REPUBLIC OF KENYA

MINISTRY OF TRANSPORT, INFRASTRUCTURE, HOUSING AND

URBAN DEVELOPMENT

State Department of Housing and Urban Development

Kenya Informal Settlements Improvement Project II
KISIP II

STAKEHOLDER ENGAGEMENT FRAMEWORK

(SEF)

Disclosure Copy

November, 2019

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Document Version and Status

Version Date Author Purpose of Issue

1.0 September 2019 MoTIHUD Proposed Stakeholder Engagement

Framework in support of KISIP II project
activities; for World Bank review and
stakeholder consultation.

2.0 October 2019 MoTIHUD Revised Stakeholder Engagement

Framework in support of KISIP II for
World Bank review.

3.0 November 2019 MoTIHUD Revised Stakeholder Engagement

Framework incorporating RSA comments,
in support of KISIP II for World Bank
review.

4.0 November 2019 MoTIHUD Approved Stakeholder Engagement

Framework (SEF) for Public Disclosure

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Abbreviations
RPF Resettlement Policy Framework
CBO Community Based Organization
CLO Community Liaison Officer
EMCA Environmental Management and Coordination Act
ESIA Environmental and Social Impact Assessment
ESHS Environmental, Social, Health and Safety
ESMP Environmental and Social Management Plan
ESMS Environmental and Social Management System
FBO Faith Based Organization
FPIC Free Prior Informed Consent
IAP2 International Association for Public Participation
HoS Head of Safeguards
KISIP Kenya Informal Settlements Improvement Project
IFC International Finance Corporation
NEMA National Environmental Management Authority
NGO Non-Governmental Organization
NMK National Museums of Kenya
RAP Resettlement Action Plan
RPF Resettlement Policy Framework
SEF Stakeholder Engagement Framework
STD Sexually Transmitted Disease
UNDRIP United Nations Declaration on the Rights of Indigenous Peoples
VMGF Vulnerable and Marginalized Groups Framework

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List of Tables
Table 1: Phased Engagement Program
Table 2: Roles and Responsibilities
Table 3: Generic KISIP Stakeholders
Table 4: Definitions for Stakeholder Analysis and Mapping
Table 5: Principles of Goals of KISIP Engagement
Table 6: IAP2 Spectrum
Table 7: Methods, Tools and Techniques for Stakeholder Engagement
Table 8: Summary of Stakeholder Concerns to Date
Table 9: Planned Stakeholder Engagement Activities

Appendices
APPENDIX 1: Key Stakeholder Profile
APPENDIX 2: Community Liaison Planning Form
APPENDIX 3: Stakeholder Contact Report
APPENDIX 4: Vulnerability Screening Checklist
APPENDIX 5: Stakeholder Commitments Register
APPENDIX 6: Grievance Redress Tools

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DEFINITIONS
For the purposes of this Framework, the following definitions apply:
Communications: Communications refers to the range of channels and format used to disseminate
consistent and relevant project information to different audiences. The purpose of project
communication is to broadly build awareness and support but can also be used to promote
milestones, keep people informed of progress and delivery as well as respond to public and media
enquiries.
Engagement: Engagement is a planned process with the specific purpose of working with
individuals and groups to encourage active involvement in the project. The term engagement is very
broad and the purpose of engagement will be defined for each specific project phase. Engagement
refers to the range of opportunities stakeholders and the community have to participate in the
project. This ranges from educating individuals or groups about a project; obtaining community
feedback at a key project stage or milestone; or working collaboratively with stakeholders to address
local issues.
Engagement can also be referred to as public participation. The International Association of Public
Participation’s (IAP2) core values of public participation include promoting sustainable decisions by
recognizing the interests of all decision-makers; actively facilitating the involvement of those
potentially affected by or interested in a decision; providing participants with the information they
need to participate in a meaningful way; and communicating to participants how their input affected
the decision.
Community: A community is a group of people who have a relationship or a shared interest. Some
examples of communities include:
▪ A community of place is a group of people who are connected by the area they live, work
and/or visit. This could include a community who live in the same street, neighborhood or
suburb; a community who work in the same building; or businesses located in a particular
activity center.
▪ A community of interest is a group of people who have a shared interest, for example the
natural environment, local history or contemporary art.
▪ A community of affiliation are a group of people who are members of the same group or
club, for example members of a sporting club, Rotary or church.

Public: Public refers to members of the general public who may not belong to a specific
community relevant to the project but they still have an interest in the project.
Stakeholders: Persons or groups who are directly or indirectly affected by a project as well as those
who may have interests in a project and/or the ability to influence its outcome, either positively or
negatively. They may include locally affected communities or individuals and their formal or
informal representatives, national or local government authorities, politicians, religious leaders, civil
society organizations and groups with special interests, the academic community, or other
businesses.

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Stakeholder Mapping: The process of identifying a project’s stakeholders.
Grievance: An issue, concern, problem, or claim (perceived or actual) that an individual or
community group wants a company or contractor to address and resolve.
Grievance Mechanism: A locally based, formalized way to receive, assess, and resolve stakeholder
complaints about the performance or behavior of project proponents, including its contractors or
employees.
Vulnerable Groups – persons who may be disproportionately impacted or further disadvantaged by
the project(s) as compared with any other groups due to their vulnerable status, and that may require
special engagement efforts to ensure their equal representation in the consultation and decision-
making process associated with the project(s).

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Executive Summary
This SEF is part of the suite Safeguards Frameworks developed for KISIP II and covers all Project
activities that require engagement with local communities and other stakeholders. It covers sub-
project conceptualization, feasibility studies, planning and Environmental and Social Impact
Assessment (ESIA), Resettlement Action plans, grievance redress, construction and later operations
phases.
The Stakeholder Engagement Framework (SEF) is designed to ensure effective engagement with
local communities and other key stakeholders throughout KISIP II life cycle. This SEF supports
sub-project conceptualization, feasibility studies, planning and impact assessment processes,
implementation, and operational and maintenance phases of the project. TKISIP II will maintain
dialogue with the relevant regulators and locally affected communities and their representatives as
well as non-government organizations (NGOs), community-based organizations (CBOs) and other
interest groups.
This Stakeholder Engagement Framework (SEF) is underpinned by the Kenya’s policy and legal
framework which guarantees the right to information and public participation. It is also supported
by the World Bank Policies on Stakeholder engagement and participation in projects. The
Constitution of Kenya (2010) Article 1(2), 10 (2), 33,35,174, 174 (d), 184, 232,37 refer to public
participation. Other relevant Kenyan Legal framework in the County Government Act (2012),
Environmental Management Coordination Act (EMCA), 1999 and the Urban Areas and Cities Act
(2011) among others. The World Bank’s Operational Policy OP 4.01 section 14 on Institutional
Capacity, section 15 on public consultations and section 16 to 19 on disclosure.
Consultations for KISIP I were held in 2010 as part of project preparation while Consultations for
KISIP II were done in October 2019. More specifically, during the update of the preparation of the
Environmental and Social Management Framework (ESMF) and Resettlement Policy Framework
(RPF), preparation of Stakeholder Engagement Plan (SEF) and Vulnerable and Marginalized
Persons Framework (VMGF).
A Summary of the issues / concerns from stakeholders ranged from; Adequate involvement of
diverse stakeholders, capacity building of the SEC / GRC, enhancement of Livelihood Restoration
Initiatives offered by KISIP, ensuring that infrastructure constructed by KISIP are well operated
and maintained, reviewing Project designs to ensure they include community needs including needs
of the vulnerable, improvement of information disclosure, more support to vulnerable persons and
community Training on safety awareness. Record of the Stakeholder Consultation is presented as
Annex 1.

The Stakeholder Engagement Framework will be periodically revised and updated as necessary in
the course project implementations in order to ensure that the information presented herein is
consistent and is the most recent, and that the identified methods of engagement remain appropriate
and effective in relation to the project context and specific phases of the development. Any major
changes to the project related activities and to its schedule will be duly reflected in the SEF.

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Table of Contents
1.1 Background ........................................................................................................10
1.3 Objectives ..........................................................................................................10
1.4 Scope.................................................................................................................11
1.5 Roles and Responsibilities .....................................................................................12
1.6 KISIP’s Policy Requirements .................................................................................14
1.7 Project Components ............................................................................................14

2.0 Policy, Legal and Institutional Framework for Public Participation ................................. 17
2.1 Kenya’s Legislative Framework ..............................................................................17
2.1.1 The Constitution of Kenya, 2010 ........................................................................17
2.1.2 The County Government Act (2012) ...................................................................18
2.1.3 Environmental Management Coordination Act (EMCA), 1999 ................................19
2.1.4 The Urban Areas and Cities Act (2011) ................................................................20
2.2 World Bank Standards ..........................................................................................21

3.0 Stakeholders Identification and Analysis ..................................................................... 23

3.1 Project Stakeholders ............................................................................................23
3.2 Stakeholder Identification .....................................................................................23
3.3 Generic KISIP Stakeholders ..................................................................................24
3.4 Stakeholder Categorization ....................................................................................26
3.4.1 Affected Parties ...............................................................................................26
3.4.2 Interested Parties .............................................................................................27
3.5 Stakeholder Analysis.............................................................................................27
3.6 Vulnerable Groups ..............................................................................................29
3.6.1 Identification of Vulnerable Groups .......................................................................29
3.6.2 Monitoring Changes to Vulnerability ......................................................................30
3.6.3 Differentiated Engagement Measures .....................................................................30
3.7 Indigenous Peoples ..............................................................................................31

4.0 Stakeholder Engagement .......................................................................................... 32

4.1 Principles and Goals of Engagement .......................................................................32

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 4.2 Engagement Guidelines and References (IAP2 Spectrum) ..........................................33
4.3 Engagement Methods and Tools ............................................................................34
4.4 Past Stakeholder Engagement for KISIP I ...............................................................46
4.6 Planned Engagement with Affected Communities and Parties ..........................................50
4.7 Stakeholder Engagement Process .................................................................................59
4.8 Measures to Improve Stakeholder Engagement ........................................................59

5.0 Disclosures ............................................................................................................ 60

5.1 Disclosure of ESMF, RPF, and SEF .......................................................................60

6.0 Grievance Mechanism ............................................................................................. 61

6.1 Worker Grievance Procedure.................................................................................64

7.0 Outreach Approaches .............................................................................................. 64

7.1 Project Tours ......................................................................................................64
7.2 Citizen/PAP Perception Survey .............................................................................65
7.3 Trainings and workshops ......................................................................................65

8.0 Monitoring, Evaluation and Reporting ...................................................................... 66

8.1 Monitoring and Reporting .....................................................................................66
8.2 Monitoring Indicators...........................................................................................66
8.3 Information Sharing .............................................................................................67

9.0 Implementation Budget ........................................................................................... 67

References .................................................................................................................... 68
APPENDICES ............................................................................................................ 69
APPENDIX 1: Key Stakeholder Profile.......................................................................... 69
APPENDIX 2: Community Liaison Planning Form ......................................................... 71
APPENDIX 3: Stakeholder Contact Report ................................................................... 73
APPENDIX 4: Vulnerability Screening Checklist ............................................................ 74
APPENDIX 5: Stakeholder Commitments Register ....................................................... 76

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1.0 Introduction
The Government of Kenya is in consultation with the World Bank for consideration of the Kenya
Informal Settlements Improvements Project II (KISIP II) to consolidate the gains made under
KISIP I and enhance the benefits of the project to more people in informal settlements. This
Second Kenya Informal Settlements Project (KISIP II) will build on the successes and lessons
learned from KISIP1, but also introduce new interventions to deepen its overall impact. It will
support the interventions that have been successful under KISIP I: tenure regularization,
infrastructure upgrading, and institutional strengthening. In addition, the project will include
activities to link vulnerable people (elderly, orphans, disabled, and others) of informal settlements to
government programs aimed at reducing poverty and vulnerability, and to link at-risk youth to
programs focused on building skills and creating opportunities for employment and self-
employment. KISIP II will include activities to prevent crime and violence.
The proposed project objective is to enhance access to basic services and improve tenure security in
urban informal settlements in Kenya. This will be achieved by investing in infrastructure based on
plans developed in consultation with the community, by supporting planning, surveying and
issuance of land documents for residents of informal settlements, and by strengthening capacity of
county administrations to deliver on their mandates. KISIP II will have a wider coverage beyond the
fourteen KISIP I Counties, to potentially cover the whole country1.
1.1 Background
The Stakeholder Engagement Framework (SEF) is designed to ensure effective engagement with
local communities and other key stakeholders throughout KISIP II life cycle. This SEF supports
sub-project conceptualization, feasibility studies, planning and impact assessment processes,
implementation, and operational and maintenance phases of the project. TKISIP II will maintain
dialogue with the relevant regulators and locally affected communities and their representatives as
well as non-government organizations (NGOs), community-based organizations (CBOs) and other
interest groups.
1.3 Objectives
The broad objectives of this SEF are to:
a) Describe the applicable regulatory and/or other requirements for disclosure,
consultation and engagement with the Project’s stakeholders;
b) To enable identify elaborately different stakeholders including their roles and develop an
approach for reaching each of the sub groups
c) Identify, analyze and prioritize key stakeholder groups, focusing on Project directly
affected local communities;
d) To provides an appropriate approach for consultations and disclosure of Project information
throughout the project cycle.
e) To plan for engagement modalities and provide effective communication tools for
consultations and disclosure of Project information at the

1
For a more detailed project description, refer to the Project Appraisal Document

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 f) Provide a transparent and inclusive strategy, action plan and timetable for disclosure of
information, ensuring that engagement with each group is undertaken without any form
of discrimination;
g) Describe the processes for implementing stakeholder engagement and community liaison
activities, including any special measures for engaging with vulnerable groups and
integration of this SEF into KISIP’s wider management systems;
h) Establish an effective grievance mechanism, ensuring that stakeholders are properly
informed of their rights and know how to communicate their concerns;
i) Determine roles, responsibilities in project consultation, communication and information
disclosure;
j) Define monitoring and reporting procedures; and
k) Ensure continuous improvement.

