SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 HIGHLIGHT How to design a Grievance The Grievance Mechanism is Mechanism that based on a survivor-centric responds to approach i.e., empowering Gender-Based the survivor of Gender-Based Violence by prioritizing their Violence? - rights, needs and wishes. This Learning from note provides an overview of South Sudan the Grievance Mechanism’s Palak Rawal setup and details for teams who might be considering implementing a similar Executive Summary mechanism in their projects. Given the pervasive nature of gender-based violence (GBV) in post-conflict settings and risks such as social norms around GBV leading to the underreporting of cases, the South Sudan Safety Net Project (SSSNP – P169274) implemented a GBV-sensitive Grievance Mechanism (GM) to effectively record and respond SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 to GBV cases, including project-related cases of Sexual The GM is a critical part of citizen engagement for social Exploitation and Abuse/Sexual Harassment (SEA/SH). protection delivery systems, aimed to make programs more The GM is based on a survivor-centric approach i.e., responsive and effective. While the GM is a mandatory empowering the survivor of GBV by prioritizing their requirement under ESS10 of the Environmental and rights, needs and wishes. This note provides an overview Social Framework (ESF) which applies to all World Bank of the GM’s setup and overview for teams who might be Investment Project Financing (IPF) on or after October 1, considering implementing a similar GM in their projects. 2018, the SSSNP GM goes beyond the minimum requirements to include additional comprehensive The SSSNP established an independent workflow within measures to deal with GBV cases. The GM draws on the the GM to deal with GBV grievances. This is based on guidelines given in the Good Practice Note on Addressing a multilayered institutional structure, which includes a SEA/SH in Human Development Operations. female GBV focal person in the primary level of the project committee. This note describes its reporting channels and workflow, as well as information sharing protocols. Key considerations for establishing a GBV-sensitive GM, as learned in SSSNP: • Develop an operational manual for GBV within the GM, including the workflow, forms, and codes of conduct to be followed. • Develop GBV-sensitive reporting channels and protocols and integrate that into the GM for safe, confidential, and ethical reporting of GBV incidents. • Embed the GBV-sensitive GM within existing community structures, while ensuring safeguards in place to protect the safety and well-being of the survivor. • Map the available GBV response services and referral mechanisms for use by survivors in project locations. • Provide regular training to all staff on GM, gender and GBV. • Provide capacity building and training to institutional structures on GM, including how to handle GBV grievances with confidentiality and adequate follow up. • Sensitize beneficiaries on the GM, GBV, standards of conduct, and how to seek redress for grievances. • Build an iterative approach to learn, document, and continuously refine the GM. -2- SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 I. Context Incidents of GBV tend to be ignored and underreported for various reasons. These include Gender-based violence (GBV)1 is highly prevalent survivors’ fear of stigma and backlash from the community, in South Sudan. About 65 percent of women and girls threat to safety, high rates of impunity, traditional beliefs face physical and sexual violence at some point in their life, that normalize violence, and reported cases being with the majority of them experiencing it for the first time mishandled by community elders as customary laws before they turn 18.2 In 51 percent of the cases, violence that are contrary to the well-being of survivors tend to is by an intimate partner, while in 33 percent of the cases, prevail. Additionally, statutory law in South Sudan does violence is perpetrated by a non-partner during military not expressly criminalize intimate partner violence (IPV)6. raids. Female members of the armed groups also report As a result, most cases of IPV are ignored in reporting.7 sexual, physical, and domestic abuse by fellow group Given these challenges, survivors have been reluctant to members.3 The legacy of decades of conflict perpetuates come forward and report incidents of GBV. violent behavior toward women and girls both inside and outside their homes. To amplify the positive impacts of safety nets, programs should be leveraged more GBV is a significant drain on human capital and systematically to prevent gender-based violence. poverty reduction in South Sudan and undermines A growing body of evidence finds that cash transfer the effectiveness of social protection programs. programs reduce violence against women and children, It undermines human capital by negatively impacting the even when the cash transfer was not designed with physical and mental health of women and their families. violence prevention in mind.8 Research also shows The economic costs of GBV, specifically lost productivity that safety nets are a powerful tool to deliver a range due to domestic violence, range from 1.2 percent to of benefits over and above income and consumption, 3.7  percent of global gross domestic product.4 GBV including health, nutrition, productivity, and well-being. has proven intergenerational impacts, where children To protect and amplify these positive impacts, safety nets who grow up witnessing violence are likely to become should be leveraged more systematically to prevent GBV perpetrators or survivors,5 thereby creating a vicious cycle and empower women. of human capital erosion. Box 1: What is a Survivor-Centric Approach? It is important that any GBV-prevention or response measure in a project, such as the GM, follows a survivor-centric approach. This means empowering the survivor of GBV by prioritizing their rights, needs and wishes. A survivor-centered approach helps to promote a survivor’s recovery and reinforce their capacity to make decisions for themselves, including about whether and which support services to access. It means ensuring confidentiality, informed consent, and access to good quality services, including health care, psychological support, security, and legal services as appropriate (refer to Box 3 for list of support