution; lack of access to technology; perceived hassle in complaining; and the belief that project authorities will not act upon their complaints. Some strategies that project’s can use to reduce these barriers to complaining and make CHMs participatory and socially inclusive are – establishing complaint uptake locations in areas where poor and marginalized people live; engaging local intermediaries (community based or civil society organizations) to facilitate the complaint submission; deploying community-specific communication strategies to allay fears about and increase comfort levels for submitting complaints; ensuring that there is no formal or informal charge for making complaints; and treating complaints confidentially.

E. CONCLUSION

As the GAC agenda continues to move forward, CHMs are likely to be an increasingly important component of all Bank-supported projects. The effectiveness of CHMs rests on three fundamentally interconnected factors: a clear organizational commitment to complaints handling, well designed internal processes for addressing grievances, and tailoring the CHM to the intricacies of the unique operating environment. In addition to addressing and resolving complaints and grievances, CHMs should also be designed to serve as a conduit for soliciting inquiries, inviting suggestions and increasing community participation. To the extent that projects are able to achieve success on these dimensions, CHMs can provide operations with a wide range of benefits including - curbing corruption; collecting information that can be used to improve operational processes and performance; empowering vulnerable populations; and enhancing the project’s legitimacy among stakeholders. As such, effective complaints handling systems represent a step in the right direction towards greater accountability, enhanced sustainability and ultimately better project outcomes.

F. REFERENCES AND RESOURCES9

Asian Development Bank (2009). Handling Complaints Efficiently. Manila: Asian Development Bank:

Commonwealth Ombudsman (2009). Better Practice Guide to Complaint Handling. Canberra: Commonwealth of Australia.

Jennet, Victoria and, Marie Chene (2007). Anti-corruption complaints mechanisms. U4 Anti-Corruption Resource Centre.

Kalahi-CIDSS Project (2003). Guide to the Kalahi-CIDSS Complaints handling System. World Bank.

National Community Empowerment Project-Urban (2008). Complaint Handling Unit. PowerPoint presentation, July 2008.

World Bank (forthcoming). A Guidance Note on Promoting Social Accountability for Increased Impact and Empowerment. Washington D.C., World Bank.

9 Additional resources for practitioners are available on the Social Development Department’s website

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World Bank Department of Institutional Integrity (2008). Leveraging Complaints Handling in Projects. PowerPoint presentation, April 16, 2008, Washington D.C.

World Bank Department of Institutional Integrity (2007). Complaint Handling Systems. PowerPoint presentation, Washington D.C.

World Bank Quality Assurance Group (2009). Governance and Anticorruption in Lending Operations: A Benchmarking and Learning Review. Washington D.C.: World Bank.

This note was prepared by David Post and Sanjay Agarwal of the Social Development Department at the World Bank as part of the DFGG “How To” Learning Note Series. The series is an attempt by the Governance and Accountability Team of the Social Development Department (SDV) in collaboration with the GAC-in-Projects Team of Operational Policies and Client Services (OPCS) and the Social Sustainability and Safeguards Practice Group to provide guidance on select approaches to improve governance and accountability in Bank operations. The authors are grateful to the peer reviewers Steve Burgess and George Soraya of the World Bank for their invaluable insights and comments. The authors would also like to thank Luiz Alcoforado, Ivor Beazley, Asmeen Khan, Charles E. Di Leva and Albert Ninio for additional comments.

The findings, interpretations, and conclusions expressed in this note are entirely those of the authors and should not be attributed in any manner to the World Bank, to its affiliated organizations, or to members of its Board of Executive Directors or the countries they represent.

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Annex 1: Core Principles of Complaints Handling Systems

Effective CHMs usually embody six core principles –A. Fairness: Complaints are treated confidentially, assessed impartially and

handled in a transparent manner. B. Objectiveness and independence: The CHM operates independently of

all interested parties in order to guarantee fair, objective and impartial treatment to each alleged case. CHM officials are given adequate means and powers to investigate complaints (e.g. interview witnesses, access records, etc).

C. Simplicity and accessibility: Procedures to file complaints and seek action are simple enough so that project beneficiaries can easily understand them. Project beneficiaries are given a range of contact options including, at a minimum, a telephone number (preferably toll-free), an email address and a postal address. The CHM is accessible to all stakeholders, irrespective of how remote an area they live in, what language they speak and their level of education or income. Complex processes that create confusion or anxiety (such as only accepting complaints on official-looking standard forms or through complaint boxes in government offices) are avoided.

D. Responsiveness and efficiency: The CHM is designed so that it is responsive to the needs of all complainants. Accordingly, officials handling complaints are trained to take effective action upon and respond quickly to complaints and suggestions.

E. Speed and proportionality: All complaints, simple or complex, receive sustained attention and are resolved as quickly as possible. The action taken on the complaint or suggestion is swift, decisive and constructive.

F. Participatory and social inclusion: A wide range of CHM users including community members, members of vulnerable groups, project implementers, civil society and the media are encouraged to bring complaints and comments to the attention of project authorities. Special attention is given to ensure that poor people and marginalized groups,

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including those with special needs, are able to access the CHM.