1.4 Scope
This SEF is part of the suite Safeguards Frameworks developed for KISIP II and covers all Project
activities that require engagement with local communities and other stakeholders. It covers sub-
project conceptualization, feasibility studies, planning and Environmental and Social Impact
Assessment (ESIA), Resettlement Action plans, grievance redress, construction and later operations
phases.
KISIP engagement principles and goals, and the IAP2 Spectrum have driven the development of a
phased approach to engaging with community and stakeholders on the sub-projects. The table
below sets out the six phases, engagement objectives and engagement outcomes.
Table 1: Phased Engagement Program
Engagement objectives Engagement outcomes
Phase 1: Project preparation- Design, Phase

a) Raise public awareness and understanding of a) Community and stakeholders

planning,

the project and early engagement understand and appreciate the

b) Raise public awareness of the project and project benefits and impacts
approval process. b) Framework for participation
ESMF, RPF, SEF disclosure.

c) Inform community members of how they established. the project and are
can be involved. motivated to be involved.
resettlement

d) Gather inputs for project design process and c) Project design improved for
obtain feedback from stakeholders and the better outcomes
community. d) Stakeholder input and
e) Raise public awareness and understanding understanding of the project
about the project benefits and outcomes impacts and mitigation
scoping,

f) Participation in the project impact measures.

assessments and mitigation measures e) Approvals obtained
g) To obtain relevant approvals

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 3: Phase 2: Construction and mobilization a) Engagement to support works, procurement a) Multiple communications
and property acquisition channels and opportunities
b) Support landowners and tenants through the provided for stakeholders and
land acquisition process the community to ask questions
c) Establish clear processes for notifying about the project and raise
stakeholders and the community about issues.
potential impacts from works, including a b) Community and stakeholders are
transparent complaints management process aware of the project benefits,
d) Engage with and provide advance notice to timing and impacts
local businesses, residents, road and public
transport users about works
e) Support the detailed design work undertaken
by the appointed construction contractors,
and activities

including providing opportunities for

stakeholder and community input and
feedback
a) Support the transition from major works Community and stakeholders are
delivery to operation and maintenance. aware of the project’s completion
b) Engage with and provide advance notice, and understand how the new
maintenance

including direct contact where required, to infrastructure will operate.

Operation

local businesses, residents, road and public Community and stakeholders have
Phase

transport users about operation of the new the opportunity to take part in
infrastructure. celebrating project achievements.

1.5 Roles and Responsibilities

This section outlines the general roles and responsibilities for KISIP and the contractors in relation
to communications and stakeholder engagement.
Table 2: Roles and Responsibilities
Organization Responsibilities

KISIP a) Set the strategic direction for and oversee communications and
stakeholder engagement activities for the Project.
b) Review communications and engagement plans and materials prepared
by contractors to support the engagement approach
c) Develop and implement communications and engagement campaigns
that increase awareness and understanding of the Project, and build
relationships with key stakeholders, and encourage public participation
d) Manage media and government relations.
Contractors a) Prepare and implement a Community and Stakeholder Engagement
Management Plans in line with EPRs and this Framework.
b) Establish and maintain effective relationships with local residents,
businesses and stakeholders along the project corridor, wherever works
are taking place

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 c) Provide timely and relevant information to the community and relevant
stakeholders about the works, including milestones, design and
construction impacts
d) Manage and respond to public enquiries, feedback and complaints
concerning the works consistent with the Grievance Redress mechanism
in the RPF.
County a) Identifies Priority Investments Jointly with KISIP Office
Governments b) Provide linkage with other sectoral agencies /stakeholders at county
level
c) Undertakes EIA / RAP Studies and prepare project Designs
d) Mobilizes community to participate in project development
Community a) Provide linkage with other sectoral agencies /stakeholders at community
Settlement level
Executive b) Participate in monitoring activities of contractors and
Committees consultants

Settlement a) Resolving disputes that may arise from the PAPs;

Grievance Redress b) Monitoring and evaluating the ARAP process at the grassroots level
Committee

The KISIP National Coordinator has overall responsibility for ensuring the establishment and
maintenance of good working relationships between KISIP and its diverse stakeholders. On a day-
to-day basis, general responsibility is discharged by the Head of Safeguards section. More
specifically, the RAP team is responsible for engagement with affected communities during the
implementation and monitoring of the resettlement and livelihood restoration processes.
Upon mobilization of the Safeguards team [ proposed to include: Head, Community Liaison Officer,
Environment Officer, Grievance officer, RAP Officer etc2.], the Head of the section will oversee the
Community Liaison Officer (CLO) and has responsibility for communicating the stakeholder
engagement strategy internally and for the integration of team activities with other core functions
(i.e. ESHS including RAP aspects, Human Resources and Security), including the Project
Management Contractor and contractors in any of their dealings with local communities and their
representatives. The CLO will be devoted to managing and implementing KISIP’s stakeholder
engagement programme, including screening of vulnerable individual stakeholders’ / stakeholder
groups. The CLO’s duties, as part of the Safeguards team’s responsibilities are defined throughout
this document.
All communication with the communities will be channeled through the CLO. Should contractors
receive a communication directly, they should notify the CLO who will log and determine
appropriate action as per the process. With regard to communications received directly by the CLO,
the CLO will inform the contractors’ community representatives of any issues they deem

2
To be finalized once the institutional and reporting structure is finalized, the final SEP will include
the adopted overarching structure.

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appropriate. The services of specialist stakeholder engagement practitioners (e.g. an NGO to
provide HIV/AIDS community awareness training) and/or consultants may also be needed from
time to time.
Irrespective of the experience and qualifications of the CLO, this SEF requires some initial
awareness raising and skills training for the community relations, focusing on the World Bank
requirements and the various methodologies being implemented as part of KISIP impact
assessment/mitigation plans (e.g. in influx assessment, local hiring policy, vulnerability screening /
human rights, community participatory monitoring programmes, disclosures and engagement
planning /monitoring/ evaluation, grievance procedures and continuous improvement).

1.6 KISIP’s Policy Requirements

KISIP has defined its environmental and social policies in the Environmental and Social
Management Framework (ESMF), Resettlement Policy Framework (RPF), and Vulnerable and
Marginalized Groups Framework (VMGF) to manage the associated environmental and social risks
and impacts in accordance with the principles of sustainable development, applicable legal
requirements, relevant international standards and recognized good practice.
KISIP recognizes the importance of developing and maintaining mutual respect and trust with its
stakeholders, particularly local communities, and will inter alia:
a) Treat all stakeholders with respect, and dignity whilst taking due account of their views,
traditions and cultural heritage;
b) Gain and maintain broad community support for the Project, through informed consultation
with its stakeholders on any issues that may have a material bearing on their cultural heritage,
lives or livelihoods, protecting community health and safety through raising awareness and
minimizing the potential for communicable or vector-borne diseases;
c) Keep communities and other stakeholders materially informed of sustainability performance
through periodic disclosures and on-going engagement activities; and
d) Establish and implement an appropriate grievance mechanism for the effective handling and
resolution of any concerns, complaints or grievances expressed by local communities or
other external stakeholders in regards to the sub-projects.
KISIP also intends that its engagement with stakeholders shall be consistent with international
practice and particularly the World Bank’s Operational Policy OP 4.01 section 14 on Institutional
Capacity, section 15 on public consultations and section 16 to 19 on disclosure.
1.7 Project Components
Stakeholder engagement will apply to project components and activities. The proposed project will
comprise the following four components.
Component 1: Integrated Settlement Upgrading
Two main interventions have been identified under this component: (i) tenure regularization; and (ii)
infrastructure upgrading.

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Tenure regularization
KISIP2 will support the chain of activities required to regularize tenure for people living on
uncontested public lands. These activities include: (i) development of a local physical plan for the
settlement which lays out land parcels and infrastructure (roads, etc.); (ii) surveying with physical
placement of beacons (pegging) to demarcate the parcels as per the plan; (iii) preparation and
issuance of letters of allotment based on the survey plan; and finally (iv) issuance of titles.
Infrastructure Upgrading
KISIP2 will support the same types of investments: roads, bicycle paths, pedestrian walkways, street
and security lighting, vending platforms, solid waste collection and settlement sorting, stormwater
drainage, water and sanitation systems, public parks, and green spaces. The menu will also include
investments related to prevention of crime and violence, including but not limited to community
centers.
Component 2: Socio-Economic Inclusion Planning
This component will support the development of community-level socio-economic plans. The plans
intend to identify together with the communities their socio-economic needs and then address how
best the needs can be met. These plans will determine activities that will take place in new or existing
community centers and will also determine how best to raise awareness on the benefits of public
spaces and green zones, and proper solid waste disposal and how to provide these within the
settlements. Vulnerable community members will be prioritized as key beneficiaries in these plans.
Through county social development and community development officers, KISIP2 will link
vulnerable community groups, including those at risk of violence, to existing World Bank3 and
government safety nets programs.
Component 3: Institutional Capacity Development for Slum Upgrading
The Project will support institutional and policy development at national and county levels.
Activities will include supporting the review of the 2005-2020 National Slum Upgrading and
Prevention Strategy, the development of county-specific slum upgrading and prevention strategies,
developing financing mechanisms for slum upgrading at county level, and developing strategies to
plan for urban growth, prevent crime and violence and to ensure adoptive planning in informal
settlements.

KISIP 2 will develop activities to build capacity of the teams at the national and county levels
mandated to implement the Strategy. KISIP2 will also support technical assistance, training,
workshops and learning events, experience sharing and peer-learning activities with other counties,
and other capacity building activities aimed at enhancing the ability of national, county, and
community teams to exercise their roles and responsibilities.

3
These are the National Safety Nets Program for Results (Additional Financing P161179), the Kenya Social and
Economic Inclusion Project (P164654) and the Kenya Youth Employment and Opportunities Project (KYEOP)
(P151831).

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Component 4: Program Management and Coordination
This component will finance activities of the NPCT and the CPCTs related to national and county-
level project management and coordination, including planning, surveying, engineering, fiduciary
(financial management and procurement), safeguards compliance and monitoring, monitoring and
evaluation (M&E), and communication and community development.

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2.0 Policy, Legal and Institutional Framework for Public Participation
This Stakeholder Engagement Framework (SEF) is underpinned by the Kenya’s policy and legal
framework which guarantees the right to information and public participation. It is also supported
by the World Bank Policies on Stakeholder engagement and participation in projects.
2.1 Kenya’s Legislative Framework

2.1.1 The Constitution of Kenya, 2010

The Constitution of Kenya (2010), which is the supreme law, provides for Public participation as
one of its core pillars and a constitutional right.
Article 1(2) of the Constitution of Kenya, 2010 provides that all sovereign power belongs to the
people of Kenya. It further states that people may exercise their sovereignty directly or through their
elected representatives. Public participation is direct exercise of sovereignty.
Article 10 (2) indicates that public participation is among the national values and principles of
governance.
Article 33 guarantees the freedom of expression including the freedom to seek, receive or impart
information or ideas. Hence, every person should feel constitutionally empowered to share
information and ideas during public participation processes.
Article 35 provides for the right to access information. It guarantees every citizen the right to access
information held by the state. This includes information required for effective public participation to
take place. The same article provides that the State shall publish and publicize any important
information affecting the nation.
Article 174(c), gives powers of self-governance to the people can derive direct benefit from
meaningful public participation as this contributes to better informed decision-makers armed with
additional facts, values and perspectives obtained through public input.
Article 174(d) recognizes the rights of communities to manage their own affairs and to further their
development.
Article 184 is exclusive on urban areas and Cities, the article provides that National legislation shall
provide for the governance and management of urban areas and cities and shall, among other
provision provide for participation by residents in the governance of urban areas and cities.
Article 232(1) (d) provides for the involvement of the people in the process of policy making and
part (f) provides for transparency and provision to the public of timely and accurate information.
Access to information for Kenyan citizens is guaranteed by Article 35 of the Constitution
Article 37 and 104 of the Constitution have a provision on grievance mechanism, including a right
to assemble, demonstrate, to picket and to present petitions or seek redress within the judicial
system.

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Article 201(a) provides Principles of public finance which require openness and accountability,
including public participation in financial matters;
Article 232(1) provides values and principles of public service include among others involvement of
the people in the process of policy making;
2.1.2 The County Government Act (2012)
The County Government Act, 2012 is the key legislation that gives effect to the constitutional
provisions on devolution. The Constitution specifies the devolution of powers from the central
government to the newly established county governments, which are now in charge of planning and
development among others services, and can enact legislation with possible implications to planned
and current projects.
The County Government Act, 2012 at the preamble defines the public: (a) the residents of a
particular county; (b) the rate payers of a particular city or municipality; (c) any resident civic
organization or non-governmental, private sector or labour organization with an interest in the
governance of a particular county, city or municipality; and (d) non-resident persons who because of
their temporary presence in a particular county, city or municipality make use of services or facilities
provided by the county, city or municipality.
The Act in Part 2 Section 6 states that in exercising its powers or performing any of its functions a
county government shall ensure efficiency, effectiveness, inclusivity and participation of the people.
Section 87 of the Act provides for the principles of citizen participation in county governance.
These include: -
(a) timely access to information, data, documents, and other information relevant or related to policy
formulation and implementation;
(b) reasonable access to the process of formulating and implementing policies, laws, and regulations,
including the approval of development proposals, projects and budgets, the granting of permits and
the establishment of specific performance standards;
(c) protection and promotion of the interest and rights of minorities, marginalized groups and
communities;
(d) legal standing to interested or affected persons, organizations, and where pertinent, communities,
to appeal from or, review decisions, or redress grievances, with particular emphasis on persons and
traditionally marginalized communities, including women, the youth, and disadvantaged
communities;
(e) reasonable balance in the roles and obligations of county governments and non-state actors in
decision-making processes to promote shared responsibility and partnership, and to provide
complementary authority and oversight;
(f) promotion of public-private partnerships, such as joint committees, technical teams, and citizen
commissions, to encourage direct dialogue and concerted action on sustainable development; and
(g) recognition and promotion of the reciprocal roles of non-state actors’ participation and
governmental facilitation and oversight.

