Measures for Gender-Based Violence (GBV), Sexual Exploitation and Abuse, and Sexual Harassment (SEA/SH)

Posted in EARDIP

Commitment to Protection and Safety

The EARDIP upholds a zero-tolerance policy toward any form of Gender-Based Violence (GBV), Sexual Exploitation and Abuse (SEA) or Sexual Harassment (SH).

Proactive measures are in place to prevent, monitor, and respond to such incidents. Both GRMs will enable channels for grievances related to GBV and SEA/SH and will prioritise a survivor-centred approach.

Preventive Measures

• Codes of Conduct:
  All workers and contractors adhere to a Code of Conduct that outlines unacceptable behaviors and sanctions. Additionally, the internal WGM will supplement existing policies and procedures, namely EAC’s Governance Code, which outlines the below concerning Sexual Harassment:

All persons working for or affiliated to the decision-making processes of the EAC shall not sexually harass a member of the public or staff. Sexual harassment includes:

• making negative advances and pressure for sexual favours;
• making intentional or careless physical contact that is sexual in nature; and
• making gestures, noises, jokes or comments, including innuendoes, regarding another person’s sexuality.

• Training and Sensitisation:
  Regular training on GBV/SEA/SH for staff, contractors, and community members.
  
  
• Awareness Campaigns:
  Culturally appropriate IEC materials and community sessions to raise awareness about rights and reporting channels.

 
Survivor-Centred Approach for GBV and SEA/SH

The survivor centred approach will ensure safe, timely, and ethical responses to SEA/SH allegations from project workers and project affected workers to ensure appropriate response to a survivor’s complaint and respect the survivor’s choices.

The survivor’s rights, needs, and wishes will also be prioritised in every decision related to the incident to minimise further harm to the survivor and promote their well-being while appropriate measures are undertaken to address the perpetrator’s actions.

Specifically, the survivor centred approach for SEA/SH involves:

• Survivors are treated with dignity and respect, with their needs, rights, and choices prioritised.
• Support is voluntary — survivors receive assistance only if and when they choose to seek resolution.
• Survivors can change their minds at any point, and support will be adjusted accordingly.
• Survivors’ choices are respected, except in cases involving minors, where mandatory reporting laws apply.
• The Best Interest of the Child principle is upheld in all cases involving children.
• Survivor safety and security are top priorities, with efforts to prevent re-traumatization.
• All survivor data and information are handled with strict confidentiality.
• Informed consent is required before sharing a survivor's information with any third party.
• Survivors receive comprehensive information to make their own informed decisions.
• No assumptions are made about the survivor’s experience; all staff are trained to handle cases with cultural sensitivity, non-judgment, confidentiality, and tact.
  
  

Uptake of SEA/SH Cases

All designated grievance points at the EAC and EARDIP Project Implementation Unit (PIU) are open to receive and handle SEA/SH-related complaints. When a survivor reports a case, the information is recorded confidentially in a private setting, with full consideration of their vulnerabilities.

Key Confidential Information Recorded:

• Age and sex of the survivor
• Type of alleged incident (as described by the survivor)
• Whether the alleged perpetrator is linked to the project
• Whether the survivor was referred to a support service

If someone other than the survivor reports the case, the E&S Safeguards Specialist will encourage direct engagement with the survivor to ensure accurate and respectful handling.

Referral of SEA/SH Survivors

Survivors who report cases of Sexual Exploitation and Abuse or Sexual Harassment (SEA/SH) will be referred to appropriate support services, strictly with their informed consent, or that of a guardian in the case of children or persons with intellectual disabilities.

Referrals will be made based on the nature of the case, either to the EAC Legal Unit, the Project Grievance Management Committee (GMC), or to external GBV service providers in the following areas:

Available Support Services:

• Health:
  Medical examination and treatment, forensic evidence collection, post-exposure prophylaxis (PEP), or abortion services, where legally applicable.
  
  
• Legal/Justice:
  Legal counseling and support to navigate the justice system and ensure timely case resolution.
  
  
• Psychosocial Support:
  Emotional support, crisis counseling, and community reintegration assistance.
  
  
• Safety/Security:
  Protection of survivors and witnesses, investigation of incidents, and support in legal action against perpetrators.

The referral process prioritises survivor safety, privacy, and choice, ensuring a compassionate and coordinated response.

Project Grievance Redress Mechanism for Stakeholders

Posted in EARDIP

Purpose of the Project GRM

The Project GRM is designed to provide communities, stakeholders and other parties with a platform to raise concerns about project activities that may affect them directly or indirectly. It promotes community participation and enhances project accountability.

