Community Grievance Mechanism
The Community Grievance Mechanism (CGM) is an important pillar of ExxonMobil’s stakeholder engagement process worldwide, and central to the Esso Exploration and Production Guyana Limited (EEPGL) venture. It is intended to address grievances that originate from EEPGL exploration, projects, and operational activities. EEPGL’s CGM is a structured process that creates an opportunity for community members and other stakeholders to raise grievances directly to EEPGL and have them addressed in a prompt and respectful manner.
The CGM will be made available to stakeholders during engagements (both formal and informal) verbally and in writing, through periodic social media posts, and online at EEPGL’s website at www.exxonmobil.com/guyana.
The EEPGL CGM was designed in alignment with internal and external best practices including the World Bank1, International Finance Corporation2, and IPIECA3.
In EEPGL, the Socioeconomic Manager coordinates the overall CGM process. The Socioeconomic Team (typically the Socioeconomic Advisor) leads the day-to-day functioning of the CGM.
Participation in the Community Grievance Mechanism does not in any manner negate an individual’s right to pursue other remedies as provided under Guyana law. Equally, EEPGL retains its rights under law to pursue legal remedies.
The CGM addresses EEPGL-related individual, community, and other stakeholder grievances. This includes grievances concerning both offshore and onshore activities. The process is designed to receive, assess, and respond to grievances and provides a mechanism to identify and address trends or systemic sources of concern.
Company and contractor workplace grievances, such as pay, overtime, and working conditions, are not managed through this process, but through processes established by each employer.
EEPGL reserves the right not to address feedback which it reasonably considers amounts to no more than general, unspecified, and therefore un-actionable dissatisfaction with the venture, is otherwise malicious or vexatious in nature, or concerns a matter for which the company has no formal responsibility (for example, a matter that other parties, including the government steward).4
EEPGL expects onshore and larger offshore contractors to utilize a CGM process aligned with the principles outlined within this document.
Application of the CGM
On a daily basis, EEPGL receives formal and informal feedback from stakeholders. While all feedback is important to review, assess, and respond, only grievances fall within the scope of the CGM and thus are governed by the mechanism described within this document. To clarify the application of the CGM, EEPGL uses the following definitions:
CGM applies to:
1. Grievance – A complaint that expresses discontent, negative impact, financial loss or physical harm or an allegation of tangible damage or impact that occurred as a result of company or contractor actions. Grievances, also sometimes called complaints, are typically accompanied by a request for resolution and rectification. For Example: “EEPGL construction trucks are creating dusty conditions along the road affecting my residence”.
CGM does not apply to:
2. Concern – A matter that engages a person’s attention, interest, or care, or that affects a person’s welfare or happiness related to questions or requests for information or general perceptions, unrelated to a specific impact or incident. For Example: “EEPGL is contributing to traffic in Georgetown”.
3. Issue – A point in a question or a matter that is in dispute between contending parties or a pre-existing complaint or concern between two non-Project entities, one of which may attempt to use EEPGL’s activities as the leverage to achieve resolution. For Example: “Regulatory agency did not provide sufficient time for public comments”. Issues will be referred to the entities directly involved.
4. Request – Asking for something to be given or done, especially as a favour or courtesy; a solicitation or petition or a communication from a stakeholder requesting something – donation, community project, job, contract, or some other benefit for a group or individual. For Example: “Would like to request a donation to support my community group”. Requests will be forwarded to the most appropriate department for review and consideration.
5. Guidance – Asking for general advice or information aimed at resolving a problem or difficulty. For Example: “How do I access business opportunities with EEPGL?” The Socioeconomic Team would provide a response or re-direct the question to the appropriate department for further action.
The objectives of the CGM include5:
- Develop and maintain positive relationships with communities affected or potentially affected by our activities
- Demonstrate EEPGL’s commitment to collect, understand, and be responsive to grievances
- Avoid potential impacts by EEPGL exploration, project, and operational activities by the early identification of concerns
- Analyze trends to drive continuous performance improvement by reducing repeat grievances
- Identify areas of stakeholder interest to enhance engagement and inform business decisions
EEPGL Community Grievance Management (CGM) Process
The CGM Process is illustrated in Figure 1 and described in more detail in Table 1. The process describes who can submit and receive feedback, how it is categorized, assessed, and stewarded to closure.
Any stakeholder can submit a grievance to the CGM. This includes individuals, communities, NGOs, and others.
Grievances can be raised through a variety of methods including:
Appendix B lists the details for all access points.
Some feedback may be confidential. In such an instance, EEPGL strives to maintain the confidentiality of the individuals and/or organisations involved.