The County Governments Act, in sub section 91 identifies modalities and platforms for citizen
participation. These obligate the county government to facilitate the establishment of structures for

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citizen participation among them information communication technology based platforms, town hall
meetings, budget preparation and validation fora, notice boards that announce jobs, appointments,
procurement, awards and other important announcements of public interest, development project
sites, avenues for the participation of peoples’ representatives including but not limited to members
of the Parliament (the National Assembly and Senate) and establishment of citizen fora at county
and decentralized units.
Effective public participation requires a clear mechanism for participation, and communication
channels between citizens and government, and that the actors, private individuals and
organizations, need to have an understanding and knowledge of the issues and public processes to
engage meaningfully. In essence, while the supply side of participation requires that enabling
systems, mechanisms and frameworks are in place, the extent to which participation achieves its
intended objectives largely depends on how the demand side (the public) is organized and informed
on the issues they seek to influence. While the latter precondition requires citizens/communities to
be organized and informed in order for them to be effective, the Constitution emphasizes the
importance of government in ensuring that the people’s capacity to engage is built. County
governments are therefore expected to “ensure” that there is public participation; to “coordinate”
the participation and to “develop” the capacity of the communities to participate.
In Part IX, of the Act establishes Principles and Objectives of public communication. Furthermore,
in Sub-Section 96, the Act establishes the modalities of access to information. It specifies that ‘every
county government and its agencies shall designate an office for purposes of ensuring access to
information.’ It further enshrines the inclusion and integration of minorities and marginalized
groups.
In Part X, the Act obligates the county governments to conduct civic education as part of enhancing
public participation. And in sub section 105, it obligates the county governments to ensure
‘meaningful engagement of citizens in the planning. COK 2010, Schedule 4 clause 14 states,
“ensuring and coordinating the participation of communities and locations in governance at the
local level and assisting communities and locations to develop the administrative capacity for the
effective exercise of the functions and powers and participation in governance at the local level” is
one of the functions of the county governments.’ It further specifies this in sub section 115 ‘Public
participation in county planning.’ In Sub- Section 119, it obligates the County Executive Committee
(CEC) to establish Citizen’s Service Centres at the county, Sub-County, Ward and any other
decentralized levels. The Citizen Service Centres are expected to ‘serve as the central office for the
provision by the county executive committee in conjunction with the national government of public
services to the county citizens.
2.1.3 Environmental Management Coordination Act (EMCA), 1999
In Kenya the Environmental Management and Coordination Act (EMCA) 1999 and the
Environmental (Impact Assessment and Audit) Regulations, June 2003 define the legal basis for and
the requirements of environmental impact assessment and management. NEMA assumes primary
responsibility for overseeing the implementation of the requirements of the Act.
Part 2 of EMCA 1999, consist of General principles: (a). principle of public participation in the
development of plans, policies and processes for the management of the environment; (b) involving

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the community to employ their cultural and traditional social principle of managing the environment
and natural resources provided it is not repugnant to the justice and morality and not inconsistent
with the law.
The EMCA and its supporting legislation set out requirements for public disclosure and consultation
in tandem with the ESIA process. KISIP II should comply with the applicable legislation during the
ESIAs, preparing community disclosure fact sheets, disseminating other information through
barazas and other stakeholder meetings, and responding to concerns through official public
meetings and the development of its policies, Framework ESMP and specific management plans.
Upon receipt of the EIA study report from any proponent under section 58, the authority shall
cause to be published in each of two successive weeks in the gazette newspaper circulating in the
area or proposed area of the project once in each of the two successive weeks in a notice which state
among others: a summary description of the project, the place where the project is carried out, the
place where the environmental impact assessment study, evaluation or study report evaluation or
review report may be inspected.
The ESIA must include a fully inclusive public/stakeholder consultation process to ensure that the
affected community is engaged throughout the ESIA process and their issues and concerns
addressed. Specifically, the proponent is required to:
a. Publicize the project and its anticipated effects and benefits by placing posters in strategic public
places in the vicinity of the site of the proposed project informing the affected parties and
communities of the proposed project;
b. Issue project notification in a nationwide newspaper for two successive weeks;
c. Arrange for a radio announcement in both local and official languages with a nationwide
coverage for at least once a week for two successive weeks;
d. Hold at least 3 public meetings with the affected parties and communities to explain the project
and its effects, and to receive their oral or written comments;
e. Send out notice of consultations at least one week prior to the meetings; and
f. Ensure, in consultation with the Authority that a suitably qualified coordinator is appointed to
receive and record both written and oral comments.

2.1.4 The Urban Areas and Cities Act (2011)

The Urban Areas and Cities Act of 2011 make further provisions for public participation. In sub
section 2, the Act provides for a Citizen Fora as a ‘forum for citizens organized for purposes of
participating in the affairs of an urban are or a city.’
In Sub Section 3 (c), it identifies ‘participation by the residents in the governance of urban areas and
cities.’
In Sub Section 11 (d), it establishes ‘institutionalized active participation by its residents in the
management of the urban area and city affairs’ as one of the principles of governance and
management of urban areas and cities. The rights of, and participation by residents in affairs of their
city or urban area are elaborated in the Second Schedule of the Act. It obligates the authorities in an
urban area or city to ‘develop a system of governance that encourages participation by residents in

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its affairs’ through creating ‘appropriate conditions for participation in the preparation,
implementation and review of the integrated development plan, the establishment, implementation
and review of its performance management system, the monitoring and review of its performance,
including the outcomes and impact of its performance, the preparation of its budget and making of
strategic decisions relating to delivery of service.

2.2 World Bank Standards

The project will adhere to the World Bank standards on participation and consultation in addition to
the GoK requirements. Where differing levels of performance are detailed between the various
standards, the most stringent requirement will be applied.
The World Bank Group’s Environmental Assessment Policy (OP 4.01, January 1999) requires that
project-affected groups and local non-governmental organizations (NGOs) be consulted during the
impact assessments process about the project’s potential environmental and social impacts.
Environmental Assessment Policy OP 4.01 Sections 15 provides that for all Category A and B
projects proposed for IBRD or IDA financing, during the EA process, the borrower consults
project affected groups and local nongovernmental organizations (NGOs) about the project’s
environmental aspects and takes their views into account. The borrower initiates such consultations
as early as possible. For Category A projects, the borrower consults these groups at least twice: (a)
shortly after environmental screening and before the terms of reference for the EA are finalized; and
(b) once a draft EA report is prepared. In addition, the borrower consults with such groups
throughout project
Information disclosure is detailed in section 16 of the policy, the section provides for meaningful
consultations between the borrower and project-affected groups and local NGOs on all Category A
and B projects proposed for IBRD or IDA financing, the borrower provides relevant material in a
timely manner prior to consultation and in a form and language that are understandable and
accessible to the groups being consulted. Any separate Category B report for a project proposed for
IDA financing is made available to project-affected groups and local NGOs and World Banks Info
Shop.
Public participation in development project is further emphasized in the World Bank’s
Environmental and Social Framework (ESF) came into effect on October 1, 2018. Even though
KISIP II is proposed to follow the old Operational Policies, the principles and key elements of the
new standards are relevant. The Framework includes Environmental and Social Standard (ESS) 10,
“Stakeholder Engagement and Information Disclosure”, which recognizes “the importance of open
and transparent engagement between the Borrower and project stakeholders as an essential element
of good international practice”. ESS10 emphasizes that effective stakeholder engagement can
significantly improve the environmental and social sustainability of projects, enhance project
acceptance, and make a significant contribution to successful project design and implementation.

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As defined by the 2018 ESF and ESS10, stakeholder engagement is an inclusive process conducted
throughout the project life cycle. Where properly designed and implemented, it supports the
development of strong, constructive and responsive relationships that are important for successful
management of a project’s environmental and social risks.
Key elements of ESS10 include:
a. “Stakeholder engagement is most effective when initiated at an early stage of the project
development process, and is an integral part of early project decisions and the assessment,
management and monitoring of the project.”
b. “Borrowers will engage with stakeholders throughout the project life cycle, commencing such
engagement as early as possible in the project development process and in a timeframe that
enables meaningful consultations with stakeholders on project design. The nature, scope and
frequency of stakeholder engagement will be proportionate to the nature and scale of the project
and its potential risks and impacts.
c. Borrowers will engage in meaningful consultations with all stakeholders. Borrowers will provide
stakeholders with timely, relevant, understandable and accessible information, and consult with
them in a culturally appropriate manner, which is free of manipulation, interference, coercion,
discrimination and intimidation.
d. The process of stakeholder engagement will involve the following, as set out in further detail in
this ESS: (i) stakeholder identification and analysis; (ii) planning how the engagement with
stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders;
(v) addressing and responding to grievances; and (vi) reporting to stakeholders.
e. The Borrower will maintain and disclose as part of the environmental and social assessment, a
documented record of stakeholder engagement, including a description of the stakeholders
consulted, a summary of the feedback received and a brief explanation of how the feedback was
taken into account, or the reasons why it was not.”
Borrowers are required to develop a Stakeholder Engagement Plan (SEP) proportionate to the
nature and scale of the project and its potential risks and impacts (paragraph 13). Stakeholders have
to be identified and the SEF has to be disclosed for public review and comment as early as possible,
before the project is appraised by the World Bank. ESS10 also requires the development and
implementation of a grievance redress mechanism that allows project-affected parties and others to
raise concerns and provide feedback related to the environmental and social performance of the
project and to have those concerns addressed in a timely manner.

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3.0 Stakeholders Identification and Analysis
3.1 Project Stakeholders
Project stakeholders are defined as individuals, groups or other entities who: (i) are impacted or
likely to be impacted directly or indirectly, positively or adversely, by the Project (also known as
‘affected parties’); and (ii) may have an interest in the Project (‘interested parties’). They include
individuals or groups whose interests may be affected by the Project and who have the potential to
influence the Project outcomes in any way.
Cooperation and negotiation with the stakeholders throughout the Project development often also
require the identification of persons within the groups who act as legitimate representatives of their
respective stakeholder group, i.e. the individuals who have been entrusted by their fellow group
members with advocating the groups’ interests in the process of engagement with the Project.
Community representatives may provide helpful insight into the local settings and act as main
conduits for dissemination of the Project-related information and as a primary
communication/liaison link between the Project and targeted communities and their established
networks. The legitimacy of such representatives may stem both from their official elected status
and their informal and widely supported standing within the community that allows them to act as
focal points of contact in Project’s interaction with its stakeholders.
For KISIP, examples of legitimate stakeholder representatives include and are not limited to:
a. elected officials (Members of Parliament and County Assemblies)
b. leaders of the Settlement Executive Committees (SECs), and community Grievance Redress
Committees);
c. non-elected leaders that have wide recognition within their community, such as chairpersons of
local initiative groups, committees, local cooperatives etc.;
d. leaders of community-based organizations, local NGOs, and youth and women’s groups;
e. the elders and veterans within the affected community;
f. religious leaders, including those representing traditional faiths;
g. teachers and other respected persons in the local communities, etc.

For some stakeholder groups, verification of their representatives (i.e. the process of confirming that
they are legitimate and genuine advocates of the community they represent) is an important task in
establishing contact with the community stakeholders.

3.2 Stakeholder Identification

The KISIP II will attract interest from a broad cross section of the community, both within the
project area and outside. Stakeholder identification and analysis is a core part of developing an
engagement approach. It is important to note that stakeholders may change over the course of the
project and different approaches may be required for effective engagement.
The following criteria, adjusted to take account of local specific conditions, are proposed to be used
for the identification of stakeholders:

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 a) Liability: project implementation or on-going operations may result in legal, financial or
other liabilities of the proponent to a social group;
b) Influence: a social group may be able to substantially influence project implementation or
ongoing operations;
c) Partnership: there are opportunities for building partnership relations between the project
developer and a given social group in the framework of the project implementation or on-
going operations;
d) Dependency: project implementation may significantly affect a given social group, in
particular, it may affect vital interests of its representatives if they are dependent on the
project on-going operations in economic or financial terms;
e) Representation: a social group may have a right to represent interests with regard to a project
or on-going operations, and this right is legitimated through legislation, custom and and/or
cultural specifics;
f) Expressed interest: a social group and/or individual may express interest to a project or
ongoing operations, and this group is not necessarily directly affected by the planned or
current activities
3.3 Generic KISIP Stakeholders
From the outset, KISIP will seek to build strategic working relationships with the various
stakeholders who are directly or indirectly impacted by and/or who have interests all the sub-
projects. The collection and use of stakeholder information by KISIP and its contractors will be
carried out in accordance with applicable privacy legislation.
A comprehensive list of stakeholders and database will be developed and maintained by KISIP. The
table below broadly identifies the key stakeholder groups, their respective relevance to and interests
in the project.
Table 3: Generic KISIP Stakeholders
Stakeholder Relevance Interests
Residents May face disruption from Project impacts / benefits, construction
construction activities management / mitigation measures
Business owners May face business disruption Project impacts / benefits, construction
from construction activities management / mitigation measures,
business support
Commuters (public May face disruption to commute Project impacts / benefits, construction
transport, road) from construction activities management / mitigation measures,
changes to transport network
Local Construction occurring in Project benefits / impacts, local planning
municipalities/ municipality, responsible for issues, social and economic development

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councils local permits / approvals
National Responsible for national Statutory requirements are met, project
Government planning approvals i.e. NEMA delivered in line with approvals
(departments and
agencies)
The World Bank Providing project financing Successful implementation of the project
to achieve sustainable outcomes.
Institutions Facilities located in close Project impacts / benefits, construction
(schools, churches, proximity may be affected by management / mitigation measures,
research, health construction changes to access
etc)
Landowners Land owned may be affected by Project impacts / benefits, construction
the project (directly or management / mitigation measures, land
indirectly) acquisition process
Media They are intermediaries for Key milestones, project updates
informing the general public
about the planned project
activities and for information
disclosure in connection with
the proposed project(s).
Industry groups / Members may be affected by Project impacts / benefits relating to
Special interest construction activities, provide each group’s specific interest area
groups advice / shape broader public
discussion about project
Project partners Partner with GoK/ KISIP / Accountable for delivery of services
contractors in the development during construction, technical advice and
and delivery of the project requirements for project
County Responsible for County Statutory requirements are met, project
Government planning approvals, overall delivered in line with approvals,
(departments and project delivery community impacts managed effectively
agencies)
Utility service Many utilities located in close Potential impacts on assets and asset
providers proximity to construction renewal plans
activities, may need to be
relocated / protected
Scientific Scientific understanding of the Technical advice
institutions range or problems associated
with the proposed project(s).

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 Scientific approach to the
relevant issues. Possible
specialists’ provision for further
activity in project
implementation.
Project employees Technical understanding of the
and Project’s range or problems associated
subcontractors with the proposed project(s)
including H&S issues.

3.4 Stakeholder Categorization

The various international standards being applied to this Project define two main categories of
stakeholder; differentiating for example between “those who will be or are likely to be directly or
indirectly affected, positively or negatively, by a project (commonly referred to as project-affected
people, households or communities)” and “those who might have an interest in, or may influence
the project”. Following this definition, the two principal groups of stakeholders in the KISIP Project
are broadly categorized as follows: Affected parties, and interested parties.
3.4.1 Affected Parties
Affected Parties include local communities, community members and other parties that may be
subject to direct impacts from the KISIP sub-projects. Affected parties are generally located within
the Project’s defined area of influence but may be elsewhere (e.g. people who outside of project area
but have personal or business interests that may be directly affected by the development of the sub-
projects).

Affected parties include 2 sub-groups:

a) Directly affected:
▪ Communities, groups and individuals displaced physically and/or economically by the
Project, including any vulnerable or marginalized stakeholders.
b) Indirectly Affected:
▪ Residents, businesses, County officials and administrators who may be indirectly affected by
employment opportunities, influx and the related pressure on resources and services;
▪ Government officials, including Municipal Administration of the in the project area, village
administrations, environmental protection authorities;
▪ Community-based groups and non-governmental organizations (NGOs) that represent local
residents and other local interest groups, and act on their behalf; and
▪ Employees, their representatives and contractors to KISIP.

Local NGOs and initiative/advocacy groups represent the considerable capacity that the project(s)
may tap for disseminating the information and raising awareness of the planned activities among the

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potentially affected communities in the project area. NGOs typically have well established
interaction with the local communities, are able to propose the most effective and culturally
appropriate methods of liaising based on the local customary norms and prevailing means of
communication, and possess the facilitation skills that may be utilized as part of the project’s
consultations. In addition, NGOs may lend assistance in disseminating information about the
proposed project(s) to the local communities, including in the remote areas (e.g. by placing
information materials about the project in their offices, distributing the project information lists
during events that they are organizing), and provide venues for the engagement activities such as
focus-group discussions.