services). -3- SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 All World Bank-financed projects have a Grievance and the capacity of existing mechanisms. Social protection Mechanism (GM) as an avenue for recourse. GM programs can consider three arrangements (or a hybrid) refers to processes or procedures to receive and facilitate to develop a GBV-sensitive GM: resolutions of concerns and grievances of project- affected parties.9 For GMs to be an effective recourse • Adapting the existing program GM to include the for beneficiaries who experience GBV in such settings, reporting of GBV grievances; or specific design and implementation features need to be incorporated that enable survivors to report cases of GBV • Linking the program GM with an existing external in a safe and supportive environment. mechanism (e.g., national GBV hotline) to handle the allegations; or While GMs are primarily designed to address project-related concerns, they can also be used • Building an independent channel and process within to refer survivors who report cases that are not the program GM for reporting of GBV-grievances, project-related.10 Given the pervasive levels of GBV either run by a specialized team within the program in South Sudan and the lack of adequate systems to or outsourced to a third party. address them, the project team went above and beyond the minimum requirements to provide support to all GBV Each arrangement has its own pros and cons, and cases, including those that are not project related. For different factors to be taken into consideration project related GBV cases, there are more resources and when deciding which approach to adopt. To choose steps deployed in the GM for case management, while for one of the three, the team should consider the needs and non-project related cases, the GM limits the process to capacity to effectively manage GBV-related complaints: referrals to service providers, followed by one follow-up before the case is closed. These processes have been • Adapting the existing program GM can provide an explained further in the follow sections. avenue to report GBV complaints, however without adequate training, sensitization, and processes for handling GBV incidents, the existing GM team may not be able to provide the right form of support to the survivors. Special protocols and training may II. GBV-Sensitive GM need to be developed to ensure survivors can come The GM is an important tool to ensure that forward without the risk of backlash, stigmatization, complaints are addressed in a timely, transparent, or re-traumatization. and sensitive manner. The World Bank’s Environmental and Social Framework (ESF) mandates that all World-Bank • Linking the program GM with an existing external financed projects have a GM to ensure the project-affected mechanism to handle GBV allegations might be communities have an avenue to raise their concerns and helpful in contexts with limited capacity and project receive appropriate response (refer to the technical note scope to integrate GBV-sensitive measures. However, on Grievance Mechanisms for SEA/SH in World Bank- it is important to consider the quality, capacity, and financed Projects). The GM is also an important feature of accessibility of any such mechanism. citizen engagement in social protection delivery systems, for programs to be responsive and effective. The choice • Building an independent channel and process run by of the appropriate GM to address GBV-related complaints specialized staff within the program GM can provide will depend on the level of risk of program-related GBV an appropriate avenue for recording and responding to GBV allegations in a survivor-centric manner. -4- SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 However, this might be resource-intensive and needs in increased stress and potential intimate partner violence. to be monitored for continuous improvement. Key risks identified by the project encompass, among others: (a) targeting of project sites by conflicting parties; (b) sexual exploitation by local authorities, influential community members and project staff during beneficiary selection; (c) sexual harassment by other beneficiaries and South Sudan Safety Net III.  project staff at the project work and payment site; (d) long Project distances that may need to be traveled to project work and payment sites; (e) lack of safety and security at the Launched in 2020, the South Sudan Safety Net project payment site; (f) intercommunal conflicts resulting Project (SSSNP) aims to provide temporary from joint implementation of activities; and (g) impacts income opportunities to selected poor and of the projects on gender dynamics and roles inside the vulnerable households, and to strengthen safety household due to improved position and welfare of the net delivery tools. The project is implemented by the women, potentially triggering GBV. Additionally, the United Nations Office for Project Services (UNOPS) and aggregation of beneficiaries within communities where has three main components: a) Labor-Intensive Public public works are undertaken may increase risks of SEA Works “Plus”, which includes cash transfers for poor and between project personnel and vulnerable members of vulnerable households for participation in labor-intensive the community. Experiences from the previous safety net public works (LIPW) to meet immediate consumption project demonstrated that greater effort was needed to needs and generate public goods, while the “plus” increase awareness, understanding, and information of sub-component involves sensitization and awareness on GBV and other gender issues among communities given key social and health topics; b) Direct Income Support, the sensitivities and social taboos around GBV issues.12 which includes unconditional cash transfers to poor and vulnerable households who lack alternate sources of income and are unable to participate in LIPW; and c) Strengthen Delivery of Safety Net Tools, which includes a biometric based payments mechanism, a fully functional management information system (MIS), and an efficient, transparent and accountable GM.11 The project is being succeeded by the South Sudan Productive Safety Net for Socioeconomic Opportunities Project (SNSOP) in 2023, which will carry forward the three core components. Considering the prevailing violence against women, particular efforts were made to mitigate immediate risks of GBV due