external grievance mechanism

1. Introduction

The Grievance Mechanism is a non-judicial mechanism by which Wibra aims to ensure fair, timely and objective resolution to a grievance. It provides a platform for individuals and organisations to submit a grievance if they feel they have been negatively affected by Wibra’s activities. It draws upon the UN Guiding Principles on Business and Human Rights “Protect, Respect and Remedy” Framework for non-judicial grievance mechanisms.

2. Scope

Wibra will accept grievances that fall within the defined Wibra Grievance Mechanism scope, which outlines who can lodge a grievance and what the content and form of said grievance should be.

Content:

A grievance¹ should be:

  • a statement about a perceived or real wrong or unfair treatment,
  • related to Wibra behaviour and
  • factual and evidence-based.

Form:

The grievance should be lodged through the Wibra website’s Grievance Form. The submission should be as complete as possible and in English, unless otherwise agreed by Wibra, and should include any supporting documentation. The grievant should:

  • Provide sufficient information to demonstrate the relevance to Wibra of the stated grievance;
  • Suggest a remedy which is agreeable to the grievant or the affected parties;
  • Add supporting evidence when possible.

Grievances can be lodged by:

  • Wibra suppliers and their business partners;
  • Workers/employees that belong to Wibra’s supply chains;
  • Stakeholders², including third parties with explicit authority³ to represent a grievant.

Wibra reserves the right not to accept or to close a grievance investigation if:

  • The grievance is out of scope (in content, in form or in type of grievant);
  • Insufficient information is given to pursue an investigation (e.g. general, unspecified, and therefore un-actionable);
  • Information requested by Wibra is not submitted in due time;
  • Legitimacy to represent affected individuals or communities is not explicit and proven.

¹ This is different than a complaint, which is general expression of dissatisfaction.
² Individuals, communities or organisations that are affected by and/or may affect Wibra’s operations, activities, markets, industries, and outcomes;
³ Wibra reserves the right to determine the concerned third parties as legitimate to represent those individuals.

Confidentiality and data protection:

Wibra owes a duty of confidentiality to the grievant. All communication and procedural steps towards remediation will not disclose any sensitive or personal information. A grievant’s personal details will only be made available to Wibra employees or agents involved in the grievance process. Wibra complies with all obligations applicable under the EU General Data Protection Regulation.

3. Procedure

The key steps of Wibra External Grievance Mechanism procedure are summarised in flowchart and described below.

Step 1: Grievance submission:

The grievant shall submit the grievance to Wibra through the Grievance Form on the Wibra website. This form includes two blocks of information:

  1. Grievant’s details: including first and last name, email address, company/organization name and address and your function/position.
  2. Grievance details: including the reason of the grievance, previous attempts to solve the grievance and preferred remedy.

Step 2: Assessment:

Within 3 working days, Wibra will assess if the grievance falls under the predefined scope and decide whether or not the grievance is acceptable. The secretariat may contact the grievant for more details to be able to assess the acceptability of the grievance. If the grievant does not provide the requested information within 14 working days, the grievance will be not accepted, and the case will be closed.

  • If the grievance is accepted, the grievant will receive a formal acknowledgement and details of the next steps in the procedure.
  • If the grievance is not accepted, Wibra will inform the grievant of the reasons why the submitted grievance does not fall within the Grievance Mechanism’s scope. No appeal of the non-acknowledgement is possible.

Step 3: Investigation:

Within 20 working days of the date the grievance is accepted, Wibra will proceed to look into the circumstances of the case, speaking with the parties involved, and conferring with relevant stakeholders. The grievant may be contacted to contribute additional information.

Step 4: Final Decision:

Within 10 working days of the date the investigation has been concluded, Wibra will outline investigation findings, define remedial actions and communicate them to the grievant. The final decision should be reasonable, proportional to the grievance and consider cultural norms. It will
become final by the 10th working day after its communication to the grievant, unless the deadline is interrupted by an appeal on the way Wibra has handled the grievance. No appeal on the final decision is possible.

4. Monitoring and evaluation

Three months after the closure of the case, Wibra may contact relevant parties (if relevant), to verify that they have acted according to the agreed remedial actions.

Wibra will review the External Grievance Mechanism process where necessary to continuously improve the grievance handling procedure.

Consolidated statistical data on grievance cases will be posted on a yearly basis on the Wibra website.

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