3.4.2 Interested Parties

The projects’ stakeholders also include parties other than the directly affected communities:
Individuals/groups/entities that may not experience direct impacts from the Project but who
consider or perceive their interests as being affected by the project and/or who could affect the
project and the process of its implementation in some way. These Interested parties may include:
▪ Residents of the other settlements within the project area, who can benefit from employment
and training opportunities stemming from the project;
▪ Civil society groups and NGOs on the regional, national and local levels, that pursue
environmental and socio-economic interests and may become partners of the project.
Organizations within this group are likely to be located outside the project’s Direct Area of
Influence;
▪ Business owners and providers of services, goods and materials within the project area that will
be involved in the project’s wider supply chain or may be considered for the role of project’s
suppliers in the future;
▪ Government officials, permitting and regulatory agencies at the National and County levels,
including environmental, technical, social protection and labor authorities.
▪ Mass media and associated interest groups, including local, county and national printed and
broadcasting media, digital/web-based entities, and their associations.
▪ Other notable projects in the region;
▪ Politicians at national / regional / local levels;
▪ Lenders’ to the Project; and
▪ Academics and other interest groups.

3.5 Stakeholder Analysis

A sound community relations approach to engagement with stakeholders, builds on in-depth and
structured analysis of stakeholders. It also allows KISIP to determine which stakeholder groups to
prioritize within the stakeholder engagement / community relations strategy. For example,
influential stakeholders who are significantly impacted by the Project typically make good partners
for KISIP to work with, while stakeholders with limited influence who are significantly impacted are
best approached through an empowerment or rights protection perspectives, as they may not have
the capacity to represent themselves properly.

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Similarly, interested parties can be a low priority for community relations efforts, but their capacity
to exert high influence over the Project, means that they need to be kept informed and involved,
while building strategies to reduce any inappropriate demands that they place on the Project.

KISIP will continue to undertake analysis of its various stakeholder groups to identify any new
stakeholders and determine/confirm the appropriate level and methods of consultation and
engagement for each stakeholder group. The Head of Safeguards and CLO will be responsible for
ongoing stakeholder identification, mapping and analysis. The CLO is also responsible for updating
the stakeholder database and matrix as well as creating/updating Key Stakeholder Profiles.

The analysis will involve mapping stakeholder using the following three key determinants:
• The stakeholder’s projected level of interest in the Project;
• The Project’s potential impact on the stakeholder; and
• The stakeholder’s degree of influence / power on or value to the Project.

By plotting influence together with impact/interest on a matrix and taking due account of further
criteria such as expertise (i.e. knowledge to contribute and legitimacy) and the stakeholders’
willingness to engage, the relative needs of key stakeholders in terms of the level and type of
consultation and engagement are determined and can therefore be properly planned.

The KISIP definitions of impact/interest and influence/power are described in Table 4 below:
Table 4: Definitions for Stakeholder Analysis and Mapping
Impact / Interest axis Influence/Power axis
High The stakeholder will experience a high The stakeholder has decision-making
degree of impact as a result of the Project powers regarding whether the project will
(e.g. resettlement, complete loss of go ahead or not and/or about the
livelihood, loss of pasture / water, etc.). adequacy of the ESIA process and/or
KISIPs mitigation strategies.
OR: The project is directly related to
stakeholder’s institutional field of interest
and/or responsibilities
Medium The stakeholder will experience some The stakeholder can influence the scope
degree of impact but impacts can be and timing of the ESIA and/or KISIP’s
managed and/or mitigated. mitigation strategies
OR: The project or aspect thereof has
some relevance to the stakeholder’s
institutional field of interest and/or
responsibilities
Low The stakeholder will experience very few The stakeholder has very little control over
effects as a result of the project. the project

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 OR: the project has limited relevance to
the stakeholder’s institutional field of
interest and/or responsibilities

3.6 Vulnerable Groups

A significant factor in achieving inclusiveness of the engagement process is safeguarding the
participation of vulnerable individuals in public consultations and other engagement forums
established by the project. Vulnerable groups are persons who may be disproportionately impacted
or further disadvantaged by the project(s) as compared with any other groups due to their vulnerable
status, and that may require special engagement efforts to ensure their equal representation in the
consultation and decision-making process associated with the project(s). The vulnerability may stem
from person’s origin, gender, age, health condition, economic deficiency and financial insecurity,
disadvantaged status in the community (e.g. minorities or fringe groups), dependence on other
individuals or natural resources, etc.

Vulnerable stakeholders require an open and inclusive approach to engagement that provides them
with suitable opportunities to participate and voice their concerns. Some vulnerable stakeholders will
need special attention in this SEF due to the factors that define their vulnerability. Accordingly,
differentiated measures may be applied to ensure the effective participation and obtain feedback
from vulnerable stakeholders.
Vulnerable groups within the communities affected by the project will be further confirmed and
consulted through dedicated means, as appropriate.

3.6.1 Identification of Vulnerable Groups

KISIP will identify individuals and groups who may be differentially or disproportionately affected
by operations due to their disadvantaged, isolated or vulnerable status and consider specific and
proactive engagement measures for these groups.
The outcomes of the various socio-economic baseline and impact studies (including the applicability
of OP 4.10 on indigenous peoples) identified the following potentially vulnerable groups as being
within or near to the KISIP’s Project’s area of influence:
a) Female headed households: In addition to the disadvantages of gender, such women often
have restricted access to income generating activities and suffer from higher levels of food
and water insecurity. Single headed households have similar problems (e.g. where the man’s
ability to earn a livelihood may be restricted by family commitments);
b) Uncontrolled influx may include Vulnerable unemployed people, particularly young adults,
who are already disadvantaged and whose condition worsens as a result of moving onto the
area;
c) Sex trade workers: Not identified currently within the Project area of influence but may
migrate or be trafficked into the area once construction works commence. Sex workers may

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 not have access to forms of protection (e.g. access to the authorities, health and/or
children’s education services) and are often subject to discrimination and harassment.
d) Elderly: The aged and infirm are less likely to receive an income and may rely upon their
families for support (however their age may confer an elevated status in traditional
governance systems and decision making);
e) Children: Children are principally reliant upon older members of the family for sustenance,
shelter and general well-being;
f) Old women: Local women traditionally have only restricted access to resources due to
cultural factors. They are often afforded only a low level of representation in community
decision making processes and may suffer from spousal abuse;
g) Physically / mentally sick and disabled: The lack of government services in the local area
deprives such stakeholder of institutional support and services to encourage their social and
economic participation in the community;
h) Others dependent upon ecosystem services: Stakeholders dependent upon the collection of
wood for charcoal production or timber for construction and also face similar declining
ecosystem carrying capacity;
i) Internally displaced: There have been ongoing outbreaks of violence within the wider region,
variously involving livestock rustling, disputes over fishing rights or access to water, pasture
and other resources. This has led to increases in the population of settlements and
consequent loss of access to resources, community cohesion and livelihoods although it is
considered highly unlikely that such people will be subject to any significant adverse project
impacts; and
j) Externally displaced: There are no refugee camps housing displaced people in the project
vicinity. KISIP will monitor and engage with appropriate GoK departments should
externally displaced people seek refuge within the concessional area.

3.6.2 Monitoring Changes to Vulnerability

KISIP will assess the vulnerability of individual and groups who may be potential candidates for
vulnerability status. Particular attention shall be afforded to the most vulnerable, least visible and
voiceless for whom special consultation measures may be required.
The CLO will maintain and update existing records of vulnerable stakeholder groups and will screen
potential individual and group candidates using the criteria developed in the Vulnerability Screening
Checklist (see format in Appendix 4 ). This process requires an update to relevant data and an
evaluation of vulnerability status, which will be undertaken either when the CLO identify a specific
need or at a minimum frequency of annually during construction and the first two years of
operations.
3.6.3 Differentiated Engagement Measures

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KISIP will ensure that such groups remain subject to culturally appropriate, differentiated measures
in engagement and/or consultation campaigns. The type and nature of such measures will vary
according to circumstances and may consist of any combination of the following:
• Ensuring the legitimacy of any designated representatives for vulnerable groups;
• Respecting traditional decision-making governance;
• Engaging separately with women and men whenever pertinent;
• Subsidizing travel and/or subsistence expenses of vulnerable stakeholders attending engagement
events; and
• Focusing any mitigation on sustainable livelihood development for such groups.

The appropriate actions shall be recommended by the CLO and approved by the Head of
Safeguards.

3.7 Indigenous Peoples

The World Bank uses the term “Indigenous Peoples” in a generic sense to refer to a distinct social
and cultural group possessing the following characteristics in varying degrees:
a. Self-identification as members of a distinct indigenous cultural group and recognition of
this identity by others;
b. Collective attachment to geographically distinct habitats or ancestral territories in the
project area and to the natural resources in these habitats and territories;
c. Customary cultural, economic, social, or political institutions that are separate from those
of the mainstream society or culture; or
d. A distinct language or dialect, often different from the official language or languages of
the country or region in which they reside.

Such groups are generally considered to be amongst the most marginalized and vulnerable segment
of population and they can be more vulnerable to impacts associated with project development.
Their inability to defend their rights to, and interest in lands, natural resources and ecosystems
services may also impact their social and cultural life.

Their peculiar circumstances may require special protective measures in the event that they are
adversely impacted by the project as required by country laws, World Bank OP 4.10 on Indigenous
Peoples (2012), and the UN Declaration on the Rights of Indigenous Peoples (UNDRIP). Those
standards set out an approach that aims to avoid any impacts (especially relocation) and requires a
distinct, culturally appropriate process for information disclosure, consultation and informed
participation. That process can under certain circumstances trigger the principle of Free Prior and
Informed Consent, which requires projects to obtain a clear mandate to proceed from bona fide
indigenous peoples.

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4.0 Stakeholder Engagement
It is acknowledged that effective engagement will be critical throughout construction to keep
community members and stakeholders informed and involved in the project. In order to be
effective, engagement needs to take place over a period of time – providing information to
community and stakeholders about the project as it develops, listening to their feedback and
responding to it.
Stakeholder engagement at all levels will take place throughout the life of the sub-projects. KISIP II
will deploy Community Liaison officers in project areas who are conversant with the local
communities to be in charge of community engagement.

This section sets out KISIP’s plans to ensure it meets its objectives and goals for stakeholder
engagement throughout the Project in respect for each stakeholder group identified.

4.1 Principles and Goals of Engagement

KISIP recognizes that project progress and decisions can be enhanced through dialogue with the
community and relevant stakeholders, including residents, businesses, government and other
interested parties. Understanding the interests, concerns, requirements and preferred outcomes of
these groups enables KISIP and the works contractors to find solutions to the issues and challenges
likely to arise in delivering the sub-projects.
The table below sets out the core principles and goals of KISIP’s Community and Stakeholder
Engagement Management Framework throughout planning and construction phases.

Table 5: Principles of Goals of KISIP Engagement

Principle Goal
Effective Engagement is open, consistent, inclusive, accessible and transparent
throughout planning and delivery of the project.
Timely Engagement spans all stages of the project, ensuring information is
provided to stakeholders as the project develops and feedback is
responded to and incorporated in the project’s development.
Meaningful Engagement is clear on the elements of the project that can be
influenced by the community and stakeholders, how the feedback will
be used and is explicit on which elements of the project are fixed and
the reason for this.
No surprises Engage early to gain understanding of interests, concerns, requirements
and preferred outcomes. Close the loop to demonstrate how feedback
has been considered.

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4.2 Engagement Guidelines and References (IAP2 Spectrum)
International Association for Public Participation (IAP2) is an international member association,
which seeks to promote and improve the practice of public participation or community engagement,
incorporating individuals, governments, institutions and other entities that affect the public interest
throughout the world.
The IAP2 Spectrum is an internationally recognized tool for planning public participation in major
projects. The Spectrum is designed to assist with the selection of the level of participation that
defines the public's role in any community engagement program. The Spectrum shows that differing
levels of participation are legitimate depending on the goals, time frames, resources and levels of
concern in the decision to be made.
KISIP and the works contractors will use the IAP2 Spectrum to guide how the community and
stakeholders will be engaged during the project planning and delivery phases.
Table 6: IAP2 Spectrum
INFORM CONSULT INVOLVE
GOAL To provide the public To obtain public To work directly
with balanced and feedback on analysis, with the community
objective information to plans and/or decisions and stakeholders to
assist them in ensure that concerns
understanding the and aspirations are
problem, alternatives, consistently
opportunities and/or understood and
solutions. considered.
PROMISE We will keep you We will keep you We will work with
informed. informed, listen to and you to ensure that
acknowledge concerns your concerns and
and aspirations and aspirations are
provide feedback on directly reflected in
how public input the project and
influenced the decision. provide feedback on
We will see your how input influenced
feedback on draft the decision.
proposals.
STAKEHOLDERS The broader Melbourne All community and Key stakeholders,
community. Stakeholders stakeholders including government
interested in engaging directly impacted agencies, directly
about the project – stakeholders – encourage impacted
educate on key elements feedback on fixed project stakeholders and
of the project and elements. community -
explain how they can be feedback on options,
involved. benefits and
potential

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 construction impacts.
ACTIVITIES Advertising Newsletters Briefings / info sessions Interactive briefings
AND TOOLS / publications Displays / Feedback forms Formal / info sessions
information stalls eNews consultation (e.g. written Feedback forms
Letters (direct mail / submissions) Social Formal consultation
letter drops) Media research Interviews (e.g. written
articles / releases / kits (phone / person) Project submissions) Online
Project website Site info line Project email engagement Working
signage / posters Social enquiries Presentations / reference groups
media Videos / DVDs Project documents and
(animations and reports Reports on
photography) Works engagement outcomes
notifications Online engagement

4.3 Engagement Methods and Tools

The project(s) intend to utilize various methods of engagement that will be used by as part of its
continuous interaction with the stakeholders. For the engagement process to be effective and
meaningful, a range of various techniques need to be applied that are specifically tailored to the
identified stakeholder groups. The format of every consultation activity should meet general
requirements on accessibility, i.e. should be held at venues that are easily reachable and do not
require long commute, entrance fee or preliminary access authorization, cultural appropriateness (i.e.
with due respect to the local customs and norms), and inclusiveness, i.e. engaging all segments of the
local society, including disabled persons, the elderly, minorities, and other vulnerable individuals. If
necessary, logistical assistance should be provided to enable participants from the remote areas,
persons with limited physical abilities and those with insufficient financial or transportation means
to attend public meetings scheduled by the project.

Ensuring the participation of vulnerable individuals and groups in project consultations may require
the implementation of tailored techniques. Since their vulnerable status may lead to people’s
diffidence and reluctance or physical incapacity to participate in large-scale community meetings,
visiting such individuals/ families at their homes or holding separate small group discussions with
them at an easily accessible venue is a way for the project to reach out to the groups who, under
standard circumstances, are likely to be insufficiently represented at community gatherings.

Various methods of engagement will be used as part of the project’s interaction with the
stakeholders, to ensure that different stakeholder groups are successfully reached and are involved in
the process of consultation, decision-making and the development of impact management solutions.