to project activities. Participation in safety net programs can contribute to increased empowerment and reduced GBV by improving the welfare levels of households and their emotional well- being, and by helping women strengthen their bargaining power within households and communities. At the same GBV-sensitive GM awareness in Torit city time, shifting power dynamics due to access to greater income opportunities provided by safety nets can also result Source: UNOPS and World Bank -5- SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 While the project will not be able to fully alleviate IV. SSSNP GBV-Sensitive GM broader social risks related to GBV due to the magnitude and complexity of the problem, the i. Guiding Principles for GBV-related project has undertaken multiple approaches to tackle gender gaps and mitigate GBV-related grievances risks due to project activities. The team developed The SSSNP GM has three guiding principles for a gender mainstreaming action plan that looks at the dealing with all GBV-related complaints: entire project cycle and identifies opportunities for gender mainstreaming as well as GBV prevention, mitigation, • Safety and Well-Being: The safety of the complainant and response. Measures included supporting women’s should be ensured at all times. participation as wage workers; designating women as direct recipient of cash transfers; providing financial • Confidentiality/Anonymity: The confidentiality and literacy training; ensuring representation in local GM anonymity of the complainant should be ensured, structures through minimum 30% women members across and relevant details should only be shared with all project committees;13 awareness-raising campaigns to the documented informed consent of the person15 ensure buy-in and communicate potential project-related (refer to Annex 3). risks; introducing codes of conduct14 for participants on clear expectations for behavior and prohibitions against • Survivor-Centered Approach: The survivor’s choices, SEA/SH; and engaging and sensitizing the community needs, safety, and wellbeing remain at the center of to shift harmful gender norms. The project has also all actions and procedures. This approach is based on established specific measures to mitigate GBV in public the principles of: works, at payment sites, and in the community, such as by adapting the project cash plus modules and community ◊ Respect for the survivor’s choices, wishes, rights, engagement toolkit to integrate a GBV-prevention and and dignity throughout the process; response lens. ◊ Safety of the survivor being the utmost priority in Given the vulnerabilities that threaten women and all actions; girls’ well-being in South Sudan, a GBV-sensitive GM is essential in safety net programs. Operating in ◊ Confidentiality to give people the right to choose a context with such high levels of GBV entailed significant whom they will or not tell their story; risk to the project. Past assessments had also pointed to the lack of capacity of the GM to respond to GBV cases. ◊ Non-discrimination referring to equal and fair Therefore, on learning lessons from the country context treatment to all survivors regardless of their age, and similar models elsewhere, the GBV-sensitive GM nationality, race etc. under SSSNP was designed. ii. Institutional Structures for GM The SSSNP GM has a multilayered institutional structure: -6- SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 • Appeals Committee: The Appeals Committee (AC) responsible for handling grievances and complaints is the key structure in the GM; it is established before against AC members. the selection and registration of beneficiaries. The members of the AC are selected from the community • Community Supervision Teams: This is the and must not be project beneficiaries. They must only committee selected after the registration of be widely respected and deemed to have a positive beneficiaries. The Community Supervision Team influence in the community. Women must constitute (CST) comprises of members elected among the 50% of committee members to ensure women beneficiaries by beneficiaries. They are responsible beneficiaries are comfortable to raise complaints. for the day-to-day implementation of sub projects, A female GBV focal person is appointed for each providing oversight on all site activities, from AC (who is also an AC member) and is responsible attendance, tools management, and actual works to for handling all incidents of GBV, including Sexual the payment of beneficiaries, and conflict mitigation Exploitation and Abuse/Sexual Harassment (SEA/SH)16 and resolution. involving beneficiaries or other persons associated with the project (refer to Box 2). • Group Leaders: Group leaders are responsible for monitoring and supervising beneficiary activities and • Quarter Council/ Boma Development are instrumental in mitigating and resolving conflicts Committee: The Quarter Council/ Boma among beneficiaries on site at the group level. They Development Committee (QCDC/BDC) is an oversight are selected among the set of beneficiaries in the committee established by the Quarter Council/Boma LIPW work group. Group leaders are also responsible authority to which grievances that cannot be resolved for forwarding complaints that cannot be addressed by the AC are escalated. The QCDC/BDC is also at the group level to the CSTs and ACs. Note: The survivors can choose to access any of the above four community-based structures; however, the AC and the toll-free helpline remain the primary channels of reporting (as explained in the following section). There is a provision for each committee to escalate complaints to the level above if they feel that they cannot address the issues, particularly if it relates to the misconduct of someone in a particular committee, such as if a grievance is logged against a member of the AC, this would automatically be escalated to the BDM which is the committee that oversees the AC (refer to Annex 1 for more details). • Health, Safety, Social and Environmental on a weekly basis to collect grievance forms, enter (HSSE) Staff at UNOPS: There are 2 layers of information in the MIS, and provide on-site technical UNOPS HSSE staff. The first are specialists based in support and guidance to committee members as Juba who are the main liaisons with the World Bank; needed. To ensure that GBV or other sensitive they oversee the GM through a set of activities, grievances