Grievance Mechanism

Harmony Energy – Grievance Mechanism

1.1 Harmony Energy Limited (the “Company”) and its subsidiaries (collectively, the “Group”) seeks to ensure that its activities and operations do not cause any issues for those living near to any of its projects or projects of Harmony Energy Income Trust plc in respect of which the Company provides asset services (each a “Project”), or any other potentially affected stakeholders. However, the Company wishes to hear about any concerns or particular complaints that stakeholders may have in relation to the activities of any project, so that any of those issues can be noted and duly addressed.
1.2 The International Finance Corporation (IFC) Equator Principles, and other similar international standards require the establishment and maintenance of a grievance mechanism open to all stakeholders, especially where there are affected communities. This procedure is used to manage stakeholders’ grievances so that they can be promptly processed, analysed and solved by the Company’s personnel.
1.3 Stakeholders’ grievances are taken into account by the Group as a valuable source of information to optimise the design and outcome of each Project.Impacts on the local community are carefully examined through each Project’s planning process and the Group commits to meet all requirements of Decision Notices for each Project.
1.4 This grievance mechanism will be maintained throughout each Project’s lifecycle. The grievance mechanism is disclosed on the website harmonyenergy.co.uk. Leaflets or brochures may be published or posters displayed to raise the awareness of affected stakeholders, where considered appropriate for the Project.
1.5 The procedure applies to grievances from external stakeholders. For internal grievances a separate whistleblowing policy applies.

2. Definition of Grievances

2.1 A grievance is a concern or complaint raised by an individual or a group within communities affected by the Group’s operations. Grievances can result from either real or perceived impacts of a company’s operations, and may be filed in the same manner and handled with the same procedure.
2.2

Examples of grievances could include:

 

  • Negative impacts on local residents (such as excessive noise, traffic, and other types of disturbance);
  • Damage to private and common assets and properties;
  • Environmental damage resulting from construction or operations activities as part of the Project; or
  • Practices or technologies that endanger the health, safety and security of the local population.

3. Purpose and Principles of the Grievance Mechanism

3.1 This grievance mechanism is established to receive and facilitate resolution of external stakeholder grievances concerning the Project.
3.2

The grievance mechanism serves to:

 

  • Minimise any adverse impacts of the Project on external stakeholders via quick and mutually acceptable resolution of grievances;
  • Identify emerging adverse trends in terms of incidents/impacts at an early stage so that measures to prevent/avoid their occurrence can be implemented quickly and proactively; and
  • Demonstrate the Company’s respect for the interests of external stakeholders.
3.3

Key principles of the grievance management process are:

 

  • Any person, group or organisation can submit a grievance at any time, without fear of retribution and at no financial cost.
  • All grievances will be taken seriously and will be treated in a fair and respectful manner. The Company will respond to the complainant to confirm receipt of the grievance within ten (10) working days.
  • The process by which grievances will be received, investigated and resolved will be consistent and transparent. Representatives of contractors, and other third parties, may be involved in the investigation where applicable.
  • Information relating to grievance investigations and the eventual resolution will be documented.
  • Personal information about the affected stakeholders will be treated as confidential (in accordance with requirements of current legislation).
  • The mechanism will not impede access to judicial or administrative remedies.

4. Stages of the grievance mechanism

4.1

Stage 1: Grievance communication and logging (registration)

 

Grievances can be submitted via the contact form on the Company’s website. All grievances will be logged.
4.2

Stage 2: Acceptance of grievance for investigation

 

The Company will respond to the complainant to confirm receipt of the grievance within ten (10) working days from receipt.
4.3

Stage 3: Notification

 

As well as confirmation of receipt the complainant will also be provided with information about response times, next steps and a contact name within the Company. If the grievance is not accepted the complainant will be notified and a reason given. It is noted that any grievances requesting mitigation beyond the boundaries of the planning permission for a Project may not be considered to require resolution beyond compliance with planning requirements.
4.4

Stage 4. Investigation

 

The Company will investigate grievances and their surrounding circumstances. These investigations will involve various individuals and, if necessary, may involve consultation with the complainant. The Company will strive to complete the process of investigating grievances and identifying a resolution within fifteen (15) working days, and in more complex cases within twenty five (25) calendar days, of the date on which the Company confirms receipt of the grievance.
4.5

Step 5: Notification of the proposed resolution

 

A proposed resolution will be based on the results of the investigation. The proposed resolution will then be formally communicated to the complainant. If the proposed resolution is not accepted, the grievance may be reassessed through an internal review. If no resolution can be agreed, the complainant is free to take their grievances to a third party dispute resolution mechanism.
4.6

Step 6: Monitoring and evaluation

 

After the accepted resolution has been implemented, it will be monitored, and its effectiveness will be evaluated by the Company

5. Reporting

The numbers and types of grievances, and the nature and timing of their resolution, will be monitored and reported internally to the board of the Company and, where relevant, the board of Harmony Energy Income Trust plc.

Latest version updated and adopted as at 4 April 2022.