International standards increasingly emphasize the importance of a consultation being ‘free, prior
and informed’, which implies an accessible and unconstrained process that is accompanied by the
timely provision of relevant and understandable information. In order to fulfil this requirement, a
range of consultation methods are applied that specifically focus on this approach.

Information that is communicated in advance of public consultations primarily includes an

announcement thereof in the public media – local, regional and national, as well as the distribution

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of invitations and full details of the forthcoming meeting well in advance, including the agenda. It is
crucial that this information is widely available, readily accessible, clearly outlined, and reaches all
areas and segments of the target community.

These parameters can be achieved by implementing the following approach:

a.Advance public notification of an upcoming consultation meeting follows the same
fundamental principles of communication, i.e. it should be made available via publicly
accessible locations and channels. The primary means of notification may include mass
media and the dissemination of posters/ advertisements in public places. The project
keeps proof of the publication (e.g. a copy of the newspaper announcement) for the
accountability and reporting purposes. Existing notice boards in the communities may be
particularly useful for distributing the announcements, such as boards adjacent to the
widely visited public premises – Chief’s offices, post offices, stores, bus parks, and offices
of the local NGOs. When the notifications are placed on public boards in open air, it
should be remembered that the posters are exposed to weather, may be removed by by-
passers or covered by other advertisements. The project’s staff will therefore maintain
regular checks in order to ensure that the notifications provided on the public boards
remain in place and legible.

b. Another critical aspect of the meeting preparation process is selecting the methods of
communication that reach the potential audience with lower levels of literacy or those who
are not well-versed in the technical aspects of the proposed. Oral communication is an
option that enables the information to be readily conveyed to such persons. This includes
involving the selected community representatives / village leaders/ SEC/ local NGOs and
initiative groups to relay up-to-date information on the project and consultation meetings
to other members of the community. Advertising the project and the associated meetings
via radio or television and making direct calls (in case fixed-line or mobile phone
communication is available) is another method that allows reaching out to most audiences.
The announcement of a public meeting or a hearing is made sufficiently in advance,
thereby enabling participants to make necessary arrangements, and provides all relevant
details, including date, time, location/venue and contact persons.
c.Placement of the project materials in the public domain is also accompanied by making
available a register of comments and suggestions that can be used by any member of the
affected community and general public to provide their written feedback on the contents
of the presented materials. As a rule, the register is made available for the entire duration
of the requisite disclosure period. Where necessary, a project representative or an
appointed consultant should be made available to receive and record any verbal feedback
in case some stakeholders experience a difficulty with providing comments in the written
form.

d. Drafting an agenda for the consultation meeting is an opportunity to provide a clear and
itemized outline of the meeting’s structure, sequence, chairpersons, a range of issues that
will be discussed and a format of the discussion (e.g. presentation/ demonstration
followed by a Questions & Answers – Q&A session, facilitated work in small groups,
feature story and experience sharing, thematic sessions with a free speaking format
enabling the exchange of ideas). A clearly defined scope of issues that will be covered at
the meeting gives the prospective participants an opportunity to prepare their questions

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 and comments in advance. It is essential to allocate a sufficient amount of time for a
concluding Q&A session at the end of any public meeting or a hearing. This allows the
audience to convey their comments and suggestions that can subsequently be incorporated
into the design of the project. Keeping a record of all public comments received during
the consultations meetings enables the project’s responsible staff to initiate necessary
actions, thereby enhancing the project’s overall approach taking onto consideration the
stakeholders’ priorities. The recorded comments and how they have been addressed by the
project becomes an appropriate material for inclusion in the project’s regular reporting to
the stakeholders.

e.Distribution of targeted invitations to the consultation meeting or a hearing is an important

element of the preparation process and is based on the list of participants that is compiled
and agreed in advance of the consultation. Invitations may be sent both to certain
individuals that have been specifically identified as relevant stakeholders (e.g.
representatives of authorities, leaders of local NGOs and initiative groups, village
chairpersons) and as public invites (e.g. addressed to initiative and professional bodies,
local organizations, and other public entities). Text of individual invitations can be tailored
to reflect the specifics of an invitee and their role in the process, whereas the text of public
invitations normally indicates general details. Means of distributing the invitations should
be appropriate to the customary methods of communication that prevail locally in the
Project Area of Influence (PAI). Depending on the availability and technical feasibility, the
following means of distribution can be used: direct mail (post); as an inclusion with other
existing public mailings, utility bills, or circulates from a local authority. The invitation
should typically contain a clear request for confirmation of the participation, also
specifying a date by which the confirmation is expected. All invitations that were sent out
are tracked in order to determine and manage the response rate. If no response has been
received, the invitation can be followed up by a telephone call or e-mail where possible.

KISIP II will use a range of techniques to fulfill the main purpose of its consultation activities aimed
at raising the community’s and stakeholder awareness about the planned and current activities
undertaken by the project, as well as to solicit public feedback that can subsequently be input into
the project’s mitigation and enhancement measures. As discussed above, due consideration will be
given to the cultural appropriateness and inclusiveness of the consultation settings as well as gender
and other sensitivities that may prevail in the local communities. Knowledge and advice of the
community representatives and local NGOs are invaluable to ensure that these aspects are fully
observed. If deemed necessary, separate meetings and focus group discussions will be held, as
described above.

An attendance list is made available at the commencement of the consultation/hearing in order to

record all participants who are present at the meeting and their affiliation. Wherever possible,
attendees’ signatures should be obtained as a proof of their participation. Details of the attendees
who were not initially on the list (e.g. those participating in place of somebody else, or general
public) should be included in addition to those who have registered for the meeting in advance.

In most cases and as a general practice, the introductory initial part of the meeting or a hearing
should be delivered in a format that is readily understandable to the audience of laypersons and
should be free of excessive technical jargon. If necessary, preference should be given, whenever
possible, to the oral and visual methods of communication (including presentations, pictorials,

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illustrations, graphics and animation) accompanied by hand-out materials imparting the relevant
information in understandable terms rather than as text laden with technical intricacies. Where
technical specifics of the project’s particular activities or solutions are required to be delivered in a
greater level of detail, it will be ensured that the information conveyed remains comprehensible to all
members of the audience and that the description of complex technicalities is adapted to their level
of understanding, thereby enabling productive feedback and effective discussion.

If a large audience is expected to attend a public meeting or a hearing, necessary arrangements will
be made to ensure audibility and visibility of the presentation and any demonstrations involved. This
includes provision of a microphone, proper illumination, projector, places allocated for the
wheelchair users, etc.

Taking records of the meeting is essential both for the purposes of transparency and the accuracy of
capturing public comments. At least three ways of recording may be used, including:

a. taking written minutes of the meeting by a specially assigned person or a secretary;

b. audio recording (e.g. by means of voice recorders); and
c. photographing.

The latter should be implemented with a reasonable frequency throughout the meeting, allowing
notable scenes to be captured but at the same time not distracting or disturbing the audience
excessively. Where feasible, the video recording may also be undertaken. Combination of these
methods assures that the course of the meeting is fully documented and that there are no significant
gaps in the records which may result in some of the important comments received from the
stakeholder audience being overlooked.

As a possible option in addition to the Q&A session nearer the close of the public meeting/hearing,
evaluation (feedback) forms may be distributed to participants in order to give them an opportunity
to express their opinion and suggestions on the project. This is particularly helpful for capturing
individual feedback from persons who may have refrained from expressing their views or concerns
in public.

Questions provided in the evaluation form may cover the following aspects:
a. Participant’s name and affiliation (these items are not mandatory if the participant
prefers to keep the form confidential)
b. How did they learn about the Project and the consultation meeting?
c. Are they generally in favour of the Project?
d. What are their main concerns or expectations/hopes associated with the Project or
the particular activity discussed at the meeting?
e. Do they think the Project will bring some advantages to their community as a whole?
f. Is there anything in the Project and its design solutions that they would like to
change or improve?
g. Do they think that the consultation meeting has been useful in understanding the
specific activities of the Project, as well as associated impacts and mitigation
measures?
h. What aspects of the meeting they particularly appreciated or would recommend for
improvement?

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Bearing in mind that some of the participants might find completion of the evaluation form
challenging due to the literacy constraints or concerns about their confidentiality, the distribution of
the feedback forms should always be explained that filling the form is optional. Some persons may
be willing to express their feedback verbally and in this case a member of Project staff will be
allocated to take notes.

A summary description of the engagement methods and techniques that will be applied by project
developer is provided in Table 5 below. The summary presents a variety of approaches to facilitate
the processes of information provision, information feedback as well as participation and
consultation.

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Table 7: Methods, Tools and Techniques for Stakeholder Engagement
Method / Tool Description and Use Contents Dissemination Method Target Groups
Information provision
Distribution of printed Used to convey Printed materials present Distribution as part of Households in Project
public materials: leaflets, information on the illustrative and written consultation meetings, Area of Influence, as well
brochures, fact sheets Project and regular information on Project public hearings, as interested parties.
updates on its progress to activities, facilities, discussions and meetings
local, regional and technologies and design with stakeholders, as well
national stakeholders. solutions, as well as as household visits.
impact mitigation Placement at the offices
measures. Presented of local administrations
contents are concise and and NGOs, libraries and
adapted to a layperson other public venues.
reader. Graphics and
pictorials are widely used
to describe technical
aspects.
Distribution of printed A newsletter or an update Important highlights of Circulation of the • Households in
public materials: circular sent out to Project achievements, newsletter or update Project Area of
newsletters/ updates Project stakeholders on a announcements of sheet with a specified Influence.
regular basis to maintain planned activities, frequency in the Project • Public venues in
awareness of the Project changes, and overall Area of Influence, as well Project Area of
development. progress. as to any other Influence- local
stakeholders that administrations,
expressed their interest in libraries.
receiving these • Residents in project
periodicals. Means of area
distribution – post,
emailing, electronic
subscription, delivery in
person.
Printed advertisements in Inserts, announcements, Notification of Placement of paid • Residents in project
the media press releases, short forthcoming public information in local, area
articles or feature stories events or commencement regional and national • Interested parties

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 in the printed media – of specific Project printed media, including
newspapers and activities. General those intended for
magazines description of the Project general reader and
and its benefits to the specialized audience
community
Radio or television Short radio programmes, Description of the Collaboration with media Residents in project area
entries video materials or Project, Project producers that operate in
documentary broadcast development updates, the region and can reach
on TV. solutions for impact local audiences.
mitigation. Advance
announcement of the
forthcoming public
events or commencement
of specific Project
activities.
Visual presentations Visually convey Project Description of the Presentations are widely Affected communities in
information to affected Project and related used as part of the public in the project area,
communities and other solutions/impact hearings and other participants of the public
interested audiences. management measures. consultation events with hearings, consultations,
Updates on Project various stakeholders. rounds tables, focus
development. group discussions and
other forums attended by
Project stakeholders.
Authorities and other
governmental bodies.
• Hazard warning signage • Hazard warning signage At project sites Persons in the project
• Visual, informative will be erected to inform area.
displays at project sites stakeholders of specific
risks - e.g. for road
works, dangerous road
junctions etc.;
• Visual, informative
displays at project sites to
explain the Project to

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 provide an outline of
essential information
such as access restrictions
and security requirements
Notice boards Displays of printed Advance announcements Printed announcements Directly affected
information on notice of the forthcoming public and notifications are communities in the
boards in public places. events, commencement placed in visible and project area
of specific Project easily accessible places
activities, or changes to frequented by the local
the scheduled process. public, including libraries,
village cultural centers,
post offices, shop, local
administrations.
Information Feedback
Information repositories Placement of Project- Various Project-related
Deposition of materials Directly affected
accompanied by a related information and materials, ESMF
in publicly available communities in the
feedback mechanism printed materials in documentation, places (offices of local project area
dedicated/designated environmental and social
NGOs, local
locations that also action plans. administrations, libraries)
provide visitors and for the duration of a
readers with an disclosure period or
opportunity to leave their permanently. Audience
comments in a feedback are also given free access
register. to a register of comments
and suggestions.
Dedicated telephone line Setting up a designated Any issues that are of Telephone numbers are Local communities within
(hotline) and manned telephone interest or concern to the specified on the printed the Project Area of
line that can be used by local communities and materials distributed to Influence. Any other
the public to obtain other stakeholders. Project stakeholders and stakeholders and
information, make are mentioned during interested parties.
enquiries, or provide public meetings.
feedback on the Project. Project’s designated staff
Initially, telephone should be assigned to
numbers of Project’s answer and respond to

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 specialized staff can be the calls, and to direct
shared with the public, callers to specialist
particularly staff involved experts or to offer a call-
in stakeholder back if a question
engagement, public requires detailed
relations and consideration.
environmental
protection.
Internet/Digita l Media Launch of Project Information about A link to the Project web- Affected and interested
website to promote Project operator and site should be specified parties
various information and shareholders, Project on the printed materials
updates on the overall development updates, distributed to
Project, impact health and safety, stakeholders. Other on-
assessment and impact community relations, line based platforms can
management process, community updates, also be used, such as web
procurement, employment and conferencing, webinar
employment procurement, presentations, web-based
opportunities, as well as environmental and social meetings, Internet
on Project’s engagement aspects. surveys/polls etc.
activities with the public. Limitation: Not all
Web-site should have a parties/stakeholders have
built-in feature that access to the internet.
allows viewers to leave
comments or ask
questions about the
Project. Website should
be available in two
languages – English and
Kiswahili.
Surveys, Interviews and The use of public opinion Description of the Soliciting participation in Directly affected
Questionnaires surveys, interviews and proposed Project and surveys/interviews with households in the Project
questionnaires to obtain related solutions/impact specific stakeholder Area of Influence. Other
stakeholder views and to management measures. groups or communities within the
complement the statutory Questions targeting communitywide. Project Area of Influence.

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 process of public stakeholder perception of Administering
hearings. the Project, associated questionnaires as part of
impacts and benefits, the household visits.
concerns and suggestions.
Feedback & Suggestion A suggestion box can be Any questions, queries or Appropriate location for Directly affected
Box used to encourage concerns, especially for a suggestion box should households in the Project
residents in the affected stakeholders that may be selected in a safe Area of Influence. Other
communities to leave have a difficulty public place to make it communities within the
written feedback and expressing their views readily accessible for the Project Area of Influence.
comments about the and issues during public community. Information
Project. Contents of the meetings. about the availability of
suggestion box should be the suggestion box
checked by designated should be communicated
Project staff on a regular as part of Project’s
basis to ensure timely regular interaction with
collection of input and local stakeholders.
response/action, as
necessary.
Consultation & Participation
Public hearings Project representatives, Detailed information on Wide and prior Directly affected
the affected public, the activity and/or facility announcement of the communities in the
authorities, regulatory in question, including a public hearing and the Project Area of Influence.
bodies and other presentation and an relevant details, including Other communities
stakeholders for detailed interactive Questions & notifications in local, within the Project Area of
discussion on a specific Answers session with the regional and national Influence. Residents of in
activity or facility that is audience. mass media. Targeted the Project Area of
planned by the Project invitations are sent out to Influence
and which is subject to stakeholders.
the statutory expert Public disclosure of
review. Project materials and
associated impact
assessment
documentation in
advance of the hearing.

