The UN Guiding Principles on Business and Human Rights expect companies to establish effective grievance mechanisms for individuals and communities that may be impacted by our operations. Mindful of the importance of building trust with local communities, Total E&P Uganda has implemented formal procedures for dealing with grievances — resolving hundreds of them and further improving community relations in its host country.
In 2012, Total E&P Uganda began exploration activities in the Murchison Falls National Park, Uganda’s largest national park and a very highly eco-sensitive area. The affiliate immediately appointed a team of Community Liaison Officers (CLOs), men and women from local communities who speak the local language and understand local customs. It also implemented a highly structured process to handle the grievances that were expected to arise from our operations or those of our contractors.
Many Types of Grievances, But a Single Resolution Procedure
There can be various complaints related to major onshore activities like ours in Uganda. Access to land can be a significant issue, especially in areas where that land is used by communities for farming, tourism or cultural heritage-related activities. Grievances can also be linked to issues related to loss of crops, logistics, transportation — trucks exceeding speed limits, for example — noise or pollution.
In line with United Nations and International Finance Corporation (IFC) guidelines, Total E&P Uganda implemented a grievance mechanism. Initially, a backlog of complaints accumulated as the CLOs familiarized themselves with the procedure. With time, there have been assertive efforts to improve it and ensure maximum efficiency to resolve cases when they arise.
Each grievance is handled in pre-established steps that make the process predictable, transparent and a source of continuous learning.
- Record and Acknowledge: Grievances can be lodged by directly contacting the CLO using a toll-free line, visiting the Total representative office or going to the local authorities, who report them to Total. We record them in a dedicated system and a copy is given to the plaintiff.
- Assess and Assign: CLOs conduct an initial review and assign each case to the department (logistics, environment, etc.) best suited to handle it, but remain involved until the case is resolved. If an immediate solution is possible, the remedy is implemented and the file is closed.
- Investigate and Respond: Grievances are investigated and a response is given. Those that cannot be resolved immediately are forwarded to the management of the affiliate, the subcontractor or supplier, who suggests a solution. If the plaintiff accepts the solution, the file is closed. If the solution is refused, the grievance is handled by a committee that includes representatives of the affiliate, the subcontractor or supplier, communities, non-governmental organizations or local associations recognized as legitimate. A new solution is then proposed.
- Close the file: When a solution has been accepted, the CLO files the close-out section of the grievance form and closes the file on the grievance system.
Each stage is documented and dialogue is maintained throughout the process. Total E&P Uganda has also defined three timescales — immediate resolution in 24 hours, then seven to 14 days and finally 30 days when a committee is needed. If a plaintiff is still not satisfied, they can pursue the issue in a court of law.
The Effectiveness of the Resolution Procedure
Total E&P Uganda recorded hundreds of complaints between 2012 and 2015, mostly related to compensation for the temporary acquisition of land for our exploration campaign, which included 3D seismic acquisition and exploration and appraisal drilling. The majority were quickly resolved.
Then there was a lull as operations on the ground were scaled back. In 2017, the affiliate recorded new grievances, this time linked to resettlement planning studies as Total E&P Uganda prepares for the development phase, which will require the permanent use of land to build an industrial area, well pad flow lines and associated access roads. For example, the affiliate received 92 grievances for the industrial area alone over a period of three months and resolved 90 in a short period of time.
This ability to resolve grievances efficiently and transparently has not only helped avert potential crises, it has also built local confidence in Total E&P Uganda as a responsible company. That in turn has strengthened our social license to operate in Uganda.
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