Stakeholder Engagement Plan SEP Network Reinforcement and Access Project P166170
Stakeholder Engagement Plan SEP Network Reinforcement and Access Project P166170
Stakeholder Engagement Plan SEP Network Reinforcement and Access Project P166170
April 2019
TABLE OF CONTENTS
1. INTRODUCTION................................................................................................................................... 3
1.1. Overview ...................................................................................................................................... 3
1.2. Stakeholder Engagement Plan (SEP) ......................................................................................... 4
1.3. Regulations and requirements ................................................................................................... 4
Statute and Regulations ...................................................................................................................... 4
2. AN OVERVIEW OF STAKEHOLDER ENGAGEMENT .......................................................................... 4
2.1. What is Stakeholder Engagement? ............................................................................................ 4
2.2. Principles for Effective Stakeholder Engagement .................................................................... 5
2.2.1. Stakeholder Engagement Considerations ......................................................................... 5
2.3. Stakeholder Identification .......................................................................................................... 6
2.4. Stakeholder identification and consultation methods ............................................................. 7
2.5. Stakeholders identified ............................................................................................................... 8
2.5.1. Stakeholder Government Ministries .................................................................................. 8
2.5.2. Stakeholder Parastatals/Agencies ................................................................................... 10
2.5.3. Stakeholder Communities................................................................................................. 12
2.5.4. Non-governmental Organizations (NGOs) stakeholders ............................................... 12
2.6. STAKEHOLDER ENGAGEMENT OBJECTIVES AND PRINCIPLES ........................................... 14
2.6.1. Communal objectives ........................................................................................................ 14
2.6.2. Operational objectives ...................................................................................................... 14
2.6.3. Key principles .................................................................................................................... 15
2.7. STAKEHOLDER ENGAGEMENT ACTIVITIES ........................................................................... 15
2.7.1 Considerations for the Engagement Process ......................................................................... 26
2.8. Culturally appropriate engagement ......................................................................................... 26
2.9. Monitoring Stakeholder Engagement Activities ..................................................................... 27
2.9.1 Review of Engagement Activities in the Field: ....................................................................... 27
2.9.2 Reporting Stakeholder Engagement Activities ...................................................................... 28
3. STAKEHOLDER ENGAGEMENT: PROJECT LIFE-CYCLE ................................................................. 28
3.1. Stakeholder Engagement and Project Cycle ............................................................................ 28
4. SEP Resources and Responsibilities ................................................................................................ 29
4.1. Resources ................................................................................................................................... 32
4.1.2 Training ..................................................................................................................................... 32
4.1.3 Budget ....................................................................................................................................... 32
5. GRIEVANCE MECHANISM ................................................................................................................. 33
5.1. Definitions and Grievance Procedure ...................................................................................... 33
5.2. Grievance Redress Process ....................................................................................................... 34
5.3. Community Level Grievance Redress Mechanism .................................................................. 34
5.4. Project Level Grievance Redress Mechanism.......................................................................... 35
5.5. Judiciary Level Grievance Redress Mechanism....................................................................... 37
6. MONITORING AND REPORTING ...................................................................................................... 38
6.1 Review of Engagement Activities in the Field ............................................................................... 40
6.2 Reporting Stakeholder Engagement Activities ............................................................................. 40
REFERENCES ............................................................................................................................................. 41
LIST OF TABLES
Table 1: Stakeholder Engagement Techniques ......................................................................................... 7
Table 2: Stakeholder Government Ministries ........................................................................................... 9
Table 3: Stakeholder Parastatals/Agencies............................................................................................. 10
Table 4: Stakeholder Engagement Activities........................................................................................... 16
Table 5: Stakeholder Engagement Communication Plan ....................................................................... 21
Table 6: Communication Channels .......................................................................................................... 26
Table 7: Grievance Redress Process at Project Level ............................................................................. 37
Table 8: Key Performance Indicators by Project phase ......................................................................... 38
LIST OF FIGURES
Figure 1: Project Map.................................................................................................................................... 3
1. INTRODUCTION
1.1. Overview
This document is the Stakeholder Engagement Plan (SEP) for the Network Reinforcement and Access
Project (the NRAP, referred to hereinafter as “the Project”).
The Government of the Kingdom of Eswatini intends to apply for a loan from the World Bank's
International Bank for Reconstruction and Development (IBRD) to finance the proposed Network
Reinforcement and Access Project (NRAP), hereinafter referred to as “the Project”.