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 Viewers/readers of the
materials are also given
free access to a register of
comments and
suggestions that is made
available during the
disclosure period.
Household visits Household-level visits Description of the Visits should be Directly affected in the
can be conducted to Project and related conducted by Project’s Project Area of Influence.
supplement the statutory solutions/impact designated staff with a
process of public management measures. specified periodicity.
hearings, particularly to Any questions, queries or Limitation: logistical
solicit feedback from concerns, especially for challenges in reaching
community members and stakeholders that may households in remote
vulnerable persons who have a difficulty locations.
may be unable to attend expressing their views
the formal hearing and issues during formal
events. community-wide
meetings.
Focus Group Discussions Used to facilitate Project’s specific Announcements of the Directly affected
and Round Table discussion on Project’s activities and plans, forthcoming meetings are households in the Project
Workshops specific issues that merit design solutions and widely circulated to Area of Influence, youth,
collective examination impact participants in advance. elderly, women, and other
with various groups of mitigation/management Targeted invitations are vulnerable groups.
stakeholders. measures that require sent out to stakeholders.
detailed discussion with
affected stakeholders.
Information centers and Project’s designated Project-related materials. Information about the Directly affected
field offices venue for depositing Any issues that are of info center or a field communities in the
Project-related interest or concern to the office with open hours Project Area of Influence
information that also local communities and for the public, together and any other
offers open hours to the other stakeholders. with contact details, is stakeholders and
community and other provided on the Project’s interested parties.
members of the public, printed materials

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 with Project staff distributed to
available to respond to stakeholders, as well as
queries or provide during public meetings
clarifications. and household visits.
Site Tours Visits to Project Site and Demonstration of Targeted invitations Local communities within
facilities organized for specific examples of distributed to selected the Project Area of
local communities, Project’s design solutions audience offering an Influence. Elected
authorities and the media and approaches to opportunity to participate officials. Media groups.
to demonstrate Project managing impacts. in a visit to the Project NGOs and other
solutions. Visitors are Site. Limitation: possible initiative groups.
accompanied by the safety restrictions on the
Project’s staff and site access during active
specialists to cover construction works.
various aspects and to
address questions arising
from the public during
the tour.

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4.4 Past Stakeholder Engagement for KISIP I
Consultations for KISIP I were held in 2010 as part of project preparation. More specifically, during
the preparation of the Environmental and Social Management Framework (ESMF) and
Resettlement Policy Framework (RPF). KISIP I continued with stakeholder engagement during
construction phase. Issues from these engagements will largely inform KISIP II. More detailed
stakeholder engagement will be undertaken once the project sites and interventions are determined.
The following table presents a summary of stakeholder concerns from KISIP I.
Table 8: Summary of Stakeholder Concerns to Date
Topic / Issue Stakeholder Concerns LTWP’s Comments and Actions
Employment • Very high expectations of • KISIP and contractors
opportunities employment. committed to employment of
local people, but will need to
manage unrealistic expectations.
• Establishment of Recruitment
Office to register potential
candidates.
• KISIP to monitor number of
locals employed by Project.
Training Implicit desire of affected people • The nature and timescale of
opportunities for training to develop new / construction works and the small
existing skills needed for operations phase workforce
employment or to support means that there is only very
entrepreneurial ambitions limited scope for any substantial
skills training.
• However, skills development is
part of the project interventions
Education Implicit desire of affected people As for training, the Project has little
opportunities to receive education / support for scope for direct interventions in
children as compensation. education provision.
Health and safety Traffic accidents because the • Extensive prior consultation and
access roads being upgraded pass further planned engagement on
through heavily settled areas-from the road rehabilitation
a high volume of heavy goods component and traffic safety.
vehicles carrying materials and • Elaboration of the Transport
equipment plus workforce Management Plan and liaison
transport during the construction with relevant public roads
period. authorities.
• Installation of temporary /
permanent road warning signage.
• Stakeholder grievance
mechanism to address
complaints.
Land acquisition Uncertainty due to changes to • Avoidance and minimization of
and resettlement / homes, businesses and lands – e.g. land take.

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loss of livelihood replacement of assets; • Definition and implementation
compensation levels may not be of RAPs in accordance with RPF.
sufficient to meet actual costs; etc. • Stakeholder grievance
mechanism to address
complaints.
Local economic • Potential local service • KISIP committed to stimulating
stimulation and providers could be keen to business and ensuring local
business participate in providing content in procurement activities
development services to KISIP and its where practicable, but may need
contractors, but lack to manage any unrealistic
information on how to adjust expectations
their businesses to meet new • Consideration of range of
needs. measures to facilitate local
• Local entrepreneurs may want procurement/ services.
support (e.g. capacity building,
access to microfinance and
order commitments) to
develop and sustain their
businesses.
Environmental / • Dust and noise impacts, • Implementation and enforcement
nuisance impacts particularly along the main of range of environmental
road corridor management measures to deal
• Environmental degradation with nuisance impacts, including
and noise disturbance during noise and dust monitoring.
road construction and use. • Participative community
• Loss and change of vegetation monitoring of dusts along the
due to soil degradation. road rehabilitation route.
• Increased waste near • Stakeholder grievance
construction sites and Project mechanism.
facilities.
Access to water / Increased demand for water which • Implementation and enforcement
water quality is already in scarce supply due to of range of environmental
introduction of Project workforce management measures to deal
and possibly other in-migrants. with protection and conservation
of water resources.
• Participative community
monitoring of water resources.
• Stakeholder grievance
mechanism.
Biodiversity and • Preservation of the nearby • Avoidance of direct impacts
protected areas protected sites - National Parks, upon any protected areas.
Biosphere Reserve and other parks • Implementation and enforcement
/ forestry reserves etc. of range of environmental
management measures to protect
flora and fauna and deal with
invasive alien species.

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Protection of Protection of any historically • Consultation with communities
cultural heritage significant heritage, traditional and National Museums of Kenya
ways of life and the diffusion of (NMK) on any concerns.
cultures alien to local ethnic • Definition and implementation
identities in the project sites. of robust Chance Finds
Procedure in accordance with
international standards.

4.5 Stakeholder Consultations for KISIP II

Stakeholder’s consultations were undertaken with the aim of providing a platform for project
stakeholders to air their views, concerns and recommendations on the draft safeguards instruments
for incorporation into the final instruments.

A 2-day consultation workshop specifically targeting the County governments was held with the 14
counties who participated in KISIP 1. This was attended by two officers from each county – an
Environmentalist and a Community Development Officer, and held on 26th and 27th September
2019 in Nairobi. Targeting the communities, and in order to have a representative sample of the
fourteen counties and 137 informal settlements that KISIP I is working in, a sample of three
counties i.e. Nairobi, Machakos and Nakuru (Naivasha) was drawn. Out of these, 11 settlements
were selected for the consultations with a mix of settlements benefitting from Infrastructure
upgrading and/or tenure regularization.

The findings from the consultative workshops is summarized below:

1. Consultations during project planning and implementation need to involve as diverse

stakeholders as possible, as per project requirements at the time, and in a timely manner. A
possible list of stakeholders includes:
• Political stakeholders (Member of County Assembly, Member of National Assembly)
• Water and Sewerage service providers
• Settlement people
• Settlement Executive Committee
• Kenya Urban Roads Authority
• Road Agencies and Kenya railways
• National Land Commission (NLC)
• Civil society/Non-Governmental Organizations/ Community Based
Organizations/Faith based organizations
• Water Agencies
• Neighborhood associations
• Relevant County Government Ministries E.g. Ministry of lands and physical
planning, Education, Public Health
• County Administration
• Relevant National Government Ministries E.g. Ministry of Interior, Education
• Business community/bodaboda/matatu saccos
• Kenya Power and Lighting Company

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 • Town Managers
• National Environmental Management Authority (NEMA)
• Kenya Forestry Service
• County commissioners
• Contractors and Consultants
• Farm owners/Private residents surrounding the settlements

2. SEC/GRC: The two committees are effective but some lapses in resolving grievances
escalated to contractor and KISIP County/National were cited. In addition, it was noted
that there is a need for KISIP to strengthen the working relationship of SEC/GRC with
contractors. Suggestions were made to formally introduce the parties to each other at
commencement of the projects and ensure sustainability through participation in site
activities, namely, monthly progress review site meetings and regular monitoring of project
impacts.

The capacity of the SEC/GRC needs enhancement through training and provision of
necessary resources e.g. office space in the settlements, airtime, stationery and for GRCs to
provide Logs, blackbooks/registers. Where facilitation of SEC/GRC is done by
contractors, these are considered to be less effective.
SEC/GRC roles and responsibilities need to be better defined due to overlapping mandate
to avoid conflict and duplication.

There is need to consider SEC/GRC timelines more so lifeline of the committees. The
committees need to be revisited in a timely manner to assess their effectiveness,
composition changes, and enable action on the same.
There is need for a mechanism to track grievances progress at settlement and
county/national level.
3. Livelihood Restoration: There is a need to enhance livelihood restoration provisions for
affected traders since current allocations are reportedly insufficient for the intended
purpose.
4. Operation and Maintenance of infrastructure: O&M of infrastructure is insufficient,
where both County and community are not maintaining the infrastructure to the required
levels. Specifically, poor solid waste management affects existing is a key threat to drainage
infrastructure.
5. Project Handing over: Generally, the consulted communities alleged that they were not
aware that infrastructure projects had been completed and handed over to the County
Government. This is with the exception of flood mast lighting where the community was
trained and adequately involved. The lack of community involvement at this critical stage
was cited as a major cause for Contractor’s getting off the hook without addressing some
defects, omissions and pending community claims.
6. Design of Infrastructure: Designs are not effectively informed by emerging issues, the
community understanding of the settlements, and other needs e.g. presence of vulnerable
groups despite socio-economic surveys been undertaken. In some cases, these designs
exacerbate existing problems e.g. flooding rather than seeking to address them or pose
some safety threats to residents especially children, disabled, elderly.
7. Information Disclosure: The use of existing sources and linking to newer concepts of
Government of Kenya run Huduma centers was encouraged. KISIP PCT should liaise with

Page | 49
 county communication offices; make use of existing resource centers in the settlements,
social media, magazines, brochures, documentaries et al.
8. In all consultations carried out with the various stakeholder groups, the message was the
same across the board; the vulnerable and marginalized groups in the sense of the VMGF
do not exist within the target informal settlements. However, other categories of vulnerable
groups exist e.g. street children.
9. Unintended Project impacts: The project has some in some cases brought about
undesired impacts to e.g. an increase in house rent is a positive impact for structure owners
but negative for tenants.
10. Vulnerable Persons: Opportunities (based on case examples) exist to enrol chiefs, county
in providing additional non-monetary assistance to some groups in e.g. rebuilding of
structures.
11. Training on safety awareness was indicated as inadequate and needs enhancement and
budgeting in contracts.
12. There is a general perception that County focus/enforcement of safeguards is lacking
despite their attendance of the various meetings at settlement level.

The issues from consultations were used to improve the design of KISIP II in such areas as:
a) Strengthening community involvement in the project from planning, designing,
implementation, and operation and maintenance
b) Provide for capacity building for safeguards management at all levels: Community, technical
staff at Count and National PCT, Grievance Redress Committees, contractors
c) Strengthen grievance redress procedures by publicizing them, and ensuring their
effectiveness
d) Plan for operational and maintenance of infrastructure before hand
e) Improve procedures for reporting and acting on occupational health and safety issues

The record of Stakeholder Engagement is presented as a separate document.

4.6 Planned Engagement with Affected Communities and Parties

Stakeholder engagement activities will need to provide stakeholder groups with relevant information
and opportunities to voice their views on topics that matter to them. Table 7 presents the
stakeholder engagement activities KISIP II will undertake for the sub- project(s). The activity types
and their frequency are adapted to the three main project stages: project preparation (including
design, procurement of contractors and supplies), construction, and operation and maintenance.

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Table 9: Planned Stakeholder Engagement Activities
Target Topic(s) of engagement Method(s) used Location/frequ Responsibilities
Stage

stakeholders ency

Project Affected • ESMF, ESMP, RPF, SEF, RAP, • Public meetings • In the • Safeguard team
STAGE 1: P ROJECT PREPARATION (P ROJECT

People: VMGF/VMGP (if triggered) • Face-to-face settlements/ • CLO

• People disclosures meetings project sites • Specialists
potentially • Project scope and rationale • Mass/social at beginning responsible for land
SCOPING, R ESETTLEMENT P LANNING

affected by • Project E&S principles - media of acquisition

land Resettlement and livelihood communication construction • RAP consultant
acquisition restoration options (as needed) that would
• People • Grievance mechanism process • Written affect the
ESMF/RPF/SEF D ISCLOSURE)

residing in information: area

project area brochures, • Continuous
• Vulnerable posters, flyers, communicati
households website on through
Information mass/social
boards or desks media and
• Newsletter routine
interactions -
Throughout
DESIGN,

RAP
development
as needed

Page | 51
Other Interested • ESMF, ESMP, RPF, SEF, RAP, • Face-to-face • Throughout • Safeguards Team
Parties (External) VMGF/VMGP meetings - Joint RAP • CLO
• Project scope, rationale and E&S public/commu development • Specialists
principles nity meetings as needed responsible for land
• Grievance mechanism process with PAPs • Project acquisition
launch • RAP consultant
meetings
• Quarterly
meetings in
affected
settlements
• Disclosure
meetings

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Other Interested • ESMF, ESMP, RPF, SEF, RAP, • Public • Project • Safeguard team
Parties VMGF/VMGP disclosures meetings, launch • CLO
(External) • Grievance mechanism trainings/works meetings
• Press and • Project scope, rationale and E&S hops (Separate • Meetings in
media principles meetings affected
• NGOs and specifically for settlements
CBOs, women and as needed
• Businesses vulnerable as • Communicat
and business needed) ion through
organizations • Mass/social mass/social
• Academic media media (as
institutions communication needed)
National • Disclosure of • Information
Government written desks with
Ministries information: brochures/p
• General Brochures, osters in
public, posters, flyers, affected
jobseekers website settlements
• Information (continuous)
boards or desks
in
Counties/settle
ments
• Notice board
for employment
recruitment

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Other Interested • Legal compliance issues • Face-to-face • Disclosure • Safeguard team
Parties • Project information scope and meetings meetings • CLO
(External) rationale and E&S principles • Invitations to • Reports as
• Other • Coordination activities public/commu required
Government • Land acquisition process nity meetings
Departments • Submission of
• Grievance mechanism process
from which required reports
permissions/c • ESMF/ESMP/RPF/VMGF/V
learances are MGP/SEF disclosures
required;
• Other project
developers,
donors
Other Interested • Project information: scope and • Face-to-face As needed • Safeguards team
Parties rationale and E&S principles meetings • Project management
(Internal) • Training ESMF/ESMP/VMGP • Trainings/work team
• Other Project requirements and other shops • CLO
staff management plans • Invitations to
• Supervision • Grievance mechanism process public/commu
Consultants • E&S requirements - Feedback nity meetings
• Contractors, on consultant/ contractor
sub- reports
contractors,
service
providers,
suppliers, and
their workers

