Safeguards and Grievance Mechanism (GM), CEPF Project

Complaints can be made:

  • In-person: Complaints can be raised during community meetings or directly to project staff and project leaders.

  • Written: Complainants can submit grievances via letter or form to the project office or relevant government offices.

  • Phone/Email. Appropriate phone numbers and emails to receive complaints are listed in this page.

Objectives of the GM

The objectives of the GM are as follows:

  1. Ensure that the World Bank ESSs are adhered to in all project activities.

  2. Address any negative environmental and social impacts of all project activities.

  3. Resolve all grievances emanating from project activities in a timely manner.

  4. Establish relationships of trust between project staff and stakeholders.

  5. Create transparency among stakeholders, including affected persons, through an established communication system.

  6. Bolster the relationship of trust among the project staff and the affected parties.

First Level of Redress

  1. Receive Grievance:At the project level, all complaints should be received by the Executive Director. Complaints can be made in person, in writing, verbally over the phone, by email or any other suitable medium. Complaints can be filed anonymously. The point of receipt of complaints is listed below:

    Contact:

    Position: Executive Director

    Telephone: +1 410 227-7689

    Email address: info@ridgetoreefs.org

    Physical address: 7566 Main St Suite 106, Sykesville, MD 21784 

    All grievances received by Ridge to Reefs, Inc.  staff should be forwarded to the Executive Director within 24 hours of receipt. 

  2. Acknowledgement: All grievances will be acknowledged by telephone or in writing by the Executive Director within 48 hours of receipt and the complainant will be informed of the approximate timeline for addressing the complaint, if it can’t be addressed immediately. The Executive Director will seek to ensure the speedy resolution of the grievance. If the grievance cannot be resolved at this level, it is taken to the next level.

  3. Record: The grievance will be registered in the grievance log submitted by Ridge to Reefs, Inc., including relevant documents.

  4. Notification: Communication of the grievance as follows:

    If it is concerning the project, communication to the Executive Director at Ridge to Reefs, Inc.  

    Notification will also be made to the CEPF Regional Implementation Team (RIT) Manager and the CEPF Grant Director for the Caribbean Islands within 15 days.

    If it is concerning general Ridge to Reefs, Inc. operations/activity, communication to the Executive Director.

  5. Assessment: A decision is made on the nature of the investigation that will take place.

  6. Investigation: Appropriate investigation of the grievance by an internal team assigned to this task (for example, this may include staff directly involved as well as the Executive Director at Ridge to Reefs, Inc.). The investigation may include meetings with the complainant and other stakeholders and a review of relevant documents. An impartial party shall be involved in meetings with the complainant. Community representatives or representatives of the complainant will be allowed to sit in on these meetings. Minutes of meetings and documents will be added to the grievance file. 

  7. Resolution: Depending on the findings of the investigation:

    A resolution is decided immediately: 1) The complaint is rejected, 2) A response is agreed, 3) The complaint is referred to as appropriate

    A resolution cannot be achieved, and the case is presented to the CEPF RIT for further input (second level of redress)

  8. Communication: Once a resolution has been reached, the decision is communicated to the complainant in writing. Documents are added to the grievance file.

  9. Satisfaction: If the complainant is not satisfied with the response from Ridge to Reefs, Inc. , it can be taken to the second level of redress. At all stages, documents are added to the grievance file.

NB: The complainant may request that the issue be transferred to the second level of redress if he/she does not feel that the grievance is being adequately addressed by the Executive Director for Ridge to Reefs, Inc. 

Second Level of Redress

If claimants are not satisfied with the way in which their grievance has been handled at level one, they will be given the opportunity to raise it directly with the Regional Implementation Team, who can be contacted as follows:

Contact

Title: Manager of the Regional Implementation Team

Telephone: +1-868-638-6062, +1-868-674-1558

Email address: executive.director@canari.org

Physical address: #105 Twelfth Street, Barataria, Trinidad and Tobago

Third Level of Redress

If claimants are not satisfied with the way in which their grievance has been handled at level two, they can contact the CEPF Executive Director via the CI Ethics Hotline (telephone: +1-866-294-8674 / web portal: https://secure.ethicspoint.com/domain/media/en/gui/10680/index.html).

