Proceudre

Grievance Redress Mechanism (GRM) - NMB Bank Zimbabwe

  • 1. Purpose
    To allow individuals, communities, and stakeholders to submit complaints directly to NMB Bank Zimbabwe, we will implement a Grievance Redress Mechanism (GRM). This mechanism enables stakeholders to voice concerns if they believe the organization’s operations or supported projects may adversely affect them, their community, or the environment. We will effectively communicate the GRM procedure by identifying key audiences and selecting suitable communication channels tailored to their needs. We will use simple language to explain the procedure, providing context and rationale while offering opportunities for feedback. To ensure widespread understanding, we will utilize various communication methods, including emails, meetings, presentations, and training sessions, depending on the stakeholder group.
  • 2. Scope
    The Grievance Redress Mechanism (GRM) procedure provides stakeholders an opportunity to reach resolution of disputes. The procedure also assists NMBZ to monitor and assess impacts of the projects being financed.
  • 3. Responsibility
    Chief Risk Officer is responsible for implementing, reviewing and maintaining this procedure.
    The Credit, Environmental & Social Risk Monitoring is responsible for the day-to-day implementation of this procedure.
    Grievance Redress Committee is responsible for assisting in implementing this procedure and providing resolutions to the complaints raised.
  • 4. Definitions
       4.1 Admissible Complaint A Complaint for which the committee has decided that it fulfils the admissibility criteria.
       4.2 Client The entity that is financed by NMBZ and responsible for carrying out and implementing all or part of the NMBZ-Financed Operation or projects.
       4.3 Complainant The external or internal party that is filing the Complaint.
       4.4 Complaint A written communication addressed to NMBZ which claims that it has been or will be affected by a NMBZ-Financed Operation.
       4.5 Dispute Resolution The process to assist in finding a resolution of the issues underlying an admissible Complaint. This process may include information sharing, fact-finding, dialogue and mediation. A pre-condition for Dispute Resolution is that all relevant parties are willing to participate in such a process.
  • 5. Abbreviations
    NMBZ: National Merchant Bank of Zimbabwe
    CRO: Chief Risk Officer
    GRMI: Grievance Redress Mechanism Implementer
    GRMC: Grievance Redress Mechanism Committee
  • 6. Guidelines
    The communication by letter or email must be written in English or any other native language to the NMBZ. The response by letter and/or e-mail will be in the language used by the Complainant.
    The scope of this procedure extends to all complaints or grievances against NMBZ financed projects that are received by telephone, email, or in person. Complaints may be submitted via email at compliancedepartment@nmbz.co.zw or 08677004011, 08677008564-6
    The Complainant is requested to submit the following which determines the course of action and time for providing a response:
    • Description of the Complaint
    • Where appropriate, an indication of NMBZ policy allegedly breached
    • A clear description of the NMBZ Financed Operation and location to which the Complaint is related.
    • Name and full address, telephone number and if possible, email address of the complainant.
    • Name of NMBZ employee whom the Complainant had contact with (if applicable).
    • A copy of information related to or relevant for the Complaint, including an overview of actions (e.g. legal, contacts with Client) that have already been taken to solve the issue.
    • Anonymous Complaints: Individuals submitting anonymous complaints are encouraged to provide as much detail as possible to facilitate the review process. While NMBZ will respect the anonymity of the complainant, it is advisable to include context that can assist in addressing the complaint effectively.
    • Anonymous complaints can be submitted through postal mail to NMB Head Office at 19207 Liberation Way Borrowdale Harare or via phone call to 08677004011
    • Any person or group, including civil society organizations representing affected people, may lodge a Complaint, as per below prerequisites:
      • The External Party must be affected or likely to be affected by an NMBZ-Financed Operation.
      • If the Complainant is representing others, they must identify the people they are representing and provide explicit evidence of the representative authority.
      • There must be an indication of a relationship between the NMBZ-Financed Operation and the alleged impacts.
    • The Grievance Redress Mechanism committee cannot investigate:
      • Complaints with the objective of gaining a competitive economic advantage or that are excessive, repetitive, clearly frivolous or malicious in nature,
      • Identical Complaints aimed at Dispute Resolution that already are being handled by other high standard administrative mechanisms (e.g. under courts).
    • Once a Complaint has been deemed admissible, other affected stakeholders typically will be notified about the Complaint. The GRMC will strictly respect and safeguard a party’s request for confidentiality (if applicable), including confidentiality of entities. The GRMC will indicate publicly when it has restricted disclosure of information in response to such a request from an External Party.
  • 7. Activity Description
    7.1 The NMBZ receives complaints through email, letter or directly from individuals or communities affected by a Bank-financed Operation or their representative.

    7.2 When submitting a grievance, the Complainant must include their name and contact details. However, if they choose to remain anonymous they can do so but must provide detailed information clearly explaining the issue they wish to report. The Bank will try by all means to communicate directly with the complainant if they are known and keeps them informed about the status of the complaint.

    7.3 All Bank staff who receive direct complaints are required to refer them to the GRMC within three (3) business days of receiving such complaint.

    7.4 Complaints received are assessed for authenticity and verified to see if they are admissible.

    7.5 If the GRMC determines that the complaint is not admissible as set out in this procedure, the GRMI notifies the Complainant of this decision and the reason why the grievance is not admissible.

    7.6 If the complaint has been declared admissible after evaluation, the GRMC will launch a preliminary review into the issue(s) raised by the Complainant. It will review the relevant documentation and records. The GRMC will aim to finish the preliminary review within a reasonable timeframe. However, the number of days to finish the preliminary review will depend on the complexity of the case and will be communicated to all parties involved.

    7.7 The GRMC may request further information from the complainant to inform the GRMI assessment of admissibility. If no response is received within fourteen (14) business days of the second request, the GRMI will make every effort to gather more information and conduct a comprehensive investigation. If these efforts fail, we will document all attempts to contact the complainant. If the complainant is known, we will advise them that the opportunity to resolve the grievance remains available should they choose to come forward in the future.

    7.8 GRMC decides on the risk classification. Admissible complaints are classified as high, moderate or low risk. This determines the prioritization of actions and the level of management engagement.

    7.9 Communication of the solution proposal to the complainant is done within a reasonable timeframe. The GRMI or GRMC sends the proposal and seeks the complainant’s input.

    7.10 If the Complainant accepts the solution proposal, the GRMC coordinates its implementation by the Borrower.

    7.11 If the complainant rejects the solution, the GRMC engages in further dialogue. If unresolved after thirty (30) business days, the issue may be escalated to arbitration or legal action.

    7.12 While the action plan is being implemented, the GRMI monitors progress and provides updates to both GRMC and the complainant.

    7.13 The GRMC closes the complaint when agreed-upon actions are satisfactorily completed. The GRMI or GRMC notifies the complainant.

    7.14 If the Complainant disagrees with the closure, they must respond within ten (10) business days. GRMI and GRMC will re-engage to seek resolution.

    7.15 GRMI escalates high-risk complaints to management or the Board if necessary.

    7.16 GRMI communicates with complainants, maintains confidentiality, and provides regular status reports to top management and stakeholders.