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 Project Affected • Grievance mechanism • Public • Quarterly • Safeguards team
People • Health and safety impacts (EMF, meetings, open meetings
• People community H&S, community houses, during • Project management
potentially concerns) trainings/works construction team
affected by • Employment opportunities hops seasons
STAGE 2: C ONSTRUCTION AND MOBILIZATION ACTIVITIEs

• CLO
land • Project status • Separate • Communicat
acquisition meetings as ion through • Supervision and
• People needed for mass/social RAP consultants
residing in women and media as
project area vulnerable needed • Contractor/subcont
• Vulnerable • Individual • Notice ractors
households outreach to boards
PAPs as needed updated
• Disclosure of weekly
written • Routine
information: interactions
brochures, • Brochures in
posters, flyers, local offices
website
Information
boards in
settlements
• Notice board(s)
at construction
sites
• Grievance
mechanism
monthly
newsletter

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Other Interested • Project scope, rationale and E&S • Face-to-face As needed • Safeguards team
Parties principles meetings (monthly during • CLO
(External) • Grievance mechanism • Joint construction • Supervision and
• Governmenta • Project status public/commu season RAP consultants
l institutions • World Bank compensation nity meetings • Contractor/subcont
for land use requirements with PAPs ractors
and
compensation
(MBC)
• Settlements
Executive
Committees (
SECs)
• Other • Project information - scope and • Public Same as for • Safeguards team
Interested rationale and E&S principles meetings, open PAPs • CLO
Parties • Project status houses,
(External) • Health and safety impacts trainings/works
Press and • Employment opportunities hops
media
• Environmental concerns • Disclosure of
• NGOs written
• Grievance mechanism process
• Businesses information:
and business brochures,
organizations posters, flyers,
• Academic website,
institutions Information
• National boards in
Government settlements
Ministries and • Notice board(s)
Departments at construction
• General sites
public, • Grievance
jobseekers mechanism

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 Other Interested • Project information: scope and • Face-to-face Daily, as needed • Safeguards team
Parties rationale and E&S principles meetings - • Supervisors
(Internal) • Training on ESMF/ESMP Trainings/work
• Other project requirements and other sub- shops
staff management plans • Invitations to
• Supervision • Worker grievance mechanism public/commu
Consultants nity meetings
• Contractor,
subcontractor
s, service
providers,
suppliers and
their workers
Project Affected • Satisfaction with engagement • Outreach to • Outreach as • County Safeguards
People: activities and GRM - Grievance individual PAPs needed team
• People mechanism process • Website • Meetings in
residing in • Damage claim process • affected
PERATION AND
MAINTENANCE

Grievance
project area mechanism settlements
• Vulnerable (as
STAGE 3: O

• newsletter
households needed/requ
ested)
• Monthly
(newsletter)

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Other Interested • Grievance mechanism process • Grievance As needed Safeguards team &
Parties • Issues of concern mechanism management
(External) • Status and compliance reports • Website
• Press and • Face-to-face
media meetings
• NGOs • Submission of
• Businesses reports as
and business required
organizations
• Workers'
organizations
• Academic
institutions
• Local
Government
Departments
• General
public

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4.7 Stakeholder Engagement Process
Table 9 presents a provisional Stakeholder Engagement Action Plan for the Project. The provisional version has
been prepared by KISIP to facilitate project appraisal. The will be reviewed and updated frequently, a minimum
6-monthly basis or as needed by specific circumstances during the construction and operation phases.
Routine engagements may simply be planned using the Community Liaison diary to record date/time, location,
purpose and participants. If needed for new or more complex engagement plans, individual Stakeholder
Engagement / Community Liaison Planning Form (Appendix B) are completed by the CLO and authorized by
the HoS to ensure proper preparation of each new engagement campaign, event or activity, including
consideration of any practical issues, potential risks associated and whether or not differentiated measures such as
a culturally appropriate approach are needed when engaged with vulnerable groups.
Contact Reports (Appendix 3) are used to record feedback from all pertinent interactions with stakeholders,
except for grievances which are recorded and processed as per the GRM procedure. This form will be completed
by the CLO or any other project employee or consultant undertaking stakeholder engagement activities.
The stakeholder database will be updated with information from the Contact Reports to facilitate key word
searches on specific topics, generate lists of target stakeholder groups and support the planning of engagement
and liaison activities.
In addition, the Stakeholder Commitments Register (Appendix 5) is used to track all new environmental and
social commitments made by KISIPP to its various stakeholders over the life of the Project and ensure timely
follow-through on its promises. This is another ‘live’ document which is maintained by the CLO. It records all
specific commitments to action made to various stakeholders, assigning the various actions and timescale needed
to discharge the obligation.
A formal review of the stakeholder engagement process shall be undertaken annually or whenever a significant
change is needed in order to fulfil KISIP’s commitment to continual improvement. Additionally, KISIP will
undertake Human Rights due diligence reviews at appropriate intervals during the Project in order to identify any
new or changed risks and impacts in line with the principle of continual improvement.
Human Rights Due Diligence is an iterative risk management process that is undertaken in order to identify,
prevent, mitigate and account for any negative human rights impacts. It considers the host country context,
potential and any actual human rights impacts resulting from Project activities; and the business relationships
connected to those activities (e.g. between the proponent and its clients, suppliers / contractors, public
authorities / agencies and other organizations).
The process is defined in the UN’s Guiding Principles on Business and Human Rights and includes 4 key steps:
(i) assessing actual and potential human rights impacts
(ii) integrating and acting on the findings
(iii) tracking responses, and
(iv) communicating how the impacts are addressed.

4.8 Measures to Improve Stakeholder Engagement

To improve its stakeholder engagement methodology, integrating it within its management systems and meeting
the international standards required by the World Bank, the following will be introduced:
• Review of existing stakeholder database and identification records to include consideration of stakeholders’
rights and/or duties as well as their capacity to engage meaningfully with KISIP (i.e. factors such vulnerability,
Page | 59
literacy, traditional lifestyle and decision-making via village elders, etc.). Records will be reviewed and updated to
reflect any notable changes in stakeholder status or circumstances;
• A Commitments Register is introduced to collate and track all new environmental and social commitments
made by KISIP to its various stakeholders over the life of the project and ensure timely follow-through on its
promises. This is an essential tool for building trust and establishing good working relationships with stakeholders
and will sit alongside the Framework ESMP and its Consolidated Register of ESIA Obligations;
• Implement a Stakeholder categorization to facilitate the prioritization of both “affected communities, groups
and individuals” and “other interested parties” in order to ensure the effective of planned engagement and liaison
activities. A stakeholder mapping process is being added to help define appropriate levels and types of
engagement required for each defined stakeholder category, facilitating due attention to vulnerable or
marginalized groups;
• Key Stakeholder Profiles (see example format in Appendix 1) will be maintained for both designated key
informants and those affected parties which have influence or are subject to high impacts, the knowledge and
legitimacy, and are capable and willing to engage with KISIP;
• A Vulnerability Screening Checklist (see Appendix 4) to facilitate evaluation of capacity and identify any future
change in status to facilitate a re-evaluation of mitigation assistance where essential;
• Stakeholder Engagement / Community Liaison Planning Form (see example format in Appendix 2) introduced
to ensure proper preparation of each event or activity, including consideration of range of practical issues, the
potential risks associated and a culturally appropriate approach; and
• Contact Reports (see example in Appendix 3) are being introduced to record all interactions with stakeholders,
except for grievances which are recorded and processed as per the GRM. This form will be completed by the
CLO or any other employee or consultant undertaking stakeholder engagement activities. The stakeholder
database will be updated with information from the Contact Reports to facilitate key word searches on specific
topics, generate lists of target stakeholder groups and support the planning of engagement and liaison activities.

5.0 Disclosures
The KISIP website will be used to disclose project documents, including those on environmental and social
performance. This will begin with disclosure of this draft SEF and the draft ESMF and RPF. Besides the draft
disclosure documents (and the final documents in future), project brochures and updates will be posted. An easy-
to-understand guide to the terminology used in the environmental and social reports or documents will also be
posted on the website. In addition, the site will provide details about the Grievance Redress Mechanism and
contact details for the Community Liaison Officer (CLO). KISIP will update and maintain the website regularly.

5.1 Disclosure of ESMF, RPF, and SEF

Project materials (ESMF, ESMP, SEF, RFP, VMGF) shall be disclosed for public review and comment. KISIP
will continue applying the similar approach to disclosure for any additional E&S appraisal materials that will be
prepared as part of the project development.

The ESMF report (together with the associated environmental and social management plan – ESMP), RPF,
VMGF and SEF shall be made available for public review for the period of 60 days in accordance with the
international requirements.

Distribution of the disclosure materials will be accomplished by making them available at venues and locations
frequented by the community and places to which public have unhindered access. Free printed copies of the
ESMF/ESMPs, VMGF/VMGP, RPF/RAP and the SEF will be made accessible for the general public at the
following locations:
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 a. The National Project office;
b. All the County Project Offices
c. At the Ward Administrator’s and Chief’s Offices in the project report
d. Community Settlement Executive Committees
e. Local NGO offices where available; and
f. Other designated public locations to ensure wide dissemination of the materials.

Electronic copies of the ESMF, ESMP, VMGF, RFP, RAP (as required) and SEF shall be uploaded on the KISIP
website: http://www.urbanandhousing.co.ke/kisip/. This allows stakeholders with access to Internet to view
information about the planned development and to initiate their involvement in the public consultation process.

The mechanisms used for facilitating input from stakeholders include press releases and announcements in the
media, notifications of the aforementioned disclosed materials to local, regional and national NGOs as well as
other interested parties.

The disclosure process will include the following:

a. Placement of the ESMF, RPF, and SEF in public domain
b. 60-day disclosure period
c. Public consultation meetings in project affected communities and with other stakeholders to present and
discuss findings of the documents.
d. Addressing stakeholder feedback received on the entire disclosure package.

The SEF will remain in the public domain for the entire period of project development and will be updated on a
regular basis as the project progresses through its various phases, in order to ensure timely identification of any
new stakeholders and interested parties and their involvement in the process of collaboration with the project.
The methods of engagement will also be revised periodically to maintain their effectiveness and relevance to the
project’s evolving environment.

Apart from disclosure in the project areas, the safeguard instruments will also be disclosed in the World Bank
external website.

6.0 Grievance Mechanism

Effective and timely response to community complaints is essential for maintaining good community relations.
KISIP is committed to having an effective complaints handling system that reflects the needs, expectations and
rights of complainants.
The guiding principles for managing complaints are:
a) Fairness: The grievance redress system will treat complainants with respect and courtesy. The rules of
natural justice apply and, where appropriate, all parties involved in the complaint will be given the
opportunity to respond to any issues raised.
b) Transparency and accessibility: The complaints handling system will be well known to stakeholders, staff
and contractors. It includes information about the right to complain, how to do it, where to do it and
how the complaint will be handled. Details on the complaints handling process will be available to all.
There is no charge to the complainant for accessing the complaints handling system. The complaints
handling system and supporting information aims to be easy to understand, use, and be in plain language.
Interpreter services should be provided, where possible, for people from a non-English speaking
background.

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 c) Responsiveness: Complaints will be dealt with quickly, courteously, fairly and within established timelines.
Complainants will be advised of how long it will take to deal with the complaint in accordance with
complaint handling timelines and kept informed of the progress. If additional time is required to resolve
the issues the complainant will be kept informed and advised of the additional time required and the
reasons for the delay. If the complaint is still not resolved to the complainant’s satisfaction, we will
explain our decision clearly, and offer any possible alternative actions or review opportunities.
d) Privacy and confidentiality: The complaint handling process will ensure complainant confidentiality and
also ensure confidentiality in the case of complaints against staff. Details of complaints should only be
known by those directly concerned.
e) Accountability: The complaint handling system is open to scrutiny by members of the public and other
oversight bodies e.g. the Ombudsman. An appropriate reporting mechanism on the operation of the
complaints process will be maintained. KISIP shall maintain a complaints register and regularly audit the
complaints handling system with appropriate action plans formulated to address any deficiencies.
KISIP has a developed methodology of recording and resolving grievances in the Resettlement Policy
Framework (RPF) based on the lessons learnt in KISIP I. The channels of uptake at all levels will include walk-
ins, face-to-face communication, toll-free calls, letters, e-mails, text messages, WhatsApp, etc. The mediation
process shall be confidential, transparent and objective, as well as accountable, easy, fast, accurate and
participative. The general steps of the grievance process have been summarized in Table 6-1 below and
comprise:

1. Registration/receipt/Acknowledgment of Complaints
2. Investigate and determine solution to the complaint
3. Implementing the Redress Action;
4. Verifying the Redress Action;
5. Monitoring and Evaluation; and
6. Recourse or Alternatives

Table 0-1: Grievance Redress Mechanism

Step Process Description Timeframe Responsibility
1 Grievance receipt • Face to face; phone; letter, 1-2 Days An aggrieved party or
and registration/ recorded during PAPs.
logging public/community
meetings; WhatsApp etc. GRCs
• Significance assessed and
grievance recorded or
logged using the model
complaint form and filed.
2 Development and • GRC meets or takes a 5- 10 Days GRC
implementation of decision on the grievance
response • Grievance assigned to
appropriate party for
resolution if necessary
• Response development
with input from relevant
stakeholders
• Redress response/action
approved by GRC and
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 logged
• Redress response/update
of progress on resolution
communicated to the
complainant
• Start implementing redress
action
3 Verifying the • Redress action 10-15 Days Environmental
implementation of implemented and verified (Social)
redress action by GRC. Officer/Safeguard
• GRC satisfied with Specialist at County
implementation of redress
action
• Complainant duly signed
the grievance resolution
form
4 Close grievance or • Completion of redress 15-25 Days Environmental
refer grievance to action recorded or logged (Social)
2nd tier resolution • Confirm with complainant Officer/Safeguard
that grievance can be Specialist at County/
closed or determine what Grievance Officer
follow up is necessary
• Record final sign off of
grievance
• If grievance cannot be
closed, return to step 2 or
recommend to the next
tier- County, National
5 Court of law If 2nd and third level Unknown Safeguard Specialist at
settlement does not address KISIP
dispute, complainant can
resort to court of law
6 Monitoring and Grievance Redress Safeguard Specialist at
evaluation, and Mechanism Process is KISIP
reporting documented and monitored

The Grievance Officers at County and National level will establish a register of grievances and disputes. The
receipt of complaints will include its logging and registration as this will help with monitoring the status of the
grievances and ease reporting on them. The existence and conditions of access to this register (where, when,
how) will be widely disseminated within the project community/town as part of the consultation undertaken for
the project in general. The person designated to receive complaints shall receive all complaints and shall officially
register these complaints using the first section of the proposed complaint registration and resolution form
provided in Appendix 9.