Individuals providing feedback may also do so anonymously either by not providing their contact information at the time of submittal or by asking that their name or entity not be recorded. Note that anonymously submitted feedback may be difficult to investigate / respond and ultimately address or close.
EEPGL will make best efforts to acknowledge receipt of a grievance within 5 working days; this acknowledgement can be verbal (and documented within the database) or written depending on how the feedback was initially received.
The acknowledgement confirms that the grievance has been received and is being assessed.
3. Assess and Assign
Using informed judgement, the Socioeconomic Team will:
Note: In some cases, the Socioeconomic Team may resolve smaller grievances on-the-spot so that they do not require escalation.
4. Review and Investigate
The ‘grievance owner’ investigates the factual basis for the Grievance and proposes options to resolve the issue. The ‘grievance owner’ may involve third parties in the fact-finding process as required. If the Grievant has specifically requested that his or her identity not be disclosed, their personal information may not be shared with third parties unless required by law.
EEPGL generally seeks to resolve complaints within 30 days. However, some grievances will require additional time before an informed response can be provided.
The Socioeconomic Team is responsible for providing regular progress reports to the Grievant including if additional time is needed to complete an investigation.
When the investigation is complete, the ‘grievance owner’ documents the findings and proposes options for resolving the grievance.
If a grievance is found to not be related to EEPGL or its contractors, the Grievant will be informed. The grievance is then considered to be closed.
The grievance owner and the Socioeconomic Team will align on a response to the Grievant which should include the findings of the investigation, set out the proposed solution and timelines, and seek feedback.
If the Grievant accepts the resolution, EEPGL will proceed to implement the agreed upon actions. The grievance owner is responsible for assigning action parties, actions, and deadlines to implement the resolution.
6. Resolved or Appeal
If the Grievant is satisfied with the response, the grievance is closed out.
If the Grievant is not satisfied with the response and/or actions taken to address the grievance, they have a right to request that the matter be reconsidered. This review will be conducted by individuals who were not part of the initial review.
A grievance is closed out when no further action can or needs to be taken.
The Socioeconomic Team will update the database with all relevant information.
In addition, in some cases the Socioeconomic Team may elect to continue to monitor the close out of a grievance to confirm that the intended outcome is achieved.
Reporting and Monitoring
Monitoring is conducted to measure the effectiveness of the CGM and to identify trends in feedback for continuous improvement of EEPGL activities and improved stakeholder engagement.
It is understood that the existence of a large number of grievances from communities is not necessarily indicative of bad performance. Such a number may, in fact, demonstrate a high-quality dialogue and community interface. The goal is to gain trust and confidence on the part of communities that when valid concerns or complaints are appropriately raised, EEPGL addresses them and responds accordingly. A grievance process should not place undue emphasis on reducing the number of grievances registered, as they may be seen in many cases as analogous to “near-miss” reports that allow the exploration to address complaints before they get serious. However, achievement of closure and the average time to achieve closure of grievances are key performance indicators.
The Socioeconomic Team is responsible for monitoring and reporting grievances. On a monthly basis a summary of grievances, status, statistics, and issues will be reviewed to identify any trends. Data typically includes:
- Number of grievances received during reporting period
- Number of grievances closed during reporting period
- Percent of grievances closed in less than 30 days
- Category of grievance
- Distribution of aged grievances (30 to 60 days, 60 to 90 days, more than 90 days).
Note: In line with permit obligations, EEPGL reports the number of environmental grievances to the EPA monthly.
Potential Conflicts of Interest
EEPGL will manage potential conflicts of interest by segregating the roles and responsibilities of individuals involved in the grievance handling process and avoiding placing individuals in a position where conflicts could be perceived to arise. When a grievance relates to a specific EEPGL employee or contractor, that person shall not play a role in the grievance handling process outside of providing background information.
Sample Grievance Form
Esso Exploration and Production Guyana Ltd.
86 Duke Street, Kingston
Grievances received through social media accounts will be routed to the Socioeconomic Team for assessment.
Facebook and Instagram: @exxonmobilguyana
1 World Bank, 2014. The World Bank's Approach to Grievance Redress in Projects. Washington, DC, USA.
2 International Finance Corporation, Sept 2009. Good Practice Note Addressing Grievances from Project-Affected Communities. Washington, DC, USA.
3 IPIECA, 2015. Community Grievance Mechanisms in the Oil and Gas Industry. London, United Kingdom.
4 IPIECA, 2014. Community Grievance Mechanism Template Procedure. Pg. 4
5 IPIECA, 2015. Community Grievance Mechanisms in the Oil and Gas Industry. Pg. 14
6 IPIECA, 2015. Community Grievance Mechanisms in the Oil and Gas Industry. Pg. 42, Figure 7