The proposed development objective of the Project is to “Improve the quality and reliability of
electricity supply and increase access in the Shiselweni region of Eswatini”. The project seeks to: (i)
reduce transmission system interruptions; (ii) reduce distribution system interruptions; and (iii)
increase the number of households provided with electricity. As part of preparation for the Project,
Eswatini Electricity Company (EEC) is required to undertake and complete an Environmental and
Social Impact Assessment (ESIA) in accordance with the Eswatini Environment Act No. 5 of 2002, the
World Bank Environmental and Social Framework (ESF)1 and the World Bank Group Environmental,
Health and Safety Guidelines for Electric Power Transmission and Distribution.
1
http://pubdocs.worldbank.org/en/837721522762050108/Environmental-and-Social-Framework.pdf
1.2. Stakeholder Engagement Plan (SEP)
The SEP seeks to define a technically and culturally appropriate approach to consultation, disclosure
and grievance redress. The goal of this SEP is to improve and facilitate decision making and create an
atmosphere of understanding that actively involves project-affected people and other stakeholders
in a timely manner, and that these groups are provided sufficient opportunity to voice their opinions
and concerns that may influence Project decisions. The SEP is a useful tool for managing
communications between EEC and its stakeholders.
The Key Objectives of the SEP can be summarised as follows:
Managing costs: Effective engagement can help project EEC avoid costs, in terms of
money and reputation;
Managing risk: Engagement helps project EEC and communities to identify, prevent,
and mitigate environmental and social impacts that can threaten project viability;
Enhancing reputation: By publicly recognising human rights and committing to
environmental protection, EEC and financial institutions (World Bank) involved in
financing the project can boost their credibility and minimise risks;
Avoiding conflict: Understanding current and potential issues such as land rights and
proposed project activities;
Improving corporate policy: Obtaining perceptions about a project, which can act as
a catalyst for changes and improvements in EEC corporate practices and policies;
Identifying, monitoring and reporting on impacts: Understanding a project’s
impact on stakeholders, evaluating and reporting back on mechanisms to address
these impacts; and
Managing stakeholder expectations: Consultation also provides the opportunity for
EEC to become aware of and manage stakeholder attitudes and expectations.
Commitment is demonstrated when the need to understand, engage and identify the
community is recognised and acted upon early in the process;
Integrity occurs when engagement is conducted in a manner that fosters mutual
respect and trust;
Respect is created when the rights, cultural beliefs, values and interests of
stakeholders and affected communities are recognised;
Transparency is demonstrated when community concerns are responded to in a
timely, open and effective manner;
Inclusiveness is achieved when broad participation is encouraged and supported by
appropriate participation opportunities; and
Trust is achieved through open and meaningful dialogue that respects and upholds a
community’s beliefs, values and opinions.
Various stakeholder categories that may be affected by, or be interested in, the Project;
and
Specific individuals, groups, and organizations within each of these categories taking
into account:
The expected Project area of impact, that is the geographical area over which it may
cause impacts (both positive and negative) over its lifetime, and therefore the
localities within which people and businesses could be affected;
The nature of the impacts that could arise and therefore the types of national/local
government entities, NGOs, academic and research institutions and other bodies who
may have an interest in these issues.
In general, engagement is directly proportional to impact and influence, and as the extent of impact
of a project on a stakeholder group increases, or the extent of influence of a particular stakeholder
on a project increases, engagement with that particular stakeholder group shall intensify and deepen
in terms of the frequency and the intensity of the engagement method used. All engagement shall
proceed on the basis of what are culturally acceptable and appropriate methods for each of the
different stakeholder groups targeted.
Table 2 shows the potential role, interest and influence of each of the target audiences captured in
the Project in as far as the mandate, history of involvement, resources and authority in development
planning and decisions making are concerned.
Table 2: Stakeholder Government Ministries
Government
Stakeholder Involvement in the project Interest Influence
Ministry of Responsible for establishing the program
Natural implementing the access component.
Resources and Perform quality assurance and approve
Energy payments for completed house connections High Medium
Government parastatals/agencies
Stakeholder Potential Involvement in the project Interest Influenc
e
Eswatini Have the overall oversight and responsibility of
Environmental ensuring compliance to environmental and
Authority (EEA) social regulations by all organisations, persons,
companies whose actions and processes have a
potential environmental and social impact.
physically disabled
women-headed households
child/orphan-headed households
households below the poverty line, and
The youth
Discussions with the vulnerable/disadvantaged groups affected by the Project aim to provide
opportunities for ground investigation on potential social impacts as a result of the construction of
the transmission line, distribution line and associated substations in the Shiselweni Region.