If the complainant does not accept the solution offered by the CEPF Executive Director, then the complaint is passed on to the fourth level. Alternatively, the complainant can access the fourth level at any point. It is expected that the complaint will be resolved at this level within 35 working days of receipt of the original complaint. However, if both parties agree that meaningful progress towards resolution is being made, the matter may be retained at this level for a maximum of 60 working days.

Addressing Gender-Based Violence: 

The specific nature of sexual exploitation and abuse and of sexual harassment (SEA/SH) requires tailored measures for the reporting, and safe and ethical handling of such allegations. A survivor-centered approach aims to ensure that anyone who has been the target of SEA/SH is treated with dignity, and that the person's rights, privacy, needs and wishes are respected and prioritized in any and all interactions. 

The sub-grantee will specify an individual who will be responsible for dealing with any SEA/SH issues, should they arise. The Grantee should assist SEA/SH survivors by referring them to Services Provider(s) for support immediately after receiving a complaint directly from a survivor. A list of SEA/SH service providers is available at the RIT’s page: https://canari.org/wp-content/uploads/2025/07/CEPF-II-GBV-Service-Providers-Dominica-2025.pdf and will be defined prior to the contracting of workers, will be kept available by the GBV trained individual, the Project Managers, Project Coordinators, and Social Specialists.  

To address SEA/SH, the project will follow the guidance provided on the World Bank Technical Note "Addressing Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) in Investment Project Financing Involving Civil Works". This Grantee will follow the official WB definitions described on the Technical Note as shown below:  

Sexual Abuse (SEA) is an actual or threatened physical intrusion of a sexual nature, whether by force or under unequal or coercive conditions

Sexual Exploitation (SE) 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.

Sexual harassment (SH)  is any unwelcome sexual advance, request for sexual favour, verbal or physical conduct or gesture of a sexual nature, or any other behaviour of a sexual nature that might reasonably be expected or be perceived to cause offense or humiliation to another, when such conduct interferes with work, is made a condition of employment or creates an intimidating, hostile or offensive work environment. 

Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH) service provider is an organization offering specific services for SEA/SH survivors, such as health services, psychosocial support, shelter, legal aid, safety/security services, etc. 

The survivor-centered approach is based on a set of principles and skills designed to guide professionals—regardless of their role—in their engagement with survivors (predominantly women and girls but also men and boys) who have experienced sexual or other forms of violence. The survivor-centered approach aims to create a supportive environment in which the survivor's interests are respected and prioritized, and in which the survivor is treated with dignity and respect. The approach helps to promote the survivor's recovery and ability to identify and express needs and wishes, as well as to reinforce the survivor's capacity to make decisions about possible interventions. 

SEA/SH grievances can be received through any of the available channels and will be considered as "High-profile grievances - that if not resolved promptly may represent significant risks to the environment or community". 

Additionally, if an incident occurs, it will be reported as appropriate, keeping the anonymity and confidentiality of the complainant and applying the survivor-centered approach. Any cases of SEA/SH brought through the sub-grantee will be documented but remain closed/sealed to maintain the confidentiality of the survivor. The RIT and the CEPF will be notified as soon as the designated persons from the sub-grantee organization learn about the complaint.

If a SEA/SH related incident occurs, it will be reported through the sub-grantee, as appropriate and keeping the survivor information confidential. Specifically, following steps will be taken once an incident occurs:  

ACTION 1: COMPLAINT INTAKE AND REFERRAL

If the survivor gives consent, the designated person responsible from the sub-grantee fills in a complaints form, excluding any information that can identify the survivor:

  1. The nature of the allegation (what the complainant says in her/his own words without direct questioning)

  2. If the alleged perpetrator was/is, to the survivor's best knowledge, associated with the project (yes/no)

  3. The survivor's age and/or sex (if disclosed); and, 

  4. If the survivor was referred to services

If the survivor does not want to provide written consent, their consent can be verbally received. If needed or desired by the survivor, the designated person responsible for the sub-grantee refers the person to relevant SEA/SH service providers, identified in the mapping of SEA/SH service providers and according to preestablished and confidential referral procedures. The survivor's consent must be documented even if it is received verbally. The service providers will be able to direct survivors to other service providers in case the survivor wishes to access other services. The designated person responsible for the sub-grantee will keep the survivor informed about any actions taken by the perpetrator’s employer. If the survivor has been referred to the relevant SEA/SH service providers, received adequate assistance, and no longer requires support; and if appropriate actions have been taken against the perpetrator or if the survivor does not wish to submit an official grievance with the employer, the designated person responsible from the Grantee can close the case.

ACTION 2: INCIDENT REPORTING 

The designated person responsible for the sub-grantee needs to report the anonymized SEA/SH incident as soon as it becomes known, to the RIT Manager who will in turn inform the CEPF. 

Complaint Forms and other detailed information should be filed in a safe location by the designated person responsible for the sub-grantee. Neither the designated person responsible for the sub-grantee nor the RIT Manager should seek additional information from the survivor.

SEA/SH incident reporting is not subject to survivors' consent but the designated person responsible from the sub-grantee needs to provide ongoing feedback to the survivor at several points in time: (1) when the grievance is received; (2) when the case is reported to designated person responsible from the sub-grantee and RIT Manager; (3) when the verification commences or when a determination is made that there is an insufficient basis to proceed; and (4) when the verification concludes or when any outcomes are achieved or disciplinary action is taken.

As long as the SEA/SH remains open the designated person responsible from the sub-grantee and/or RIT Manager should update the CEPF on the measures taken to close the incident. 

ACTION 3: GRIEVANCE VERIFICATION AND INVESTIGATION

Each SEA/SH incident should be verified to determine if it was related to the CEPF-funded project. The designated person responsible for the sub-grantee should form a SEA/SH verification committee comprised by her/him, one member of the sub-grantee organization, one member of a local service provider and a representative of the contractor (if relevant). The designated person responsible from the sub-grantee should notify the SEA/SH Committee of the incident within 24 hours of its creation. The SEA/SH verification committee will consider the SEA/SH allegation to determine the likelihood that the grievance is related to the project. 

If after the committee review, SEA/SH allegation is confirmed and it is determined that it is linked to a project, the verification committee discusses appropriate actions to be recommended to the appropriate party—i.e., the employer of the perpetrator, which could be the designated person responsible from the sub-grantee or a contractor. The designated person responsible from the sub-grantee will ask contractors to take appropriate action. The committee reports the incident to the perpetrator's employers to implement the remedy/disciplinary action in accordance with local labor legislation, the employment contract of the perpetrator, and their codes of conduct as per the standard procurement documents.

For SEA/SH incidents where the survivor did not consent to an investigation, the appropriate steps should be taken to ensure the survivor is referred to/made aware of available services and that the project mitigation measures are reviewed to determine if they remain adequate and appropriate or if they require strengthening.

If the survivor is interested in seeking redress and wishes to submit an official complaint with the employer, or with entities in SVG legal system, the designated person responsible from the sub-grantee should provide linkages to the relevant institutions. Ensuring due legal process is up to the police and the courts, not the SEA/SH verification committee. Unlike other types of issues, the designated person responsible from the sub-grantee does not conduct investigations, make any announcements, or judge the veracity of an allegation.

Any cases of SEA/SH brought through the sub-grantee will be documented but remain closed/sealed to maintain the confidentiality of the survivor. This will primarily serve to:

  1. Refer complainants to the SEA/SH Services Provider; and 

  2. Record the resolution of the complaint

The Grantee will also immediately notify both the CEPF and the World Bank of any SEA/SH complaints WITH THE CONSENT OF THE SURVIVOR.

CEPF also requires that all direct, contracted and community and community workers be provided with Conservation International’s (CI) Code of Ethics and be informed that any violations of the Code of Ethics should be reported to CI via its Ethics Hotline at www.ci.ethicspoint.com