GRIEVANCE MECHANISM

PROCEDURE
CTGIR-QHSE-PRO-024
Date Review Review Description Elaboration Validation Approval

08/06/2017 00 First Issue S. Santos V. Saluto D. Lancha

20/12/2017 01 Change of the code of the document S. Santos V. Saluto D. Lancha

Update in line with Project-specific Grievance

14/04/2020 02 P. Gimenez V. Saluto D. Lancha
Mechanism

01/01/2022 03 Change of logo and entity from AE to CTGIR M. Kaleem N. Akhtar Q. Wu

This document is property of CTGI Renewable Energy Partners who will safeguard its rights according to the civil and penal provisions
of the Law
INDEX

1 PURPOSE 3

2 SCOPE 3

3 GRIEVANCE MECHANISM PROCESS 3

STEP 1: RECEIVING A GRIEVANCE 4
STEP 2: RECORD THE GRIEVANCE 5
STEP 3: SCREEN THE GRIEVANCE 5
STEP 4: ACKNOWLEDGE THE GRIEVANCE 6
STEP 5: INVESTIGATE THE GRIEVANCE 6
STEP 6: ACTING ON THE GRIEVANCE 6
STEP 7: CLOSE OUT & FOLLOW UP 7
4 MONITORING 7

5 REPORTING 7

6 REFERENCES 8

ANNEX 1 – GENERAL PRINCIPLES FOR PROJECT GRIEVANCE MECHANISM 8

CTGIR-QHSE-PRO-024 2
1 PURPOSE
The Grievance Mechanism is intended to provide well-functioning procedure for receiving and addressing
concerns about CTGI Renewable Energy Partners’ environmental & social performance from stakeholders,)
whenever those may arise and facilitating the evaluation and resolution in a planned, timely, and respectful
manner. The Grievance Mechanism:

 provides the appropriate platform for receiving, evaluating and addressing complaints and
communications from external stakeholders promptly, fairly and effectively;
 uses an understandable and transparent consultative process that is culturally appropriate,
prioritizing processes that seek consensus and reconciliation through engagement and dialogue, at
no cost and not impeding access to other judicial and administrative mechanisms available in the
geographies where we operate for resolution of disputes;
 is fully documented for transparency as well as to prevent the recurrence of stakeholder concerns
whilst allowing for anonymous complaints;
 is readily accessible to stakeholders through CTGI Renewable Energy Partners’ website; and
 is ultimately intended to capture and respond to stakeholders’ concerns.

2 SCOPE
The Grievance Mechanism Procedure described in this document applies to the identified stakeholder groups
for CTGI Renewable Energy Partners including:

 The ‘Identified Local Communities’ to our seven (7) assets, including their residents, legitimate
community leaders and Community Based Organisations (CBOs);

 The ‘Internal Stakeholders’ being CTGI Renewable Energy Partners ‘direct employees’1 and
‘contracted workers’2 employed by our Contractors and its subcontractors whether permanently or
temporarily employed in relation to our activities, as well as service providers, consultants and
suppliers;

 The ‘Interest based Stakeholders’ including national and local governmental entities in the
geographies where we operate, non-governmental organizations and media; and
 The ‘Participatory Stakeholders’ including our shareholders, the Project lenders to each of our seven
(7) assets, energy regulators and energy off-takers for our seven (7) assets.

It must be noted that CTGI Renewable Energy Partners’ seven (7) assets have their Project-specific grievance
mechanisms in place, covering both community and worker grievances. In addition, as part of the CTGI
Renewable Energy Partners Code of Conduct there is active ethics line which is also readily accessible to
stakeholders through CTGI Renewable Energy Partners’ website.

3 GRIEVANCE MECHANISM PROCESS

The following figure presents the different steps of the grievance management:

1 ‘Direct employees’ are those engaged by CTGI Renewable Energy Partners Limited or any of its affiliated entities.
2 ‘Contracted workers’ are those engaged through third parties, such as the Contractor or its subcontractors, to perform work related
to core business processes for the operation and maintenance of the Project (e.g. technicians, security guards)

CTGIR-QHSE-PRO-024 3
 FIGURE 1 GRIEVANCE MECHANISM PROCESS

STEP 1: RECEIVING A GRIEVANCE

There are different ways in which a grievance from a stakeholder may be received such as verbal (e.g. face
to face or over the phone) or written (e.g. by letter or by email) and this may be received by different members
of the Project Company.

