FEDERATED STATES OF MICRONESIAPACIFIC REGIONAL CONNECTIVITYPROGRAM (ICT) Kosrae Component

Environmental and Social Management Plan

Grievance Redress Mechanism(Projects Complaint Process)June 2020

1. Principles of the Complaints Process (GRM)➢The Complaints process is for people seeking satisfactory resolution of their concerns
and/or complaints on the environmental and social performance of the East
Micronesian Cable Project based at the Department of Transport, Communications
and Infrastructure (DTC&I) at the FSM national government in the Federated States ofMicronesia (FSM) in conjunction with the FSM Telecom Cable Corporation.
➢ This Process is consistent with the Project’s Environmental and Social Management
Framework (ESMF), Environmental Management Plan (EMP) and projects Grievance
Redress Mechanism (GRM) and is directly related Kosrae ICT State project.
➢ The mechanism will ensure the following:• Basic rights and interests of every person affected by the projects environmental
performance or social management of the project are protected; and• Their individual concerns arising from the performance of the projects
environmental and social performance during the project phases of design,
construction and operation activities are effectively and timely addressed.

2. How to get in Touch with the Project
Anyone can ask for information on the project, express a concern, make a complaint(grievance) or get in touch with the project for any reason. Complaints/concerns can beanonymous and the various ways to get in touch with the project include:
National Contacts:
Department of Transport, Communications & Infrastructure (DTC&I)
All correspondence to: Assistant Secretary, Mr. Mark DeOrio.
1. By Phone: (691) 320- 2865
2. By
email:
mark.deorio@gmail.com
copytobeulah.FSM@gmail.com
andwkilmete@yahoo.com
3. By mail: Post Office Box PS-2, Palikir, Pohnpei, FSM 96941
4. In person: DTC&I Office National Government, Palikir, Pohnpei, Federated States ofMicronesia. Given to the Departments Office Secretary.
5. Website: www.ict.fm/contact
FSM Telecom Cable Corporation
All correspondence to: Mr Pieter Bakker, Chief Executive Officer and Mr. Gordon Segal ManagerOperations and Chairman Management Committee (EMCS).
1. By Phone: (691) 320- 2602
2. By email: pieter.bakker@fsmcable.com, gsegal@fsmcable.com orinfo@fsmcable.com copy to beulah.FSM@gmail.com and wkilmete@yahoo.com
3. By mail: Post Office Box 2202, Kolonia, Pohnpei, FSM 96941
4. In person: Ocean View Plaza (East Wing) Suite 15, Kolonia, Pohnpei, Federated

States of Micronesia. Give to the Office Secretary.
5. Website: www.fsmcable.com

Kosrae State Project Sites:All correspondence to: Mr. Gordon Segal Manager Operations and Chairman Management
Committee (EMCS).
Mr Segal will manager the project until a Kosrae project manager isappointed. This will be undertaken before the commencement of works.
1. By Phone: (691) 320-2602
2. By email: gsegal@fsmcable.com and copy to beulah.FSM@gmail.com andwkilmete@yahoo.com
3. By mail: Post Office Box 2202, Kolonia, Pohnpei, FSM 96941
4. In person: C/O Ocean View Plaza (East Wing) Suite 15, Kolonia, Pohnpei, Federated States ofMicronesia. Give to the Office Secretary.
5. Website: www.fsmcable.com
This information, and a brief summary of the process for answering queries and managing
grievances, will be published on the DCT&I, FSM cable and Department of Finance andAdministration (DoFA).

3. Roles and Responsibilities:
The following are persons involved in the complaints process and their supporting roles andresponsibilities.
➢ Focal Point for managing the FSM ICT projects Complaints Process: Mr. Gordon Segal,
Manager of Operations for the ICT cable Project (gsegal@fsmcable.com).
➢ Person who will manage the database and record keeping: Mr. Wilmer Kilmete in coordination
with Mr. Steve Lindsay and Ms. Beulah Daunakamakama at the Central Implementation Unit(CIU) of the FSM Government Department of Finance & Administration.
➢ Person who will answer simple queries and manage simple complaints: Mr. Gordon Segal,
Manager of Operations for the ICT cable Project (gsegal@fsmcable.com).
➢ Person who will manage difficult complaints or grievances: Mr. Gordon Segal, and/or Mr.
Pieter Bakker for the ICT cable project and Mr. Mark DeOrio, Acting Secretary DCT&I withsupport from CIU.
➢ Person/organization who will prepare report/s for World Bank reporting: CIU safeguard team.
➢ Grievance Committee will be formed on an ad hoc basis for complex or significant grievance
management. This will be made up of appropriate senior officials (Assistant Secretary level orabove) from the following:• Department of Finance & Administration (DoFA) with support from CIU Safeguards
Specialist; and• Department or Office managing the project at which the complaint is aimed (FSMTelecom Cable Corporation).

4. The Complaints Process:➢All complaints or grievances will be entered into an assigned database that tracks progress ofeach complaint/grievance. Complaints records (letter, email, record of conversation etc.) arestored both electronically and in hard copy. Each record has a unique number reflecting year
and sequence of received complaint (i.e. 2019-01, 2019-02 etc.).
➢ Each complaint/grievance is assigned a specific person responsible for its management andclose out.
➢ Each complaint or grievance will have a plan for addressing and closing out:
• If the complaint/grievance relates to a contractor activity, the project will ensure theContractor remedies any damage, pays compensation for damage or loss, etc.
• Use of community leaders and customary methods of conflict resolution is encouraged
and utilized if and when appropriate – on a case-by-case basis.

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If an issue/complaint cannot be resolved on site, it is elevated to the Project Manager forresolution (with support from the Safeguards Specialist in the CIU). If the ProjectManager and Safeguards Specialist cannot resolve the issue, it is referred to the ad hoc
Grievance Committee.
• If a resolution cannot be found through the Grievance Committee, the next course ofaction is the courts of FSM or an independent mediator.
All simple complaints and grievances must aim to be closed out within 1 month.
Complex complaints should aim to be closed out within 3 months or deferred to the GrievanceCommittee.
All complainants have the right to use the courts of FSM at any time to seek resolution, if andwhen required.
The ICT Project Manager will make adjustments to consultations, the GRM, community
engagement, project implementation and other aspects as necessary to avoid futurecomplaints and grievances if and when required.

5. Reporting and Evaluation:➢Complaints shall be reported in the regular project reporting to the World Bank. It should
contain:• Total number of complaints/grievances received.
• Total number resolved.
• Total number under investigation/not yet resolved.
• Total number not yet resolved and also exceeds the recommended close out time of 1
month or 3 months.
➢ Short paragraph on any significant grievances currently not yet resolved and any risks toproject implementation.
• If there are more than 30 complaints/grievances recorded, the Project Manager may
decide to investigate any patterns or repetition of issues that need addressing. The
Project Manager may decide to get an independent consultant to review and provide
advice.