This RPF recommends a four-tier grievance mechanism- at the community, County, national and resolution
through courts of law. It is desirable to resolve all the grievances at the community level to the greatest extent
possible. To achieve the community or settlement level grievance mechanism must be credible and generally
acceptable. The grievance redress mechanisms will aim to solve disputes at the earliest possible time in the
interest of all parties concerned.

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The first level in addressing grievances will be at the settlement. The settlement will form a Settlement Grievance
Redress Committee comprising of two members from SEC, and three other respected community members who
are not PAPs. The committee should be elected by the community in a transparent manner and after sensitisation
by KISIP PCT.

The second level of grievance mechanism will involve the County Resettlement Implementation Committee
(CRICs). The CRICs will consider grievance reports forwarded to it from the community grievance committee
and make a determination. The CRIC will comprise of the County Coordinator, Environment Officer,
Social/Community Officer, Component Heads for Infrastructure, and Land tenure, Assistant Deputy County
Commissioners, and Ward Administrator4.

The third level of grievance mechanism will involve the National PCT, (NRIC) which will comprise of the
National Project Coordinator, Heads of Components, Environment and Social Safeguard heads, and a designated
Grievance Redress Officer who will be the Secretary. It will handle grievances referred to it by the CGRCs and
monitor the performance of the whole GRM for the project. The NRIC will also provide overall coordination of
the implementation of this RPF.

If complainants are not satisfied by the decisions of the grievances committees, they can seek redress from the
High court.

Grievance procedures may be invoked at any time, depending on the complaint. No person or community from
whom land or other productive assets are to be taken will be required to surrender those assets until any
complaints he/she has about the method or value of the assets or proposed measures are satisfactorily resolved.

6.1 Worker Grievance Procedure

KISIP is committed to enforcing comprehensive labor and employment policies, including its requirements on
workplace discrimination and harassment, across the entire workforce. This policy requires that all employees and
contractor workers are to be treated fairly, with dignity and respect, and have equal employment opportunities.
KISIP contractors will be required to develop a Labour Management Plan that includes an authorized process for
workers to raise grievances and concerns to senior management, covering any issues that are work related, that
affect an employee or contractor, or that an employee deems unfair. Such concerns may relate (but are not
limited) to the following:
• Management decisions;
• Occupational health and safety concerns;
• The behavior or conduct of another employee, manager, or contractor; and
• The effects of KISIP’s contractors’ Human Resources policy or procedures.

KISIP will ensure that all grievances raised by workers are treated impartially, respectfully and confidentially. The
employee grievance process is separate from the aforementioned RAP grievance procedures.

7.0 Outreach Approaches

7.1 Project Tours

At appropriate points during the construction phase, if there is sufficient interest, KISIP may organize site visits
or demonstration tours for selected stakeholders from media organizations or local governments.

4
One staff based at County Government will be designated as a grievance officer for monitoring and tracking progress.

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7.2 Citizen/PAP Perception Survey
A perception survey examining citizen’s experience and feedback about the project will be carried out twice
during the project’s lifecycle: during mid-term review and end-of Project review. Results of these surveys will be
reviewed carefully to identify refinements or changes in project methods and procedures that may be needed to
reduce impacts or improve efficiency.

7.3 Trainings and workshops

Finally, trainings on a variety of social and environmental issues will be provided to KISIP and contractor staff
and possibly to interested government or nongovernment service providers. Issues covered could include such
topics as the worker code of conduct, gender based violence and the worker grievance mechanism. KISIP may
also provide training to residents on various topics including hygiene and sanitation, operation and maintenance.

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8.0 Monitoring, Evaluation and Reporting
8.1 Monitoring and Reporting
The Stakeholder Engagement Plan will be periodically revised and updated as necessary in the course project
implementations in order to ensure that the information presented herein is consistent and is the most recent,
and that the identified methods of engagement remain appropriate and effective in relation to the project context
and specific phases of the development. Any major changes to the project related activities and to its schedule
will be duly reflected in the SEF.
Monthly summaries and internal reports on public grievances, enquiries and related incidents, together with the
status of implementation of associated corrective/preventative actions will be collated by responsible staff and
referred to the senior management of the project(s). The monthly summaries will provide a mechanism for
assessing both the number and the nature of complaints and requests for information, along with the Project’s
ability to address those in a timely and effective manner.
Contact Reports are to be prepared by CLO or other relevant function whenever an external consultation event is
conducted. Meeting minutes are also to be kept for community meetings and other ESHS engagement activities
held with affected stakeholders.
Where considered beneficial, participative community monitoring programmes will be introduced to check
project impacts and the effectiveness of mitigation programs). The HoS and/or the CLO will establish suitable
environmental and/or social topics for this approach, identify potential participants from amongst the affected
communities, and provide any capacity building / training. The output (reports from participants) from such
monitoring is likely to be verbal (meetings or telephones) and will be recorded by the CLO.
Other project teams shall maintain suitable monitoring measures for engagement with interested parties / other
stakeholders such as national government and its agencies, non-government organizations and the general public.
All new commitments made by KISIP or its representatives to stakeholders are to be entered into the
Commitments Register.
Information on public engagement activities undertaken by the Project during the year may be conveyed to the
stakeholders in a standalone annual report on project’s interaction with the stakeholders.
8.2 Monitoring Indicators
A number of Key Performance Indicators (KPIs) will also be monitored by the project on a regular basis,
including the following parameters:
a) Number of public hearings, consultation meetings and other public discussions/forums conducted within
a reporting period (e.g. monthly, quarterly, or annually);
b) Number of participants attending consultation meetings and other forums disaggregated to show women,
and vulnerable and marginalized persons;
c) Frequency of public engagement activities;
d) Geographical coverage of public engagement activities – number of locations and settlements covered by
the consultation process, including the settlements in remote areas within the Project Area of Influence
(PAI);
e) Number of public grievances received within a reporting period (e.g. monthly, quarterly, or annually) and
number of those resolved within the prescribed timeline;

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 f) Type of public grievances received;
g) Number of press materials published/broadcasted in the local, regional, and national media;

8.3 Information Sharing

Information sharing and knowledge transfer is an important part of the successful transition from the planning
and design phase to detailed design and delivery phase of the sub-projects.
KISIP and sub-project contractors will work together to ensure the contractors have a strong understanding of
the project’s stakeholders and their interests, concerns and desired outcomes for the project, based on
engagement undertaken to date. This will minimize the need for contractors to revisit matters that stakeholders
have previously raised with KISIP.
To ensure ongoing information sharing, KISIP will establish regular coordination meetings with the works
contractors, involve contractors in the reference groups and encourage contractors to engage with each other,
particularly where work packages overlap or construction issues are similar.

9.0 Implementation Budget

The implementation of the SEF is a shared responsibility between the National Government (National PCT) and
the County Governments (County PCT). The Costs will therefore be spread over the two levels of Government.
The following is an indicative budget for implementation of Stakeholder Engagement Plan (SEP) for each sub-
project.

No. Activities Approx. Cost(USD)

1 Stakeholder consultation meetings 60,000.00
2 Information products e.g. brochures 40,000.00
3 Publicity/media 30,000.00
4 Capacity building 50,000.00
5 Monitoring and evaluation 70,000.00
6 Setting and operationalizing community liaison offices in 20,000.00
settlements

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References
1. Guidance Note Managing the Risks of Adverse Impacts on Communities From Temporary Project
Induced Labor Influx – December 2016
2. Good Practice Note Addressing Gender Based Violence in Investment Project Financing involving Major
Civil Works September 2018

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APPENDICES
APPENDIX 1: Key Stakeholder Profile
Last updated:

Stakeholder group:

Primary subject/ issue of engagement

with this group

Stakeholder objective

Preferred level of engagement with

this group

Stakeholder group representative

Specific representative(s) /
representing organisation

KISIP contact person

Stakeholder’s general view

Specific expectations

Engagement history

Stakeholders’ usual or preferred

approach to engagement

Stakeholders’ sources of funding

Relationships/ conflicts with other

stakeholders

Knowledge of the issue Leading Opinion Good Knowledge Medium Knowledge

Lacking Knowledge No Knowledge

Legitimacy High Legitimacy Limited Legitimacy Low Legitimacy No Legitimacy

Willingness to engage Willing Moderately interested but friendly Uninterested Hostile

Actual and/or potential impacts of Positive Impacts/ Opportunities:

stakeholder on business – associated
risks and opportunities Negative Impacts / Risks:

Scale at which they operate Global National Regional Local Internal to Project

Cultural issues to consider

Practical issues to consider (e.g.

ability to engage given literacy,
resources, staff, etc)

Is it necessary to engage with this

stakeholder?

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Other comments

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 APPENDIX 2: Community Liaison Planning Form
Overview

Subject / scope of engagement

Strategic objectives and intended

outcomes:

Engagement approach / method(s /

tools):

Target groups & representatives:

Practical Issues Activities & resources Responsibility Timeframe

Ground rules and terms of

reference

Invitation / publicity / pre-

information

Logistics (Transport, food /

refreshments, etc.)

Venue, timing (if not ongoing)

Equipment etc.

Participants’ reimbursement of
expenses (?)

Process to ensure satisfactory

outcomes

Agenda/ plan for the event

On-the-day roles and facilitation

Record keeping and assurance

Feedback to participants

Wider communication of results

Signals of success ( inputs and

outcomes)

Participant satisfaction feedback

Risk Assessment of Proposed Engagement

Risks (including security):

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Contingency plan:

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 APPENDIX 3: Stakeholder Contact Report
Record Number Entry Date CLO / Other

Name/Title of Contact and Organisation Location of Interaction Date

Stakeholder Contact Details Tel. no.:

Email address:
Street address:

LTWP Participants

Who Initiated the Interaction? Interaction Objective:

LTWP Contact

Nature of Interaction: Complaint Commitment Request Other

Summary:

Recommendations:

Action / Decision Person Responsible Due date

Close-out Comments Date

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 APPENDIX 4: Vulnerability Screening Checklist
So far there is no indication that the Project will adversely impact indigenous persons is it targets urban areas. As
such the nature and extent of the likely impact is unknown. However, if by chance indigenous people are
encountered, then KISIP II will fully comply with all the guidelines and implement comprehensive mitigation
strategies. This will be done through a comprehensive social assessment plan. Identification of
Indigenous Peoples will be reported to the World bank as soon as possible and next steps will be
discussed and agreed.

Step 1: Initial Checkpoints

Define the vulnerable / marginalised social group

(where appropriate refer to Indigenous Peoples criteria
in the SEF):

Why are they vulnerable? What are the underlying

causes of vulnerability?

Has their vulnerability evolved or changed as a result of

the Project or other factors? If worsened, what are the
main contributory factors?

What are the vulnerable stakeholders doing to address

their circumstances?

What mitigation was targeted by the Project and how

successful has it been / likely to be?

What assistance, if any, does the group receive from

central / local government, NGOs, aid agencies or
others? What are their policies and how successful have
their interventions been / likely to be?

What are the capacities of the vulnerable group and any

supporting NGOs?

What recent engagement has the Project had with the

group and their legitimate representatives?

What are the main concerns?

Step 2: Research and Analysis Checkpoints

What additional data and research is needed?

What additional mitigation options are available? How

much? From whom? Over what timescale?

What recommendations for further Project

interventions? How feasible / what cost?

How will success be judged and by whom? What

performance indicators are needed?

What further engagement is needed with this

vulnerable group?

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Step 3: Action Plan and Approval

Confirm what actions are needed to implement

recommendations and who needs to approve the plan?

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APPENDIX 5: Stakeholder Commitments Register
LTWP Commitment / Obligation
Item
No. Nature Source (e.g.
Who to? Date Type (Commitment / Scope Details Comments Actions Close -out
Request / Other) Contact Report)

A. Commitments to National Government

A1

B. Commitments to County / Regional Authorities

B1

C. Commitments to Civil Society (NGOs / CBOs / FBOs)

C1

D. Commitments to Local Communities

D1

E. Commitments to Vulnerable / Marginalised Groups / Individuals

E1

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APPENDIX 6: GRIEVANCE TOOLS
A. Grievance Form

H1 - Grievance Form

Reference: Date Received:

Complainant / site details
Name (or withhold name if you wish to be anonymous):
Address:

Telephone / other contact details:

Details of complaint:

Form completed by:

Name: Position:
Location / Organisation:
Actions required and details of complaint passed to:
Name:
Position:
Department / organisation:
Project / site:
Date:
Resolution and notification of completion to be sent on:

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B. Acknowledgement Template

Grievance Acknowledgement Template (use if formal reply needed, otherwise

telephone)

[Claimant Address]

[Date]

[Reference]

Dear [name of claimant]

I refer to [correspondence / meeting] on [date, month]. We understand that you wish to lodge a
complaint associated with the KISIP Project in relation to [subject of grievance].

We will attempt to contact you within 14 days of the date of this letter in order to discuss your
concerns and to decide up an appropriate course of action should this be appropriate. This will
be without prejudice to your statutory rights.

Sincerely yours,

Community Liaison Officer [or other respondent]

KISIP

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B. Close out Record
Close-out Records (where legal record required)
Reference Details:
Grievance Reference Number: CLO:
Summary of Grievance:

Steps Identified for Corrective Action: Due Date:

1
2
3
4
5
6
Resolution Actions and Close-out:
Notes:

Complainant (Title-Name- LTWP Representative (Title- Official Witness (Title-Name-

Signature Name-Signature) Signature)

Date:

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C. Example of Grievance Monitoring Indicators
Example Monitoring Indicators
Step Indicator Result Corrective
against action
indicator
1, Confirm receipt of Percentage of total number of grievances received
grievance identified as requiring resolution
Percentage of total number of grievances received
being confirmed in writing by the Community
Relations Officer within 7 days of receipt (target
100%)
2. Investigate and seeking of Percentage of total grievances (requiring
resolution resolution) for each identified grievance category
Percentage of meetings with claimant held within
14 days of receipt of grievance (target 100%)
Percentage of grievances (requiring resolution)
resolved by grievance officer within 7 days of
meeting the claimant (target 100%)
Percentage of grievances (requiring resolution)
resolved by grievance officer in more than 7 days
of meeting the claimant
3. Involve senior KISIP Percentage of grievances requiring the
management or third party involvement of senior KISIP management
authorities where required resolved within 14 days from the grievance officer
meeting with the claimant (target 100%)
Percentage of grievances requiring the
involvement of senior LTWP/ATL management
resolved in more than 14 days from the grievance
officer meeting with the claimant
Percentage of grievances requiring the
involvement of third party authorities resolved
within 30 days from receipt of grievance (target
100%)
Percentage of grievances requiring the
involvement of third party authorities resolved in
more than 30 days from receipt of grievance
4. Close Out N/A

5. Facilitate provision of N/A

adjusted entitlements (if
required)
6. Follow up N/A

7. Legal redress Percentage of grievances (requiring resolution)

resulting in legal action (target 0)

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