To ensure that consultation with local communities is inclusive of disadvantaged groups,
presentations will be conducted in siSwati because many community members may be illiterate.
Where necessary, additional formats such as location sketches will be used to enhance
understanding. The assistance of community leaders will be needed to encourage effective
representation of Vulnerable /disadvantages groups in group discussions throughout the project
phases.
Prior to the commencement of stakeholder engagement activities, meetings shall be scheduled with
relevant traditional authorities, Civic Leaders, Community Representatives, Political leaders, Heads
of Government departments, Members of Parliament in the project area, representatives from NGOs
and CSOs, the Media and other Interested and Affected Parties (I&APs). The purpose of these
meetings shall be to refine the stakeholder engagement strategy so as to meet the requirements of
I&APs and ensure that future communication is effective and cognisant of social and cultural
sensitivities.
The objectives of engaging stakeholders during the ESIA process include the following:
Engaging vulnerable groups: An open and inclusive approach to consultation increases the
opportunity of stakeholders to provide comments on the proposed Project, and to voice their
concerns. Some stakeholders, however, need special attention in such a process due to their
vulnerability. Special measures will be considered to ensure that the perspectives of vulnerable
stakeholders are heard and considered.
Managing expectations: It is important to ensure that the proposed Project does not create or
allow unrealistic expectations to develop amongst stakeholders about proposed Project benefits.
The engagement process will serve as a mechanism for understanding and managing stakeholder
and community expectations, where the latter will be achieved by disseminating accurate
information in an accessible way.
Ensuring compliance: The process is designed to ensure compliance with both local regulatory
requirements and international best practice.
o One of the key outcomes of engagement should be free, prior and informed consultation of
stakeholders, where this can be understood to be:
o Free: engagement free of external manipulation or coercion and intimidation;
o Prior: engagement undertaken in a timely way, for example the timely disclosure of information
before a development is undertaken and/ or participation is sought with regard to the
identification of issues of concern; and
o Informed: engagement enabled by relevant, understandable and accessible information.
Scoping To meet key stakeholders and Meetings with key stakeholders Government
introduce them to the Project and ESIA to facilitate the broader Government
Engagement Process; stakeholder engagement parastatals/agencies
To disclose the Project in the public process Local/traditional
domain to all interested and affected Dissemination of engagement communities
stakeholders; materials (background Vulnerable/disadvant
To gather issues of concern and information document, posters, aged Groups
through this identify a list of potential media notices etc.) Non-government
impacts; Consultation on the proposed organizations (NGOs);
To consult key stakeholders on the Project and associated ESIA
next steps in the ESIA process; through meetings and
To generate feedback on the Draft workshops with identified
Scoping Report, including the scope, stakeholders. Details may
approach and key issues to be include:
investigated further for the ESIA. o Nature, purpose and
scale of the proposed
project
o ESIA & stakeholder
engagement process
Confirmation of issue
identification and feedback from
stakeholders;
ESIA To discuss the identified impacts and Dissemination draft ESIA Report Government
Disclosure proposed mitigation measures with to all stakeholders. Government
stakeholders allowing for their input; parastatals/agencies
and Copies of the ESIA report will Local/traditional
To provide stakeholders with the also be distributed in public communities
opportunity to comment on the Draft buildings in the vicinity of the Vulnerable/disadvant
ESIA report. site of the proposed project. aged Groups
Business Community
Availability of the draft ESIA Contractors &
Report will be advertised Contract Workers
through print and electronic Non-government
media for public review. organizations (NGOs);
o Identification of
revisions or additions
to the draft ESIA report
where necessary.
Formal Submission of final ESIA Report with Submission of the Final ESIA for World Bank
Submission comments incorporated from the ESIA approval.
of Final ESIA engagement and disclosure stage
Stage Objective Key Activities Target Stakeholder
Resettlement To share draft policy framework based Dissemination draft RPF to all Government
Policy on national legislations, current stakeholders. Government
Framework practices in the country and parastatals/agencies
(RPF) Environmental and Social Standards of Copies of the RPF will also be Local/project affected
disclosure the Bank and finalised based on distributed in public buildings in communities
and feedback and inputs the vicinity of the site of the Vulnerable/disadvant
stakeholder proposed project and uploaded aged Groups
consultation on EEC website. Business Community
Royal Krals and Chiefs
Availability of the draft RPF Regional
Report will be advertised administration office
through print and electronic Non-government
media for public review. organizations (NGOs);
Consultation on the draft RPF.