Target Audience

According to the EARDIP Stakeholder Engagement Plan (SEP) project-affected parties include, and are not limited to, the following stakeholders across EAC Partner States:

• Regulators and government authorities of Partner States
• Regional ICT regulatory associations
• EAC Secretariat
• Operators, services providers, and industry actors such as e-commerce firms
• Non-governmental organizations and civil society organizations
• Academic and research institutions
• International organizations and development partners
• Users and beneficiaries of ICT, including members of vulnerable groups, such as, but not limited to, persons with disabilities, women, ethnic minorities, and other marginalized populations.
  
  

Types of Grievances Handled

Complaints that may be submitted by project stakeholders and affected parties can relate to a wide range of issues including, but now limited to, for example:

• Non-compliance with measures and guidelines under the EAC EARDIP Environmental and Social Commitment Plan (ESCP),
• Exclusion of stakeholders from project activities,
• Disputes concerning data disclosure or procurement,
• Absence of or weak consideration of gender aspects in the implementation of activities, E
• Gender-Based Violence/Sexual Exploitation and Abuse in relation to interactions between project stakeholders/project affected communities and members of the project direct and contracted workforce.

How It Works

1. Submission:
   Complaints can be lodged through information channels such as Email messaging, EARDIP EAC PIU website, Social media, email messaging, conferences and workshops, Events, such as conferences and workshops, Third-party community partners, including government authorities, civil society, non-governmental organizations, and industry and the private sector.
   
   
2. Acknowledgment:
   All complaints are acknowledged within 48 hours.
   
   
3. Assessment:
   Each complaint is reviewed to determine eligibility and action.
   
   
4. Resolution:
   A resolution is provided within 30 working days, with regular updates to the complainant.
   
   
5. Appeal:
   If the complainant is unsatisfied, they can escalate the issue as may be guided.

 
Confidentiality & Non-Retaliation

The GRM guarantees the confidentiality of complainants and strictly prohibits any form of retaliation.

Workers’ Grievance Redress Mechanism

Posted in EARDIP

Purpose of the Workers’ GRM

This mechanism provides a confidential and responsive system for addressing concerns raised by the EAC EARDIP project workers , including direct and contracted labour. It ensures compliance with labour laws and promotes fair and safe working conditions.

Key Features

• Anonymous Complaints: Workers may file grievances without fear of retaliation or identity exposure.
  
  
• Accessible Channels: Grievances can be submitted via hotline, physical drop boxes, email, or in-person through designated focal points.
  
  
• Timely Processing: Grievances are acknowledged within 3 days and resolved within 15–30 days, depending on complexity.
  
  
• Appeals Process: Workers have the right to appeal decisions if they are not satisfied with the resolution.

Types of Grievances Addressed

The types of complaints by workers can include a range of issues such as, for example, those pertaining to:

• Terms and conditions of employment

• Unsafe or unhealthy working conditions
  
  
• Discrimination and unfair treatment, including recruitment and equal opportunity
  
  
• Harassment or abuse in the workplace, including workplace sexual harassment.

 
Roles and Responsibilities

This composition of the WGM for Project Workers ensures that the appropriate focal points within the EAC Project Implementation Unit (PIU) are included in terms of leadership and expertise in safeguards, while also availing a channel to a non-EARDIP focal point should that be desired by the project worker(s) submitting a complaint.

Overview of the Grievance Redress Mechanism (GRM)

Posted in EARDIP

What is the GRM?

The Grievance Redress Mechanism (GRM) is a structured and accessible process designed to receive, address, and resolve complaints and concerns related to the implementation of the Eastern Africa Regional Digital Integration Project (EARDIP). The GRM ensures transparency, accountability, and compliance with environmental and social safeguards by ensuring complaints from individuals or groups negatively affected by activities of the Project are addressed.

Objectives of the GRM

• Timely Resolution:
  Facilitate prompt and effective responses to grievances raised by stakeholders, including community members, workers, and vulnerable groups.
  
  
• Transparency & Fairness:
  Maintain a clear and equitable process to resolve issues at the lowest appropriate level.
  
  
• Stakeholder Engagement:
  Foster trust through continuous dialogue and ensure that all project-affected persons have a voice.
  
  
• Compliance Assurance:
  Ensure adherence to national laws and international standards including World Bank Environmental and Social Framework (ESF).

Scope of the GRM

This GRM is specific to EAC’s activities under EARDIP (SOP-I). The GRM covers all aspects of the Project, including environmental impacts, labour and working conditions, community health and safety, data privacy, and risks of gender-based violence and harassment.

As part of EARDIP, EAC will establish two (2) distinct GRMs that are proportional to the scope of project activities and linked with its Environmental and Social Commitment Plan (ESCP). The GRMs are:

• An internal-facing Worker Grievance Mechanism (WGM) for all direct and contracted workers engaged in relation to the project to raise workplace concerns, including sexual harassment; and

• An external-facing Project Grievance Mechanism (PGM) covering Stakeholder Engagement and Information Disclosure.

Who Can Use the GRM?

• Community members affected by project activities
• Project workers and contractors
• Government agencies and partners
• Vulnerable or marginalized populations