do not get ‘lost’, the HSSE officer uses such as generating monthly GM reports from the a checklist every time s/he collects forms to check Management Information System (MIS). The second whether there are any GBV/sensitive complaints that layer are field-based HSSE officers; they visit each AC need to be prioritized and entered immediately. -7- SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 • Project Manager: The Project Manager, who is a UNOPS staff, oversees the entire UNOPS team implementing SSSNP. This person is informed of a GBV case and provides oversight to the Juba-based HSSE specialist in its case management. Box 2: Role of GBV Focal Point in the Appeals Committee • Receive all GBV complaints from beneficiaries or those linked to the project • Notify the UNOPS HSSE Assistant of GBV incidents immediately after they occur or get reported regardless of whether the incident involves project personnel • Obtain consent from GBV survivors necessary for making referrals to the nearest service provider • Ensure utmost confidentiality (i.e., not share identifiable information about the case with anyone, including the chairperson of the committee or community leaders) in the handling of GBV grievances and information related to the incidents • Create awareness and sensitization among beneficiaries on GBV and SEA/SH matters • Ensure that the complainant is provided a safe and caring environment that upholds the principles of a survivor-centered approach • Provide reliable & comprehensive information on available services and support to survivors • Ensure that survivors of rape have access to medical care within 72 hours of the incident to access HIV/ AIDS post-exposure prophylaxis and/or emergency contraception iii. Process for GBV-related complaints 1. Through the community-based project implementation structures described above; or The SSSNP GM consists of two main channels for 2. Through the Lulu Care GBV helpline (run by an NGO)17. reporting all GBV-related grievances: -8- SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Figure 1. MIS workflow for GM Aimed to provide a step-by-step mechanism for registering and tracking grievances in the system. Source: SSSNP GM MIS Module Workflow (developed jointly by UNOPS and World Bank). -9- SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 The GM is designed to record all types of GBV For complaints reported through the helpline, trained cases in a structured manner. The process for response officers handle them once it is established that dealing with GBV complaints is divided into eight they do not wish to go to the AC. For complaints reported steps18, listed below: on the Lulu Care Toll free helpline, Lulu Care refers all SSSNP-related complaints to the UNOPS HSSE team. Step 1: Report Grievance Step 2: Record Complaint in the MIS There are two ways in which grievances related to GBV can be reported: the community-based structures, or the Once the complaint is reported (through both channels) toll-free helpline (run by the NGO Lulu Care). For complaints and received by the HSSE staff, they enter the grievance reported through the GM institutional structures outlined into the MIS using a specific GBV-submodule developed above, the GBV focal person records the details in the for the project GM’s MIS. When the information is entered GBV Incident Form without divulging personal identifier into the MIS, the system flags the incident on the dashboard details about the survivor. The GBV focal person is tasked and generates a unique GBV grievance reference number with maintaining the details of the grievance completely for tracking. Access to the GBV sub-module is restricted confidential and store the GBV Incident Report Forms in a to HSSE Personnel and the Project Manager. dedicated folder until the HSSE staff collects these forms and stores them in cabinets.19 Step 3: Obtain Information Sharing Consent The GBV focal person obtains the survivor’s informed consent by completing a GBV Information Sharing Consent Form (refer to Annex 3) before referring the survivor to the appropriate GBV support service.20 It is important to note that the choice to access the services ultimately resides with the survivor. Where the survivor does not provide informed consent for information sharing regarding their case, the GBV focal person provides the survivor with information about available services to allow the survivor to decide whether or not to access the services. Step 4: Referral Depending on the needs of the survivor, the GBV focal person, with the support of HSSE staff, identifies the appropriate GBV support services21 (refer to Box 3) to which the survivor is referred using the GBV consent form. Appeals Committee Help Desk in Yei If the complaint is not project-related, the process ends at providing referrals and one follow-up before closing Source: UNOPS and World Bank the case. If the complaint is project-related, the process provides a more in-depth case management support, as explained in the following steps. - 10 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Step 5: Notify Management outcome of the investigations, appropriate action is taken in line with the UNOPS and World Bank policies The GBV focal person ensures that all GBV incidents are and applicable legislation. If the GBV incident is linked reported to UNOPS immediately after they occur and to project activities, follow up ensures that the case is UNOPS notifies the World Bank of the incident within addressed and that measures to prevent recurrence of the 24 hours of receiving the report. The detailed information incident are established. sharing protocols are part of the project GRM Manual. Step 7: Close Step 6: Investigate and Follow-up Once the survivor has accessed the necessary services, Investigations may be conducted by appropriate investigations concluded and the survivor is satisfied with institutions in accordance with the survivor’s wishes. the outcome, the case is closed in the MIS. Where the alleged perpetrator is associated with the project, investigations are undertaken in line with the GM guidelines (refer to Annex 1). Step 8: Appeal The HSSE Specialist follows up on the incident to ensure The survivor is informed of the option to appeal before the investigations are concluded and survivors access closing the grievance. the necessary treatment or services. Depending on the Box 3: Types of GBV Support Services I. Health/Medical Treatment Legal Assistance III.  and Assistance (either traditional or formal) • Emergency contraception • Legal protection and assistance • Treat injuries • Prosecution, adjudication • Treat Sexually Transmitted Infections • Apply appropriate laws, hold perpetrators • Post-exposure Prophylaxis (PEP) accountable Case Management and Psycho- II.  