This will include:
o Identification of
impacts categories
based on preliminary
survey report and
possible entitlements
and eligibility criteria;
Key principles of
resettlement and broad
institutional
arrangement.
o Identification of
stakeholder concerns
and opinions on the
contents of the RPF;
o Involvement of
stakeholders in
assessing the
appropriateness of the
proposed resettlement
principles, impact
categories,
entitlements;
institutional
arrangement for
preparation and
implementation of RAP.
Assess adequacy of RPF during
ESIA and RAP preparation
Identification of revisions or
additions to the draft RPF where
necessary.
Resettlement To share draft RAP based on RPF and Dissemination of cut off date Project affected
Action Plan specific impact area as per designs and census survey of all affected Persons
(RAP) subsequently finalise based on through structured Other project affected
disclosure feedback and inputs questionnaire communities
and FGDs and community level Vulnerable/disadvant
stakeholder meetings facilitated by Chiefs aged Groups
consultation and Community Laison Officers Business Community
Dissemination of draft RAP to all Royal Krals and Chiefs
stakeholders. Regional
administration office
Use of Leaflets on non technical Non-government
summary of RAP and folk media organizations (NGOs);
for the project affected
Copies of the RAP will also be
distributed in public buildings in
the vicinity of the site of the
proposed project and uploaded
on EEC website.
Identification of revisions or
additions to the draft RAP
where necessary.
-Project brief
document
Ministry of Commerce Discussion on future plans of -Formal meetings May 2019
commercial and industrial
development -Email
Frequency
-Posters yet to be
Implementation steering determined
committee progress reports -Press Statements
Record discussions
-Project brief
document
Ministry of Health Project brief -Formal meetings Once Off
Discussion with the related
department on issues of -Email Yearly
health relevant to the
project. -Posters
Record discussions
-Press
Statements
-Project brief
document
Deputy Prime Minister’s Office Project brief -Formal meetings Frequency
yet to be
Disseminate technical -Email determined
information
-Posters
Record discussions
-Press Statements
-Project brief
document
Ministry of Tourism and Project brief -Formal meetings Frequency
Environmental Affairs yet to be
Disseminate technical -Email determined
information -Posters
-Project brief
document
Ministry Works and Transport Project brief -Formal meetings Frequency
yet to be
Allow group to comment – -Email determined
opinions and views
Build impersonal relation -Posters
with high level stakeholders
-Press
Site visits Statements
-Project brief
document
Eswatini Environmental Authority Project Brief and request for -Formal meetings January 2019
(EEA) categorization
-Email May 2019
Site visits
-Site visits September
Periodic compliance reports 2019
-Posters
Monthly
-Press Statements
-Project brief
documents
Town Councils of Nhlangano, Project Brief and discussion -Formal meetings May 2019
Hluthi, and Lavumisa of council procedures for
servitude acquisition -Email On-going
Compliance and Monitoring
meetings -Workshops
-Site visits
-Posters
-Press Statements
-Project brief
documents
Resettlement engagement
Meetings (Refer to RPF and
RAP)
Site visits
Resettlement engagement
Meetings
Swaziland Action Group Distribute non-technical -Formal meetings
Against Abuse (SWAGAA) information Frequency
Coordinating Assembly for -Email yet to be
NGO's (CANGO) Facilitate meetings with determined
Youth presentations and -Workshops
Organisation/Associations PowerPoint
Women -Site visits
Organisations/Associations Allow the group to provide
Organisations for their views and opinions -Posters
disabilities
Organisations for Request guidance on how to -Press Statements
prevention of Gender handle issues related to their
based violence and target groups as NGOs
Violence against Children especially the vulnerable
Organisations on HIV parties likely to be affected.
Organisations on labour
rights
Table 6: Communication Channels
a) Stakeholder database
b) Issues and Response table, and
c) Meeting records of all consultations held.
Moreover, the tool can be used to manage ongoing issues, and for stakeholder identification and
analysis processes.
2.9.2 Reporting Stakeholder Engagement Activities
Performance will be reviewed following the engagement sessions conducted in the field. In addition,
there will be opportunity to review and assess performance in-between the engagement sessions
depending on the level of feedback received from stakeholders during these periods.
