Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697795347135.pdf (Dominica)
Dominica Housing Recovery Project Contractors Code of Conduct (CoC) What is a Code of Conduct?

• Set of rules outlining the norms, rules, and responsibilities or proper practices of a company.

• It contains the policies that relate to the legal and ethical standards of conduct that workers and partners must comply with while carrying out their duties and responsibilities on behalf of the company.

• Compliance with these principles is a condition of employment or engagement with a company or project.
Roles & Responsibilities • The Housing Recovery Project’s Implementation Unit is responsible for the coordination and implementation of the program, and will work closely with the Design & Supervision Firm.

• The Firm is responsible for ensuring that contractors are aware of and comply with the Code of Conduct (CoC).

Priorities during Construction • Assign responsibilities to your staff for the implementation of the ESMP guidelines and standards within the scope of works.
• Demonstrate social sensitivity to the demographic groups in the communities where the construction works will take place and maintain good community relations.

• Verify age and work permits of all construction workers in accordance with The World Bank’s regulations and guidelines.
Priorities during Construction • Prepare and submit reports as required by the Environmental and Social Management Plan which includes: • Installing appropriate signage • Ensuring traffic safety • Limiting work hours to daytime or daylight hours • Providing PPE to workers • Proper waste storage and disposal • Adequate toilet facilities for workers Prohibitions • Cutting of trees for any reason outside the approved construction area • Illegal dumping of demolition material and debris • Use of unapproved toxic materials, including lead-based paints, asbestos, etc.
• Disturbance to or removal of anything with architectural or historical value • Burning of waste/Open fires (or any outdoor fires) • Use of alcohol or narcotics whilst on the construction site • Use of child labor or forced labor • Sexual harassment of beneficiaries • Sexual relations with or physically abusive behavior towards beneficiaries • Sexual activities on the construction site • Gambling on the construction site • Carrying of deadly weapons including licensed firearms whilst on the construction site Code of Conduct & Connection to Complaints • Any violation or breach of the Code of Conduct can trigger a grievance or complaint by a project stakeholder.
• With the Code of Conduct being a guide to expectations of each contractor working with the project, it is imperative that it is maintained.

• The HRP has established a mechanism for managing complaints about all aspects of the project, including actions that are not in compliance with the Code of Conduct, and the consequences of not implementing the mitigation measures of the ESMP.
Dominica Housing Recovery Project Grievance Redress Mechanism (GRM) Definitions During the course of policy and project implementation concerns, complaints and disputes will arise.

• Grievance: • Distress expressed in the form of a complaint.

• Redress: • To set right, remedy by removing the cause of a grievance or making up for it.

• Dispute: • Two or more people confront over goals they perceive to be incompatible.

• Feedback: • Opinions on the performance of a project provided to those who run it.
They can be positive or negative Grievances What is the role of Feedback and Grievance Redress Mechanisms?

• A Grievance Mechanism is a system by which stakeholders of a project or a program can seek information and clarifications about the project and are responded to in a timely manner.

• A system in which, if problems arise out of implementation, these problems are communicated, tracked and are resolved in the most efficient manner.
• As in any dispute, project-related grievances may escalate if not redressed early.

What We Mitigate by Implementing a GRM Anxiety and Fear Lack of avenues to dialogue Distrust : feeling bypassed and not consulted with Anger and frustration HRP Grievance Redress Mechanism • The Project Implementation Unit (PIU) manages grievances and resolutions based on the HRP GRM document which includes administrative responsibility for the GRM, including the formation and management of a Grievance Redress Committee.
• The Grievance Redress Committee will address all complaints that could not be resolved at the local level with a clear process for decisions taken.

GRM Flowchart The diagram below describes the process that will be used to resolve any grievances: RECEIVE Complaint received through different channels captured or the MIS.

RECORD Grievance is logged by the PIU in MIS and gets a unique identifier code.

SCREEN Screening is done to determine the grievance category and level.
Grievance Owner is identified and assigned.

ACKNOWLEDGE The grievance is acknowledged within 2 working days of being submitted.

INVESTIGATE The investigation is carried out within 5-10 working days by Grievance Owner.

High level cases will take 10 to 20 days and will be managed by the Project Manager and IST.

Any meeting will be minuted and relayed back to the grievance owner who records in the system.
ACTIONS & COMMITMENTS An action plan is developed and communicated to complainant once all actions are completed.

FOLLOW UP & CLOSE OUT The Grievance Owner will contact the complainant 10-15 working days after the grievance was resolved to verify that the outcome was satisfied.

APPEAL If not satisfied, the matter will be escalated to the management team (HRP Project Manager and IST) who will review and decide on seeking advice from other independent parties including the Grievance Redress Committee.
The complainant must file a written appeal to the Grievance owner.

Logging a Grievance • Who?

• Anybody who is directly or indirectly related to the project who feels that they are being impacted can provide feedback to the PIU eg.

beneficiaries, community members, construction workers • How?
• Fill out the form on our website www.hrp.gov.dm • Call our office (767)616-9766 • Visit our office at 40 Old Street, Roseau, Dominica Encourage other stakeholders to use the Grievance and Complaints Logging System (GCLS) Jahna McLawrence Social Safeguards Specialist socialsafeguardshrp@dominica.gov.dm