Safe Space Assistance and Security IV. social Assistance • Physical safety • Emotional support (peer support) • Safe house or temporary housing • Skills training • Police report and investigation • Social reintegration, social support - 11 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 iv. Monitoring Mechanisms Monitoring is also done through the review and analysis of compiled grievance data to assess the overall efficiency of UNOPS, the implementing partner, monitors the the GM process, and the percentage of grievances lodged complaints and GM on a regular basis. UNOPS through the ACs. Additionally, this is done through the on continuous basis compiles all grievances as they are MIS dashboard and auto-generated reports, which helped reported from various project locations and a report is staff quickly assess performance and notice any red flags produced every month indicating a summary of the or delays, to take prompt action. Further, the Third-Party complaints and highlighting unusual and sensitive ones. Monitor engaged by the project undertakes periodic third- The project team also undertakes monitoring of the GM party monitoring and verification of the implementation on a monthly and quarterly basis and makes adjustments of the GM. As of March 2023, when the project closed, where necessary. Monitoring includes spot checks at it received a total of 7 GBV cases, which took an average the ACs during project activities such as payments and time of 1 to 2 months to close. The time taken is due to monthly GM reports. Key indicators for monitoring include the significant follow-up and case management support, the average time taken to resolve grievances, grievance to ensure the survivors received all possible support at documentation process and information handling. every stage. GBV Monitoring Data Recorded (further segregated by age & project location with details) GBV Grievances by Program & Status Percentage of Total Number of Resolved Number of Ongoing Type Number Grievances Grievances SSSNP-related Other Total v. Guiding principles for GM • Provide capacity building and training on GM, including how to handle GBV grievances with implementation confidentiality and adequate follow up, for AC members and GBV focal points. The trainings are The enhanced GM under the SSSNP has the delivered by the UNOPS staff, with refresher trainings following implementation guidelines: conducted biannually. • Embed the GM within existing community • Sensitize beneficiaries and communities on structures, building on traditional conflict resolution GBV to be able to use the GM to report cases. practices. However, ensure safeguards in place to Evaluation of the previous safety net project pointed protect the safety and well-being of the survivor. to the lack of action among beneficiaries to report GBV cases, due to the lack of awareness on what • Ensure 30% female representation in all constituted GBV and the perception of the GM not committees, particularly for the ACs. This will make being an appropriate medium for it. To resolve these it more likely that women feel comfortable enough to issues, the project conducted extensive awareness report GBV-related complaints. - 12 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 raising activities on GBV – what it entails, why it is communities, including information on available important seek support and how the project GM can health and other support services. provide support. • Map the available GBV response services and • Sensitize beneficiaries on the GM and on how referral mechanisms for use by survivors in project to seek redress for grievances. The project team locations by collaborating with World Bank-funded conducted awareness sessions at all levels, including ‘Provision for Essential Health Services Project’ and community outreach by UNOPS, posters during other partners with capacity in the field such as community meetings, and repeated messaging to United Nations Children’s Fund (UNICEF), United beneficiaries on reporting all forms of GBV, while Nations Population Fund (UNFPA). communicating the limitations of the project GM. The Lulu Care NGO also conducted extensive awareness • Engage World Bank and other GBV experts in project locations on how their helpline services to enhance the understanding on the links between work. safety net support and GBV, and incorporate any lessons learned to mitigate risks. • Develop GBV-sensitive reporting channels and protocols and integrate into the GM for safe, • Adopt lessons from the review of GM for confidential, and ethical reporting of GBV incidents. conflict-sensitive delivery of safety net interventions, including GBV risks.22 The • Pilot the training of GBV focal persons within findings and recommendations from a recent study the GM, supported by international GBV experts. will inform further planning and implementation of These focal persons increased awareness among the GM under SNSOP. While setting up a GBV-sensitive GM is not a linear process, following are the important building blocks in the South Sudan project, which constitute an iterative process: Establish separate Ensure female focal Information sharing Establish separate codes of conduct person in and confidentiality MIS workflow for GBV to deal with GBV cases the project committee protocols Representation Train all staff Sensitize beneficiaries Strengthen referral of women on GM, gender, GBV on GBV and GM pathways for GBV in project committees - 13 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 V. Lessons Learned beneficiaries receive referrals if they want them. Further, the project facilitates access to referral • Operating in a fragile environment means the services for survivors in project related GBV cases as context in each new project location needs to access is often limited with service providers being far be analyzed, assessing key risks in each location, from the communities.23 and incorporating that into the GM and GBV training for committee members and beneficiaries. This • The project adopted an iterative approach, using