Grievances from ‘Internal Stakeholders’ may most likely be received by Supervisors, Plant Manager, the Social
Specialists and/or the Human Resources (HR) Department and be registered and addressed through the
Project-specific worker grievance mechanisms. Grievances from ‘Identified Local Communities’ may most
likely be received by the Social Specialists or the Community Liaison Officers (CLO) and be registered and
addressed through the Project-specific community grievance mechanisms. However, those described and
grievances from ‘Interest based Stakeholders’ and ‘Participatory Stakeholders’ may be received through this
Grievance Mechanism as per the following reporting channels and access points and be managed by the HR
Manager and Corporate QHSE Team:

Company established channels to receive a Grievance

Dedicated telephone number +201222198646

Website www.ctgsail.com

Egypt: Egypt_grievance@ctgsail.com

Jordan: Jordan-Grievance@ctgsail.com
Email
Corporate: whistleblow@ctgsail.com

Letter Address o Room 3401, 34/F, Cosco Tower, 183 Queen's Road Central, Sheung Wan, Hong Kong
o Attn: Chief Compliance Officer

TABLE 1 CHANNELS TO RAISE A GRIEVANCE

CTGIR-QHSE-PRO-024 4
Whichever the way a grievance is received, it is the responsibility of the recipient to prompt the complainant to
complete a Grievance Form (CTGIR-QHSE-DOC-033) or to complete the form on his/her behalf should the
complainant be illiterate.

Upon receiving a grievance by a complainant through this Grievance Mechanism, the recipient shall briefly
explain the process and different remaining steps to be followed as per the procedure including an ‘early’
indication on what the appropriate actions may or may not entail in order to manage expectations of the
complainant. The recipient shall also ensure confidentiality of the complainant should he/she prefer to remain
anonymous.

As noted, the recipient would be most likely the HR Manager and/or Corporate QHSE Team/Grievance officer,
Country Social Specialist but it could be the case that grievances would be received at Corporate level by
other CTGI Renewable Energy Partners employees. The HR Manager and Corporate QHSE Team shall
ensure employees are informed about the Grievance Mechanism at the time they are hired during the induction
and orientation sessions, and details about how the mechanism operates should be easily available within the
Company’s shared file system.

STEP 2: RECORD THE GRIEVANCE

All formal grievances shall be communicated to the HR Manager and Corporate QHSE team. The grievance
shall be registered within the Grievance Register Database (CTGIR-QHSE-DOC-032) by the QHSE team. Any
associated documentation in relation to the grievance shall be saved in CTGI Renewable Energy Partners
shared file system for record keeping purposes. In the case that the complainant requested to remain
anonymous, this should be respected accordingly within the Grievance Log.

STEP 3: SCREEN THE GRIEVANCE

Grievances shall be screened and evaluated depending on the nature and the level of magnitude of the
complaint and/or the associated consequence, sensitivity of the complainants/s and the combined severity of
the complaint. Determining the level of severity of a grievance is critical in order to determine who the grievance
owner should be and how the grievance should be approached. See below table categorising the different
levels:

Severity Description Likely Grievance Owner

Level 1 - Low The magnitude of the complaint is limited and possibly within the Project Social Specialist and
operations and activities and the complainant/s does not belong to a Corporate QHSE Team
vulnerable group. The complaint may be managed at a local level through
the standard process as per the Project specific grievance mechanism

Level 2 – The magnitude of the complaint may go beyond the Project area of Corporate QHSE Team and
Medium influence and operations. The complainant/s is a respected member or HR Manager
representative of the Identified Local Communities. The grievance may
pose environmental & social risks if improperly managed and may
represent a non-compliance against the applicable legal framework. The
complaint may be managed at a Corporate level and coordinated by the
QHSE Team.

Level 3 - High The magnitude of the complaint may go above and beyond the Project area HR Manager, Senior or
of influence and operations, may be repeated (not the first occurrence) Executive Management
and/or may be irreversible. The complainant/s is a respected member or
representative of the Identified Local Communities, governmental
representative or lobbying group. The grievance may pose significant
environmental & social risks and may represent a non-compliance against
Company policies and Code of Conduct. The grievance has the potential to
be escalated beyond the reach of the Company (e.g., to media and social

CTGIR-QHSE-PRO-024 5
 Severity Description Likely Grievance Owner
media) posing a reputational risk to CTGI Renewable Energy Partners in
addition to the inherent environmental & social risks and even legal
prosecution.

