- Step 1: Engage Stakeholders and Partners
- Step 2: Assess risks and impacts
- Step 3: Develop code of conduct
- Step 4: Communicate and Train across your supply chain
- Step 5: Monitor compliance
- Step 6: Remediate violations
- Step 7: Independent review
- Step 8: Report performance
Grievance mechanisms are the cornerstone of collective bargaining. They allow workers to raise issues with employers without fear of reprisal. Workers without the protection of a collective bargaining agreement should also have ways to make anonymous complaints and should have whistleblower protections.
Your company should ensure that safe, accessible channels are available to workers to lodge complaints about any issue related to your code of conduct. Ideally, multiple channels should be available, such as through trade unions (if available), through supervisors, directly through management or directly to your company. Procedures for bringing a grievance to each available channel should be clearly explained at training sessions and posted at the worksite, in all applicable languages. When auditors and/or independent verification organizations visit worksites, workers should be encouraged to make known any complaints to them in a confidential setting.
Standard procedures should also be in place for handling and resolving complaints that are received through all channels. These procedures should be clearly explained and posted. The procedures should include protection of privacy and protection from reprisal for the person or group bringing the complaint, as well as a communications protocol to notify both the complainant and other affected stakeholders of the outcome of the grievance.
Establishing Effective Grievance Mechanisms
“Operation-level grievance mechanisms for those potentially impacted by enterprises’ activities can be an effective means … when they meet the core criteria of: legitimacy, accessibility, predictability, equitability… and transparency, and are based on dialogue and engagement with a view to seeking agreed solutions. Such mechanisms can be administered by an enterprise alone or in collaboration with other stakeholders and can be a source of continuous learning. Operational-level grievance mechanisms should not be used to undermine the role of trade unions in addressing labor-related disputes, nor should such mechanisms preclude access to judicial or non-judicial grievance mechanisms.”
Source: OECD, Guidelines for Multinational Enterprises, 2011.
Essential Components of a Company Grievance Mechanism (JPG; narrative description) (Source: International Finance Corporation. Good Practice Note, Project-Level Grievance Mechanisms for Affected Communities, March 2009)
In 2009-2010, the Corporate Social Responsibility Initiative (CSRI) at the Harvard Kennedy School examined pilot projects commissioned by the UN Special Representative on Business and Human Rights. These pilots were focused on testing grievance mechanisms involving business enterprises and communities in which they operate. The CSRI project resulted in a revised set of principles for effective grievance mechanisms:
- Legitimacy: Enabling trust from the stakeholder groups for whose use they are intended, and being accountable for the fair conduct of grievance processes;
- Accessibility: Being known to all stakeholder groups for whose use they are intended, and providing adequate assistance for those who may face particular barriers to access;
- Predictability: Providing a clear and known procedure with an indicative time frame for each state, and clarity on the types of process and outcome available and means of monitoring implementation;
- Equitability: Seeking to ensure that aggrieved parties have reasonable access to sources of information, advice and expertise necessary to engage in a grievance process on fair, informed and respectful terms;
- Transparency: Keeping parties to a grievance informed about its progress, and providing sufficient information about the mechanism’s performance to build confidence in its effectiveness and meet any public interest at stake;
- Rights-compatibility: Ensuring that outcomes and remedies accord with internationally recognized human rights;
- Dialogue and engagement: Consulting the stakeholder groups for whose use they are intended on their design and performance, and focusing on dialogue as the means to address and resolve grievances;
- Continuous learning: Drawing on relevant measures to identify lessons for improving the mechanism and preventing future grievances and harms.
Source: Piloting Principles for Effective Company-Stakeholder Grievance Mechanisms: A Report of Lessons Learned. Harvard Kennedy School Corporate Social Responsibility Initiative, May 23, 2011.
For additional research by CSRI and others, the SHIFT Project is a good source of information and guidance on operation-level grievance mechanisms.
Positive Impact of Grievance Mechanisms
The Fair Labor Association’s 2008 study, “How a Functioning Grievance Procedure May Positively Impact a Factory’s Performance” conducted surveys in 11 FLA member factories in Thailand and China to gather data on the impact of grievance mechanisms in place. In coupling these results with the Sustainable Compliance Self-Assessment Tool for factory managers, the FLA study found that when workers use a factory’s grievance procedure they are less likely to leave the factory for other work. Lower turnover rates have a positive impact on a factory’s operation through a higher percentage of production delivered on time. The FLA found further that better communication, documentation and transparency, and integration of workers into the factory’s grievance procedures were important components of a sustainable grievance policy.
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