includes considering the accessibility and feasibility the lessons from each safety net project to of measures, such as what types of channels would improve the GM. The lessons from the South Sudan be easily accessible to the most vulnerable groups Safety Net and Skills Development Project (SNSDP) in the communities, or what type of system will be were incorporated in SSSNP, such as standardized feasible in a challenging and low-capacity country, trainings to all committee members on GM, gender, for instance, where digital tools cannot be leveraged and GBV, and the introduction of female GBV focal for monitoring data. points in all ACs. Similarly, the lessons from SSSNP will be used to refine the GM implementation under • A code of conduct for beneficiaries was SNSOP, such as introducing alternative channels of introduced, which is communicated during reporting to reach remote areas. registration and throughout the project (i.e., community meetings, LIPW sessions) that includes • To ensure that grievances are entered routinely into zero tolerance for violence. This was in response to the MIS, field-based staff have assigned one a case where the perpetrator and survivor were both day a week to the GM which has helped them beneficiaries and the project lacked the policies to stay on track. address it. In addition to the code of conduct, the project developed a policy on how to address GBV issues if the perpetrator is a beneficiary (refer to Annex 1). • The project also developed a code of conduct for committee members, which includes zero tolerance for violence, including SH/SEA. Similarly, the project has a policy on how to address GBV cases where committee members are perpetrators (refer to Annex 1). • Given the fragility, conflict, and violence context, it was very important to be clear that the project will not be able to address all GBV issues and does not have a mandate to do so as GBV has reached epidemic levels in South Sudan and the response to GBV requires a holistic approach. However, there are clear guidelines which ensure that regardless of whether the grievance is project-related, - 14 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Leaflets used for GBV awareness (English and Arabic) Source: UNOPS and World Bank - 15 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 VI. ANNEXES Annex 1 Process for complaints reported against committee members or project beneficiaries Step 1: Record incident the report, and informs them of the course of action to be undertaken by the leadership in the committee to which The GBV focal point of the committee ensures that the the accused member belongs. survivor is treated with respect and every effort is made to protect the safety and wellbeing of the survivor. Informed consent is obtained from the survivor prior Step 4: Investigation and Immediate Actions to recording details of the incident. Confidentiality is observed throughout the process. The GBV focal point or committee chairperson, through a confidential letter copied to the UNOPS Project Manager, notifies the suspect that investigations will be undertaken Step 2: Referral to GBV service providers to establish the facts in the matter. The investigation is conducted by the appropriate committee above the one The GBV focal point assesses the risks to the survivor and to which the member implicated in the incident belongs, where feasible, identifies the most appropriate service such as if a grievance is logged against a member of provider to whom they should be referred. Referrals are the AC, this would automatically be escalated to the made with the written consent of the survivor (refer to BDM which is the committee that oversees the AC. Annex 3). Where there is imminent risk of retaliation or Suspected perpetrators temporarily cease to participate the survivor’s safety is threatened, the GBV focal point in project activities, such as put on leave or not allowed prioritizes a referral to a safe space for the survivor. to participate in project activities until the investigation is complete, if their participation could result in interference with the matter or pose further harm to the survivor. Step 3: Notify Management The GBV focal point notifies the chairperson of the The UNOPS HSSE Specialist follows up on the incident respective committee in confidence immediately after a to ensure the investigations are concluded and survivors GBV incident is reported to the UNOPS HSSE Assistant to access the necessary treatment/services. Depending on record the case and enter it into the MIS. If the accusation is the outcome of the investigations, the committee takes against the chairperson, the chairperson of the committee appropriate action in line with the applicable project above and the UNOPS HSSE Assistant are notified. Only codes of conduct and/or applicable legislation. The necessary and non-identifiable information about the accused member may not be reinstated to the committee grievance is shared. After entering the information unless there is unequivocal and clear evidence that the in the MIS, the HSSE Assistant reports the case to the complaint is not well-founded, and the majority of the HSSE Specialist who in turn notifies the UNOPS Project investigating committee agree that the member should Manager, the relevant UNOPS Field Team Leader, and the be reinstated. World Bank of the incident, within 24 hours of receiving - 16 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Step 5: Resolution and Closure Step 6: Appeal: Once the investigation is concluded by the relevant The survivor is informed of the option to appeal before committee, parties and/or authorities and appropriate closing the grievance. action has been taken against the accused, details of the case shall be updated, and the case is closed in the MIS. - 17 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Annex 2 GBV Incident Report Forms The below form is used by the UNOPS HSSE personnel to report incidents to the Project Manager. CONFIDENTIAL GBV Incident Report Project / Office Report Date Reported By Title/ Role xxx I.DETAILS OF THE INCIDENT Incident Date Incident Time Incident Place Incident Class Category Class 1 Reportable Social II.IDENTIFICATION OF TYPE OF INCIDENT AND IMMEDIATE CAUSES Incident Type Descriptor Description of Immediate Causes of the Incident III. DETAILED DESCRIPTION OF THE INCIDENT IV.ROOT CAUSE ANALYSIS Root Causes Yes No Improper Planning ✓ Poor