TABLE 2 GRIEVANCE LEVEL OF SEVERITY

STEP 4: ACKNOWLEDGE THE GRIEVANCE

A grievance shall be acknowledged by the recipient and/or assigned grievance owner, within two working days
of a grievance being formally received. The communication shall be made either verbally or in written form,
depending on the preferred method of communication if outlined by the complainant.

The acknowledgement of a grievance should include a high-level summary of the understanding of the
grievance, the first steps that will be taken by the Project Company in order to address the grievance and an
estimated timeframe. The acknowledgment also provides an opportunity for the grievance owner to request
for any clarifications or additional information in relation to the grievance in question. The date of and details
of the acknowledgement shall be noted in the Grievance Log accordingly.

STEP 5: INVESTIGATE THE GRIEVANCE

The grievance owner shall be responsible for leading and coordinating the investigation of the grievance. The
investigation may entail consulting ‘direct employees’, ‘contracted workers’ or external stakeholders as
appropriate and determined on case-by-case basis. Records of meetings, discussions, activities and
documented evidence during the investigation shall be recorded. The information gathered during the
investigation shall be analysed to assist in identifying the root cause of the grievance and evaluating whether
the grievance is substantiated and actionable in line with the Company policies and applicable legal framework.
It is also the responsibility of the grievance owner to ensure that the identity of the complainant remains
anonymous if applicable and that those involved in the investigation are knowledgeable of that.

STEP 6: ACTING ON THE GRIEVANCE

Following the investigation, the grievance owner will use the findings to create an action plan outlining steps
to be taken in order to resolve the grievance. The grievance owner is responsible for assigning actions,
monitoring actions undertaken and making sure deadlines are adhered to.

Following the investigation, the grievance owner/, in coordination any other teams as required, shall determine
how the grievance is to be addressed with the proposed steps to be followed including well defined
responsibilities and reasonable timelines on case by case basis. The proposed steps should take into
consideration the nature of the grievance and sensitivity of the complainant, so that confidentiality and
anonymity is respected as appropriate. The complainant shall be informed on the proposed actions and
engaged in the process to the extent believed appropriate on case by case basis.

The QHSE Team shall be responsible monitoring implementation of actions undertaken and making sure
deadlines are adhered to. The implementable actions to be followed including responsibilities and timelines
shall be rigorously recorded within the Grievance Log by the QHSE Team.

CTGIR-QHSE-PRO-024 6
 STEP 7: CLOSE OUT & FOLLOW UP

Once all the proposed actions have been effectively implemented, the grievance owner considers the
grievance has been addressed and the QHSE Team has verified its implementation, the grievance owner shall
formally advise the complainant via their preferred method of contact of the implementation of such actions,
the rationale behind it in line with the Project legal framework and request feedback about the level of
satisfaction on the outcome and process followed. These shall de documented by the grievance owner and
recorded within the Grievance Log by the Corporate QHSE Team.

The grievance owner shall also fill in and signed off the Grievance Closeout Form (CTGIR-QHSE-DOC-034)
and prompt the complainant to review it and sign it. It is worth noting that a complainant may or may not be
satisfied with the outcome and process followed to address the grievance based on for instance his/her
expectations, personal interests or understanding of the issue. Even in those cases, a grievance may be
considered ‘Closed’. This shall be documented within the Grievance Log and the Grievance Closeout Form,
including feedback about the grievance owner evaluation of the process and level of satisfaction.

4 MONITORING

The implementation of this Grievance Mechanism shall be monitored through the periodical review of the
Grievance Log to be updated and submitted by the Development Coordinator and Social Specialist to the
QHSE Team on monthly basis, to assess whether the engagement activities within this Plan are being
successfully and timely undertaken.

The implementation of this Plan shall be monitored through the continuous monitoring of the email access
channel and the review of the Grievance Log. The performance of its implementation and the timely resolution
of grievances shall be evaluated on bi-annual basis as part of the year and mid-year internal audits by
evaluating:

 The degree to which the Grievance Mechanism is working effectively and being implemented as
planned;

 Any particular trends shown by the nature of grievances received, the root cause of grievances and
efficiency and level of satisfaction when resolving those; and

 Potential areas of improvement and of concern.

5 REPORTING
As noted, the following documentation shall be duly kept for each of the received grievances within the
Company’s shared file system:

 Grievance Registration Form (CTGIR-QHSE-DOC-032)

 Grievance Investigation Form (CTGIR-QHSE-DOC-066)


 Grievance Close Out Form (CTGIR-QHSE-DOC-033)

 Grievance Register Database (CTGIR-QHSE-DOC-034), which combines all the registered
grievances as well as the commitments, agreements, and complainant feedback up to the resolution
and closure of the grievance.

