2010
          
        
        
          AMBATOVY SUSTAINABILITY REPORT
        
        
          13
        
        
          B3. Organizational Approach to Sustainability
        
        
          
            B3.4 The Ambatovy Grievance Mechanism
          
        
        
          Ambatovy engages stakeholders on a range of subjects
        
        
          from safety to social and economic development to practical
        
        
          management of Project sites. Nevertheless, stakeholders
        
        
          can always raise their own concerns. Issues raised by
        
        
          stakeholders include:
        
        
          3
        
        
          Allegations of harassment or improper behaviour
        
        
          3
        
        
          Claims for property damage or financial loss
        
        
          3
        
        
          Concerns linked to health, safety and the environment
        
        
          A grievance management mechanism is in place for reporting,
        
        
          assessing and addressing issues raised by stakeholders.
        
        
          While many of these issues can be resolved through the
        
        
          regular consultation process, the grievance mechanism
        
        
          provides a channel for cases that should be addressed
        
        
          formally and/or confidentially with each step of the process
        
        
          documented. Implemented in March 2010, the mechanism
        
        
          has quickly become a vital tool for monitoring and mitigating
        
        
          concerns raised by local stakeholders.
        
        
          Ambatovy defines a complaint as “a claim or grievance filed
        
        
          by an individual or a group within the communities affected by
        
        
          the operations of the company.” Any individual or group that
        
        
          feels negatively affected by the activities of Ambatovy can file
        
        
          a complaint and all complaints received from eligible parties
        
        
          will be accepted, analyzed and processed. To ensure that
        
        
          the mechanism is accessible, individuals may file grievances
        
        
          by phone, mail, email or in person at Ambatovy offices in
        
        
          Antananarivo, Moramanga or Toamasina. They may also file a
        
        
          grievance with any Ambatovy field worker or at the office of a
        
        
          local authority.
        
        
          5
        
        
          All grievances are treated in a three-step process:
        
        
          3
        
        
          The stakeholder receives an acknowledgement of the
        
        
          grievance and an initial response.
        
        
          3
        
        
          Ambatovy conducts an investigation as required.
        
        
          3
        
        
          Ambatovy provides the results of the investigation to
        
        
          the stakeholder with a proposed course of action to
        
        
          resolve the matter. If the stakeholder does not accept
        
        
          the proposed course of action, Ambatovy engages in
        
        
          further dialogue with the stakeholder until there is a
        
        
          mutually acceptable outcome.
        
        
          The Project monitors the mechanism closely and prepares
        
        
          regular reports to management and the Executive Committee
        
        
          on the number of grievances and the status of the Project’s
        
        
          responses.
        
        
          Our grievance mechanism has been a critical way of tracking
        
        
          these major issues. The most significant topic raised through
        
        
          the mechanism has been the compensation and restoration
        
        
          process for rice fields affected by pipeline construction.
        
        
          Ambatovy has responded by investigating the cases and
        
        
          explaining the process for determining the compensation and
        
        
          restoration method. The Project is planning an external audit
        
        
          to assess the adequacy of the current compensation process.
        
        
          5
        
        
          This authority is generally the
        
        
          
            Fokontany
          
        
        
          , which are the Malagasy government’s liaison and administrative offices at the village or neighbourhood level.