Evaluation of performance will be assessed based on the extent to which the engagement activities
and outputs meet those outlined in this SEP. In assessing performance, the following will be
considered:
Materials disseminated: types, frequency, and location
Place and time of formal engagement events and level of participation including specific
stakeholder groups (e.g. women, youth, community leaders)
Number of comments received on specific issues, type of stakeholder and details of feedback
provided
Numbers and type of stakeholders who come into contact with the Project team by mail,
telephone and any other means of communication
Meeting minutes, attendance registers and photographic evidence
Comments received by government authorities, community leaders and other parties and
passed to the Project
Numbers and types of feedback and / or grievances and the nature and timing of their
resolution, and
The extent to which feedback and comments have been addressed and have led to corrective actions
being implemented.
Design/Plan: the process of ensuring that systems and components of the Project are
designed, installed, and maintained to prescribed / agreed requirements;
Stakeholder engagement within the project preparation and implementation process is critical for
supporting the project’s risk management process, specifically the early identification and
avoidance/management of potential impacts (negative and positive) and cost effective project
design.
Stakeholder engagement is an on-going process throughout the life of the project:
Planning/design (including disclosure);
Construction
Commissioning
Disclosing and consulting on the draft results of the ESIA process is an integral part of the
engagement process. Within the overarching ESIA engagement objectives, the specific objectives for
the ESIA phase are to:
Provide feedback to the stakeholders on the draft impact assessment and associated
management/mitigation measures
Gather stakeholder input on the impact assessment and outlined mitigation and
enhancement measures
The disclosure and consultation activities will be designed along with some guiding principles:
Owner’s engineer (Consultant) shall be recruited to provide institutional capacity and support to
the Project Implementation Unit (PIU) with: (a) overall project management and supervision
including procurement, design, contract management; and (b) oversee the overall implementation,
monitoring, and reporting of safeguards aspects such ESMPs, LMP, SEP and RAPs. After familiarizing
themselves with the project area through reading and consultations with the EEC Project Unit, the
consultants will design appropriate questionnaires intended for data collection at project location
levels. The consultant will design questionnaires for data collection from various households,
individual farm units, depending on the nature of information source. The RAP development, as well
as monitoring and implementation, will be done in close collaboration with all impacted households,
affected community members, chiefs, Royal kraal council members and other interested and affected
parties. The consultations will be on-going and an integral part of the project as set out in this RPF.
In order to advance the Project the PIU will work collaboratively with some of the EEC departments
and stakeholders such as (i) Commercial Services, (ii) Finance, (iii) Corporate Communication and
Marketing, (iv) Operations Division, (v) Corporate Services, (vi) MD’s Office.
The roles and responsibilities, their interest and potential influence, and the internal coordination
and communication arrangements are summarised below.
Internal Departments
Community Liaison Officers - EEC through the assistance of the Chiefs (Community Leaders) will
hire Community Liaison Officer who will be the direct contact for PAP in the local communities. They
will provide EEC with assistance during consultations, identification of PAPs, and conducting of
interviews, where required. The EEC considers the Community Liaison Officers to be an extension of
the PIU and therefore will be entitled to a stipend according to traditional practices for similar
community office bearers and therefore will not be salaried like the PIU staff.
4.1. Resources
The EEC Marketing and Corporate Communications (MCC) Department will be responsible for the
design proper implementation and monitoring of the SEP. This department is responsible for the
company-wide stakeholder management program at EEC. The MCC Manager will provide
management oversight of SEP and will work closely with Project Team Members for expertise in the
different functions required in the project. This is to ensure that the SEP is implemented in a
successful manner.
4.1.2 Training
All parties involved on the SEP will attend a workshop that will orient everyone about the Project
and appraise all individuals of responsibilities and reporting structures.
4.1.3 Budget
The Marketing and Corporate Department has an adequate standing budget allocated towards the
Stakeholder Management Program. This is a budget that, as when is necessary, will be supplemented
an increase or by other budgets related to the activities required for the SEP. Also, the HR Department
will be engaged to consider the extra staff hired and include in the EEC payroll database.