CTGIR-QHSE-PRO-024 7
On a bi-annual basis and following the internal audit, the QHSE Department shall provide a report on the status
of grievances received through this Grievance Mechanism to the Head of Delivery and Operations and to the
HR Manager.

6 REFERENCES

CTGIR-QHSE-DOC-032 Grievance Register Database

CTGIR-QHSE-DOC-033 Grievance Registration Form
CTGIR-QHSE-DOC-066 Grievance Registration Form
CTGIR-QHSE-DOC-034 Grievance Close Out Form
IFC Performance Standard 1: Assessment and Management of Environmental and Social Risks and Impacts
IFC Performance Standard 2: Labour and Working Conditions

ANNEX 1 – GENERAL PRINCIPLES FOR PROJECT GRIEVANCE MECHANISM

Process transparency and fairness

 Ensures process transparency through procedures that are easy to understand and accessible to all
workers including migrants;
 Establishes multiple and clear communication channels through which workers can voice their
concerns, grievances, and/or suggestions freely;
 Ensures complainant confidentiality and that anonymous complaints can be submitted and resolved;
 Protects complainant from discrimination or sanctions ensuring that workers can report grievances
without fear of dismissal or reprisal of any kind;
 Defines clear roles, clear line of accountability, responsibilities, procedures, and process steps
including monitoring and evaluation;
 Actively provides information on the existence and functioning of the mechanism in a way that is
consistent to the context and audience for whose use it is intended to:
 Ensures ethical and impartial behavior of the Grievance Manager responsible for the Grievance
process in taking fair and just actions to resolve the grievance;
 Allows workers to report a grievance against a supervisor to an impartial entity, and in any case to
someone other than that supervisor or any other manager in that supervisor’s chain of command; and
 Allow submissions of both collective and individual grievances following the same step by step process
described in this document.

Migrant workers and vulnerable groups

 Provides access to all workers, and migrant workers and workers from vulnerable groups, to a
transparent and fair grievance management system that allows them to voice concerns without fear
of punishment or retribution;
 Ensures process transparency through procedures that are easy to understand, culturally appropriate,
and accessible to all workers, including migrants and vulnerable groups such as women workers if
applicable and workers from vulnerable/minority ethnic groups;
 Provides multiple communication channels to ensure that workers find an avenue with which they are
comfortable registering concerns, and employs translators where necessary; and,
 Ensures confidentiality – and anonymity – in submitting grievances.

Staff Training and Awareness

CTGIR-QHSE-PRO-024 8
  Provides appropriate training to staff and contractors on dealing with grievances; and
 Ensures ethical and impartial behavior of the Grievance Manager responsible for the Grievance
process in taking fair and just actions to resolve the grievance.

Rights of Workers
 Respects the rights of workers to be accompanied at formal grievance resolution meetings by a work
colleague or worker representative who has not been involved in the case; and
 Assesses any complaint on its possible human rights implications and ensures that outcome do not
infringe on the rights of the complainant.

Improved Communication
 Promotes the collaboration and joint effort of workers and Management in the satisfactory and timely
resolution of the grievance while ensuring minimal tension; and,
 Allows better communication between workers and supervisors or Management through the promotion
of direct communication to address concerns before they turn into formal grievances.

Feedback and Reporting

 Establishes a Grievance Committee to monitor and follow up with the resolution process and
implementation of agreed actions;
 Ensures reporting back to complainants on the grievances submitted; and,
 Enables workers to monitor the status of complaints.

Appeal Option and Resort to Justice

 Provides an appeal mechanism involving third parties through mediation in case the Consortium and
the complainant do not reach or agree upon a resolution; and,
 Does not impede access to existing judicial or administrative remedies or other grievance mechanisms
established through collective agreements.

Process Review and Monitoring

 Keeps a centralized record of complaints and concerns;

 Records all details of compensations, commitment and agreements arising; and,
 Monitors and assesses the performance of the mechanism on a regular basis to integrate key
learnings into the process to strengthen its effectiveness and commitment to respect workers´ rights.

Compliance

 Complies with national and international labor norms and standards, including applicable laws, rules
and regulations in the country (and region) where work is to be carried out, and International Finance
Corporation Performance Standard 2 on Labor and Working Conditions.

CTGIR-QHSE-PRO-024 9