Maintenance ✓ Poor Supervision ✓ Poor Quality of Equipment ✓ No rules, standards, or procedures ✓ Lack of knowledge or skills ✓ Improper motivation or attitude ✓ Failure to comply with rules ✓ Other (specify) GBV - Economic violence ✓ V.RECOMMENDED ACTION/ CORRECTIVE MEASURES • Mitigation Measures Implemented/ Envisaged Responsibility Timeline Status ● UPDATE: RECOMMENDATION: - 18 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Whereas the below form is used by the GBV focal points at the ACs and Lulu Care to record details of the incidents from the survivors. Full name of the complainant (optional): Date of Birth (Approximate if necessary): Incident reported by: □Survivor □Family member □Friend □Caregiver/Guardian Date of interview (day/month/year): Time: Location: Date of incident: (day/month/year) Time: Location: Gender □ Male □ Female Is the client a person with disability? □ No □Mental □Physical □Both General area of residence (Do not specify physical address) Is the client an Unaccompanied Minor, Separated Child, or Other □ No □ Unaccompanied Minor Vulnerable Child? □ Separated Child □ Other vulnerable child Has the complainant sought any type of medical care? □ No □ Yes Account of the incident/Description of the incident (summarize the details of the incident in client’s words) Was money, goods, benefits, and / or services exchanged in relation to □ No □ Yes this incident*? Is the perpetrator known: □ No □ Yes If known, is the perpetrator associated with the project? □ No □ Yes □ Don’t know Is the client at risk of retaliation by perpetrator: □ No □ Yes How would you like the issue to be resolved? What actions would you like to take? When asking this question, make sure you don’t discourage anyone from making complaints and do NOT suggest a course of action on their behalf nor suggest any informal mediation. Would the complainant like to access available assistance (counseling, □ No □ Yes GBV case management service, etc.? Type of Referral Provided (tick all that apply) □ Case Management □ Medical/Health Care □ Safety and Security □ Legal and Justice □ Mental Health and Psychosocial Support □ Protection and Shelter □Other e.g. NFI/Food/Cash (specify) □ Yes (Enter detail) □ No Is the client willing to provide a contact number/ person for follow up? Incident Received by: Name: Position: Contact No: Date and Signature: - 19 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Annex 3 GBV Consent Form CONFIDENTIAL Consent for release of Information (This form should be read and clearly explained to the complainant that he/she can choose from the listed options) I, _________________________________________________________________, give (Indicate full names) my permission for ______________________________________________________ (Indicate names and position of project representative) to share information about the incident I have reported to them as explained below: ● I understand that by giving my permission I am agreeing to the sharing of the specific case information from my incident report with the appropriate service providers and/or other relevant parties; ● I understand that some non-identifiable information may also be shared for reporting purposes. Any information shared will ensure my confidentiality and anonymity so as not be specific to me or the incident and there will be no way for someone to identify me based on the information that is shared; ● I understand that the information shared will be treated with utmost confidentiality and respect and shared only as needed for reporting and to provide the assistance I request; ● I understand that releasing this information means that the service provider may come and talk to me; ● I understand that I have the right to change my mind about sharing information with the designated focal points or service providers listed below at any point in time. I would like information released to the following service providers: Yes No (Tick all that apply and specify name, service provider and/ or agency as applicable) Protection Services: Medical services: Psychosocial services: Legal assistance: Safe Space: Other(specify): Signature or Thumbprint of Complainant _________________ Date:_________________ Contact Number: _________________________________________________ Address: ______________________________________________________ - 20 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Annex 4 Additional Resources SSSNP GM Manual: A detailed document on the structures, processes, and roles in GM SSSNP GBV and GM Refresher Training presentation for Appeal Committee members SSSNP Updated MIS GM Tracking Module Workflow SSSNP Gender Action Plan: Identifies opportunities throughout the project cycle to mainstream gender issues in activities. SSSNP Project Appraisal Document SNSOP Project Appraisal Document - 21 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 Endnotes 1 Gender-based violence, or GBV for short, is the umbrella term for all forms of physical, sexual, emotional, and psychological violence that is based on socially ascribed (that is, gender) differences between men and women. It includes acts that inflict physical, sexual, or mental harm or suffering; threats of such acts; coercion; and other deprivations of liberty. These acts can occur in public or in private (2015 Inter-Agency Standing Committee Gender-based Violence Guidelines, pg. 5) 2 UNICEF. 2019. South Sudan GBV Briefing Note. South Sudan Country Office. https://www.unicef.org/southsudan/media/2071/file/UNICEF-South-Sudan-GBV-Briefing-Note-May-2019.pdf 3 UNICEF. 2019. South Sudan GBV Briefing Note. South Sudan Country Office. https://www.unicef.org/southsudan/media/2071/file/UNICEF-South-Sudan-GBV-Briefing-Note-May-2019.pdf 4 Renner LM, Slack KS. 2006. Intimate partner violence and child maltreatment: understanding intra- and intergenerational connections. National Library of Medicine. 5 Klugman, Jeni; Hanmer, Lucia; Twigg, Sarah; Hasan, Tazeen; McCleary-Sills, Jennifer; and Santamaria, Julieth. 2014. Voice and Agency: Empowering Women and Girls for Shared Prosperity. World Bank Group. Washington DC 6 Intimate partner violence, or IPV, refers to violence committed by a current or former spouse or partner in an intimate relationship against the other spouse or partner. While IPV can be experienced by men and women, women experience IPV at greater rates than men. 7 UNICEF. 