Contacts:
The Marketing and Corporate Communications Manager (Acting)
Name: Khaya Mavuso
Email: [email protected]
Contact: +268 2409 4170/ 7607 0038
5. GRIEVANCE MECHANISM
5.1. Definitions and Grievance Procedure
A grievance mechanism has been developed for potential use by external stakeholders. The aim of
the grievance mechanism is to achieve mutually agreed resolution of grievances raised by such
stakeholders. Labour related grievances shall be addressed in accordance with Section 9 of the
Labour Management Procedure (LMP) and Resettlement related grievance shall be addressed in
accordance with Section 12 of the Resettlement Policy framework (RPF).
This grievance mechanism ensures that complaints and grievances (see ‘definitions’ below) are
addressed in good faith and through a transparent and impartial process, but one which is culturally
acceptable. It does not deal with ‘concerns’ which are defined as questions, requests for information,
or perceptions not necessarily related to a specific impact or incident caused by a project activity. If
not addressed to the satisfaction of the person or group raising the concern, then a concern may
become a complaint. Concerns are not registered as a grievance but will be managed via the EEC
external communications plan.
Key definitions are as follows:
o Complaint: an expression of dissatisfaction that is related to an impact caused by the project
activities, which has affected (i) an individual or group adversely, (ii) the interests of an
individual or group and who wants a proponent or operator (or contractor) to address and
resolve it (e. g. problems related to dust deposition, noise or vibration). A complaint is normally
of a less serious nature than a grievance; and
o Grievance: a claim raised by an individual or group whose livelihood, health and safety, cultural
norms and heritage are considered to have been adversely affected (harmed) by a project activity
which, if not addressed effectively, may pose a risk to EEC operations (through stakeholder
actions such as access road blockages) and the livelihood, well-being or quality of life of the
claimant(s).
The grievance mechanism described in this section includes both complaints and grievances
(hereinafter referred to only as ‘grievances’).
Grievances raised by stakeholders need to be managed through a transparent process, readily
acceptable to all segments of affected communities and other stakeholders, at no cost and without
retribution. The grievance mechanism should be appropriate to the scale of impacts and risks
presented by a project and beneficial for both a proponent/operator and external stakeholders. The
mechanism must not impede access to other judicial or administrative remedies.
This grievance mechanism sets out the following steps to be taken to resolve grievances, the role of
different staff members involved and timeframes to reach a decision on grievances. The types of
grievances stakeholders may raise include, but are not limited to:
o Negative impacts on communities, which may include, but not be limited to financial loss,
physical harm and nuisance from construction or operational activities;
o Health and safety risks;
o Negative impacts on the environment; and
o Unacceptable behaviour by staff or employees.
It is critical that stakeholders understand that all grievances lodged, regardless of the project phase
or activity being implemented, will follow one single mechanism.
When a grievance is logged by the Social Standards Officer, The Social Standards Officer will
acknowledge the complaint, unless the issue is logged anonymously. If the issue is registered
anonymously it will be automatically referred to the head of the Project Unit. Upon registration, the
Social Standards Officer will refer the issue for resolution or mediation to relevant officials. The aim
is to resolve all grievances within four weeks. Any grievance which is not resolved within that
timeframe will be reported in detail in monthly Project Unit report and quarterly reports to the World
Bank. All other grievances will be aggregated to track trends for managerial response.
In principle, where the complaint is related to Swazi Nation Land, the Social Officer will seek to
mediate the situation through the community liaison officer. Where an issue related to deeded or
land on 99-year lease, the Social Standards Officer will liaise with the project unit to determine
proposed resolution.
The project level GRC shall resolve or reach a decision five (5) days from the date the complaint is
received. The chairperson of the GRC shall communicate the committee’s decision to the aggrieved
PAPs in writing and maintain a record of all decisions related to each case.
A committee of knowledgeable persons, experience in the subject area, shall be constituted at the
EEC to handle complaints that have not been addressed or resolved at the Project level in the impact
area or the project area corridor. The EEC level GRM shall be comprised of the following members:-
(a) General Manager, Chair person
(b) Legal Compliance Officer, Member
(c) Social Development Officer, Member
(d) Safety Health Environmental Risks and Quality Manger (SHERQ)
(e) PAPs Representative
The EEC level Grievance redress committee shall do everything possible to hear and determine the
issues within five (5) days from the date the case has been transferred to it from the GRC. The
chairperson of the GRC shall communicate the outcome to the aggrieved PAP(s) in writing. The GRC
shall maintain a record of all outcomes related to each case.
If the complaint is not resolved to the satisfaction of the aggrieved party, it will then be referred by
the EEC Secretary to the National Steering Committee (NSC). The NSC will be required to address the
concern within 1 month.
2
As regulated by Eswatini Energy Regulatory Authority Act, Electricity Act, and the Acquisition of Property Act.
Should measures taken by the National Steering Committee fail to satisfy the complainant, the
aggrieved party is free to take his/her grievance to the Ombudsman’s Office, and the Ombudsman’s
decision will be final. It is possible that for land issues, it would be advisable for the complainant to
take his/her issue to the Minister of Lands for a final pronouncement.
It is rare for a complaint to be unresolved after the Ombudsman’s decision or for MNRE’s resolution
to be taken further. However, on both cases, the very last resort will be at the Courts, or Land Court
for land disputes.
It is vital that appropriate signage is erected at the sites of all works providing the public with
updated project information and summarising the GRM process, including contact details of the
relevant Project Contact Person. Anyone shall be able to lodge a complaint and the methods (forms,
in person, telephone, forms written in English and SiSwati) should not inhibit the lodgement of any
complaint.
The Complaints Register will be maintained by the Social Standards Officer as the PCP, who will log
the: i) details and nature of the complaint; ii) the complainant name and their contact details; iii)
date; iv) corrective actions taken in response to the complaint. This information will be included in
EEC’s progress reports to the Bank.
The project level process can only act within its appropriate level of authority and where appropriate,
complaints will be referred on to the relevant authority such as those indicated.
Monitoring of the stakeholder engagement process allows the efficacy of the process to be evaluated.
Specifically, by identifying key performance indicators that reflect the objectives of the SEP and the
specific actions and timings, it is possible to both monitor and evaluate the process undertaken.
Two distinct but related monitoring activities in terms of timing will be implemented:
o During the engagement activities: short-term monitoring to allow for
adjustments/improvements to be made during engagement; and
o Following completion of all engagement activities: review of outputs at the end of engagement to
evaluate the effectiveness of the SEP as implemented.
A series of key performance indicators for each stakeholder engagement stage have been developed.
Table 8 shows the indicators, and performance against the indicators will show successful
completion of engagement tasks.
Phase
activities
Communities provided
feedback;
The identification of NRAP-related impacts and concerns is a key element of stakeholder engagement
that will occur over the complete NRAP life-cycle. As such, the identification of new concerns and
impacts as the ESIA and NRAP progresses will serve as an overall indicator for the utility of the
stakeholder engagement process.
In the ESIA Reports there will be a review of the engagement activities conducted; levels of
stakeholder involvement (particularly for affected communities, women and vulnerable
people/groups); the issues discussed and outcomes; and the extent to which stakeholder issues,
priorities and concerns are reflected in the ESIA Report, particularly with respect to mitigation and
monitoring strategies contained in the Environmental and Social Management Plan.
6.1 Review of Engagement Activities in the Field
During engagement with stakeholders the engagement team will assess meetings using a feedback
evaluation form or asking questions to participants, depending on the stakeholder group, to ensure
that messages are being conveyed clearly.
The engagement team will conduct debriefing sessions while in the field. This assesses whether the
required outcomes of the stakeholder engagement process are being achieved and provide the
opportunity to amend the process where necessary.
The use of engagement tools developed through the ESIA engagement including:
Stakeholder database;
Issues Log or Issues and Response table; and
Meeting records of all consultations held.
Moreover the tool can be used to manage on-going Project issues, and for stakeholder identification
and analysis processes.
Evaluation of performance will be assessed based on the extent to which the engagement activities
and outputs meet those outlined in this SEP. In assessing performance, the following will be
considered:
Materials disseminated: types, frequency, and location;
Place and time of formal engagement events and level of participation including specific
stakeholder groups (e.g. women, youth, community leaders);
Number of people attending public or formal meetings
Number of comments received on specific issues, type of stakeholder and details of feedback
provided;
Numbers and type of stakeholders who meet the Project team by mail, telephone and any other
means of communication;
Meeting minutes, attendance registers and photographic evidence;
Comments received by government authorities, community leaders and other parties and
passed to the Project;
Numbers and types of feedback and / or grievances and the nature and timing of their
resolution; and the extent to which feedback and comments have been addressed and have led
to corrective actions being implemented.