2019. South Sudan GBV Briefing Note. South Sudan Country Office. https://www.unicef.org/southsudan/media/2071/file/UNICEF-South-Sudan-GBV-Briefing-Note-May-2019.pdf 8 Buller, Ana Maria; Peterman, Amber; Ranganathan, Meghna; Bleile, Alexandra; Hidrobo, Melissa; Heise, Lori. 2018. A Mixed-Method Review of Cash Transfers and Intimate Partner Violence in Low- and Middle-Income Countries. World Bank Research Observer. 9 World Bank. 2017. Environmental and Social Framework. 10 World Bank. September 2022. Good Practice Note – Environmental & Social framework for IPF Operations: Addressing Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) in Human Development Operations. 11 World Bank. 13 March 2020. South Sudan Safety Net Project Appraisal Document. 12 World Bank. 2020. South Sudan Safety Net Project – Project Appraisal Document. 13 The project has achieved 44% participation rates across committees. 14 In the Good Practice Note, a Code of Conduct (CoC) refers to a written document that sets out core principles and minimum standards of behavior with which project actors agree to comply on an individual basis, specifically in relation to a Bank-financed project. A CoC will usually be rolled out to individuals who are not covered by existing Behavioral Standards and who are engaged specifically for the project. Violation of the CoC may result in disciplinary action by an employer and may affect the worker’s ongoing employment. 15 The Good Practice Note mentions that Consent must be informed, based on a clear appreciation, and understanding of the facts, impli- cations, and future consequences of an action. In order to give consent, the individual concerned must have all relevant facts at the time consent is given and be able to evaluate and understand the consequences of an action. The individual also must be aware of and have the power to exercise the right to refuse to engage in an action and/or to not be coerced (i.e., by financial considerations, force, or threats). There are instances where consent might not be possible due to cognitive impairments and/or physical, sensory, or developmental disabilities. 16 Sexual exploitation refers to any actual or attempted abuse of a position of vulnerability, differential power, or trust for sexual purposes, including, but not limited to profiting monetarily, socially, or politically from the sexual exploitation of another (UN Glossary on Sexual Exploitation and Abuse 2017, pg. 6). Sexual abuse includes any actual or threatened physical intrusion of a sexual nature whether by force or under unequal or coercive condi- tions. Sexual abuse is a broad term, which includes a number of acts including rape and sexual assault, among others (UN Glossary on Sexual Exploitation and Abuse 2017, pgs. 5-6). Sexual harassment refers to any form of unwanted verbal, non-verbal, or physical conduct of a sexual nature with the purpose or effect of violating the dignity of a person, in particular when creating an intimidating, hostile, degrading, humiliating, or offensive environment. This may include any unwelcome sexual advances, or requests for sexual favors, and may take place through online activity or mobile communications as well as in person. - 22 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 17 The project partnered with the existing Lulu Care (NGO) GBV helpline. The helpline is an alternative reporting channel to be used by beneficiaries who do not wish to go to the AC. Though the focus of the hotline is GBV and SEA/SH complaints, it is expected that complaints falling under multiple categories will be received through this channel. Operationally, UNOPS (the implementing partner) has a signed MoU with Lulu Care, where UNOPS covers the cost of equipment and staff training. The World-Bank project pays for two staff members for this helpline. 18 There is a process for all other non-GBV complaints in the GM, however this note only captures the process for GBV complaints. 19 It is important to note that a third party may lodge a GBV complaint. If the survivor is an adult, the survivor’s consent is required to process the grievance. If the survivor is a child, following with the principle of ‘best interest of the child’, the survivor’s consent is not required to process the grievance. 20 To enable access to the support services, whenever operations start in a new location, the HSSE staff carry out a GBV referral services mapping, often in coordination with partners already present on the ground. This includes an assessment of the quality of these services and are readily available to the AC, particularly the GBV focal point, to help guide beneficiaries to the appropriate service. 21 GBV service provider is an organization offering specific services for GBV survivors, including survivors of SEA/SH, such as health ser- vices, psychosocial support, shelter, legal aid, safety/security services, etc. 22 The team analyzed GBV data collected from the field. This study developed several tools to facilitate the integration of GBV prevention, mitigation, and response into social safety net structures, specifically the cash plus modules and community engagement material. It also looked at different options for an alternative GBV-sensitive channel that does not rely on phone access and is more accessible to beneficiaries living in remote areas with low connectivity. 23 The project team has set aside a fund in every district to be used in a discretionary manner based on approval of the Juba-based team. It was envisioned to cover costs such as transportation or the fees that need to be paid at the police station to file a GBV report. - 23 - SOCIAL PROTECTION & JOBS | P  OLICY & TECHNICAL NOTE JUNE 2023 | No. 29 © 2023 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW Washington DC 20433 Telephone: +1 (202) 473 1000 Internet: www.worldbank.org This work is a product of the staff of The World Bank with external contributions. The findings, interpretations, and conclusions expressed in this work do not necessarily reflect the views of The World Bank, its Board of Executive Directors, or the governments they represent. The World Bank does not guarantee the accuracy of the data included in this work. The boundaries, colors, denominations, and other information shown on any map in this work do not imply any judgment on the part of The World Bank concerning the legal status of any territory or the endorsement or acceptance of such boundaries. 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