REFERENCES
Stakeholder Engagement Plan for Tonga
https://consultations.worldbank.org/Data/hub/files/consultation-template/review-and-update-
world-bank-safeguard-policies/en/materials/revised_factsheet_ess10_july_29_aki.pdf
ANNEXURES
4. Closing
All
ATTENDANCE:
The Chief’s Royal Kraal Chairman (Indvuna) welcomed EEC participants to the Meeting and
introduced all members of the Chief’s Royal Kraal Council and acknowledge the appointment
made by EEC specifically to address the council. The chairman requested EEC to introduce
themselves and Present.
2. Objectives of Meeting(NRAP Presentation)
2.1 Project Description
2.1.1 EEC informed the council that the Eswatini Network Reinforcement and Access
Project (Project) supports the Government of the Kingdom of Eswatini’s (GoKE)
goal of providing access to modern energy to all by 2022 as stated in the National
Energy Policy. Stated that the proposed NRAP will include construction of ≈87km
of 132 kV transmission line from Nhlangano II to Lavumisa with 2 new substations
at Matsanjeni and Lavumisa, and expansion works at the existing Nhlangano II
substation, and the 11kV Hluthi switching station that will be converted into a
20MVA 132/11kV substation.
2.1.2 EEC informed the meeting that the route of the transmission line is likely to
traverse over land belonging to community members which my result in temporary
or permanent displacement which the EEC shall address through inclusive and
participatory consultation with the affected persons or households and resettlement
and compensation will be done in accordance to a policy framework which shall
be shared and discussed with all stakeholders. EEC then mentioned that all efforts
will be made by the project as far as practicable to reduce the impact of
resettlement.
2.1.3 The EEC also told the meeting that there will be stakeholder engagement processes
following this initial meeting to share information, consult affected persons and
provide a mechanism for reporting grievances, concerns and any other issues
related to the project.
2.2.1 NRAP goal is to improve its network reliability and quality of supply to support
growing demand in the region. It will cover the electrical, civil and
electromechanical works, switchgear, and protection and control equipment thus
reinforcing weak segments of the distribution network installing control equipment
in key segments of the network.
2.3.3 The aesthetic and visual quality of the surrounding landscape of the project area
from the introduction of transmission towers
2.3.4 Soil erosion due to excavation activities when constructing substations;
2.3.8 Community safety and health from construction activities and labour influx in the
region;
2.3.10 Public nuisance such as noise, dust pollution etc., during construction activities.
2.4.1 Each Chief’s Royal Kraal is expected to appoint a Community Liaison Officer
(CLO) to facilitated continuous consultation with person affected by the project to
ensure that all stakeholders, particularly project affected households and
communities, vulnerable and disadvantaged people are involved throughout the
process of resettlement planning, implementation, and monitoring. The NRAP
shall deploy appropriate consultation methods while engaging the various
stakeholders, including: i) focus group discussions, ii) informal interviews and, ii)
public consultations. In each of these consultations, the NRAP’s Project
Implementation Unit shall ensure that everyone’s voice is heard, responded to,
recorded, and fully incorporated into the RAP.
The meeting was informed about the Project impact mitigation plan on
environment and social issues as follows;
1) The Resettlement impacts will be avoided or minimized
11) Project activities must be in accordance with policy and legislative framework
2.6.1 EEC informed the meeting of its commitments to; i) Climate Change Mitigation
& Adaptation; ii) Pollution Prevention; iii)Waste Management plans; iv) Risk
Assessment & Management; v) Sustainable Development; vi) Biodiversity
Protection; vii) Social impact mitigation
Approaches:
Avoid: The Company will (where practicable) avoid activities that could result in significantly
adverse impacts in a project area.
Prevent: The Company will prevent occurrence of adverse impacts on the environment during
project implementation.
Minimise: Where unavoidable, the company will reduce the degree or extent/ duration of the
adverse impact through immediate reaction.
Rehabilitate: The Company will restore affected project area zones to their original states
3. Discussion Feedbacks and Questions
3.1 Royal Kraals’ Feedback and Discussions
The comments and responses that came from the Royal Kraal leaders and
community members at large were invariably the same owing to the current poor
state of the network reliability and quality of supply service that these communities
experience frequently. Some of the comments that were made are as follows:
Figure 2: Initial stakeholder Engagement Meeting at Sihlahleni, Endlovini area under Zwide II Umphakatsi -
Ezikhotheni
4. Closing
4.1.1 The Royal Kraal Council chairman (Indvuna) closed the meeting with a word of
Appreciation to EEC on the engagement at the early stage of the project.
Dumisani Shongwe
Approved by: __________________________