stakeholder engagement plan -...
TRANSCRIPT
REPUBLIC OF INDONESIA MINISTRY OF RELIGIOUS AFFAIRS
DIRECTORATE GENERAL OF ISLAMIC EDUCATION
REALIZING EDUCATION’S PROMISE: SUPPORT TO INDONESIA’S MINISTRY OF RELIGIOUS AFFAIRS FOR IMPROVED QUALITY OF
EDUCATION (P168076)
STAKEHOLDER ENGAGEMENT PLAN May 2019
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1
ABBREVIATIONS AND ACRONYMS
ADB Asian Development Bank
AMAN Aliansi Masyarakat Adat Nusantara (Indigenous Peoples' Alliance of the Archipelago)
CPF Country Partnership Framework
CSO Civil Society Organization
ECOP Environmental Code of Practice
ESCP Environmental and Social Commitment Plan
ESF Environmental and Social Framework
GRM Grievance Redress Mechanism
IAIN Institut Agama Islam Negeri (State Islamic Institute)
ICT Information and Communication Technology
IP Indigenous People
KAT Kelompok Adat Terpencil (Remote Adat Group)
KKG Kelompok Kerja Guru (Peer Working Group for Primary Teachers)
LMP Labor Management Procedure
MGMP Musyawarah Guru Mata Pelajaran (Peer Working Group for Jr and Sr Secondary Teachers, Subject-based)
MHA Masyarakat Hukum Adat (Customary Law Communities)
MoRA Ministry of Religious Affairs
NES National Education Standards
NGO Non-governmental organization
PAP Project Affected Persons
PIU Project Implementing Unit
SEP Stakeholder Engagement Plan
SOP Standard Operating Procedure
TPS
Tempat Pembuangan Sementara (Temporary Collection Facility)
2
April 2019
1. INTRODUCTION AND PROJECT DESCRIPTION
Indonesia’s Country Partnership Framework (CPF) with the World Bank (2016–2020)
highlights the importance of equality of opportunity, getting reform priorities right, refocusing
public administration on better implementation, and building in more accountability and
transparency at the local government level to ensure better service delivery. There is a strong
focus on the importance of working in support of education, though this was originally
conceived in a context of decentralization, while the Ministry of Religious Affairs (MoRA) is a
centralized ministry. Engagement Area 4 of the CPF, Delivery of Local Services and
Infrastructure, includes Pillar 2 which specifically refers to an education project to ensure
universal access to education services that meet minimum quality standards.1
To fully realize Indonesia’s human capital potential, all students must have access to learning;
this is education’s promise. The Project aims to improve the MoRA’s ability to manage the
organization of education and improve teaching practices in the classroom. With the aim of
strengthening education services under MoRA, specific investments are proposed for roughly
50,000 primary and secondary formal education institutions nationwide under MoRA through
the following components:
• Component 1 - Nationwide implementation of electronic performance-based
budgeting system
• Component 2 - Implementation of a national, census-based student assessment in
4th grade.
• Component 3 - Continuous professional development for teachers and education
personnel
• Component 4 - Strengthen systems to support quality improvement
The Project activities are not expected to have significant impact on environmental and social
aspect. An assessment of the environmental and social impacts of each component can be
seen in section IV.
MoRA has prepared a Stakeholder Engagement Plan (SEP) and will implement it to ensure
that stakeholder engagement is conducted on the basis of timely, relevant, understandable,
and accessible information, in a culturally appropriate format. MoRA will ensure that both the
format and location of the consultations are inclusive and accessible. The SEP includes a
grievance redress mechanism (GRM) which will allow stakeholders, beneficiaries, and
employees working on the Project to raise potential concerns about the Project.
1 http://documents.worldbank.org/curated/en/195141467986374707/pdf/99172-REVISED-World-Bank-Indonesia-
Country-Partnership-Framework-2016-2020.pdf; page 32
3
The first draft SEP was disclosed on March 15, 2019, and is available at:
https://madrasah2.kemenag.go.id/read/20190315/293/draft-ecop-escp-dan-sep-mora-
kementerian-agama-tahun-2019. The draft SEP will be updated after the public consultations
and, as necessary, throughout the Project life cycle (preparation and implementation). During
first year of project implementation, the Project will conduct two consultations with
beneficiaries, particularly those who may be identified as IPs, vulnerable or disadvantaged
groups living below poverty line. First public consultation was held at MoRA office on April
23, 2019. The consultation was attended by 25 participants from the elements: Ministry of
Finance, Ministry of Environment and Forestry, Dinas Lingkungan Hidup, DKI Jakarta
Province, MoRA, CSOs: representative of Muhammadiyah and Ma’arif Nadhlatul Ulama. The
summary of the consultation, the list of attendees and the photos can be found in Annex 1.
The Project will do next consultation and involve interest groups such as non-governmental
organizations/civil society organizations (NGO/CSOs), representatives of teachers,
pengawas, principals, indigenous people (IP), and local communities during the
implementation of the Project.
2. SOCIAL ASSESSMENT
Social assessment aims to help MoRA understand key social issues and determine social
impacts on different stakeholders. Throughout the Project preparation and implementation, it
will use periodic consultations and outreach to determine needs and priorities of key
stakeholders to obtain their views on the design and proposed implementation mechanisms
of the Project, and to build capacity and involvement. Social assessment under the Project
will be a continuous process and will help make the Project responsive to social development
concerns that may arise during implementation. In particular, social assessment will aim to
assist MoRA in reaching the vulnerable and the poor and ensure that the Project objectives
are acceptable to the intended beneficiaries.
The World Bank will finance a package amount at an average of US$50 million per year or
1.43 percent of MoRA’s annual education budget. The Project will be for 5 years, with the
closing date currently set for December 31, 2024.
The Project activities will take place nationwide in 34 provinces. The Project activities are
related to improvement of (i) the planning and budgeting system, (ii) the student assessment
system, (iii) teacher competency, and (iv) the education data system. These activities are not
expected to result in any direct negative social impacts. However, many schools under MoRA
are located in remote areas of Indonesia, and communities in those remote areas are often
deemed as vulnerable groups. Their vulnerability can be seen in various ways, such as the
level of their income, which is often below the poverty line, and the lack of access to quality
education.
Under Component 1 (sub-component 1.4) will also an inclusion activity for medium
rehabilitation and repair works to support learning needs. Medium rehabilitation is defined as
repair of a portion of the non-structural components and/or repair of a portion of the roof,
ceiling, and/or floor of classrooms, libraries and laboratories. This civil works will do at existing
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buidling and on existing land. Major physical rehabilitation and infrastructure works including
structural repairs to beams and coloumns will be explicitly excluded in the Project.
Project activities under Component 2 on the student assessment system and Component 3
on teacher competency improvement will likely cover schools where the vulnerable groups as
well as IPs may be present. Even though there are no negative impacts expected as per the
World Bank’s ESS7 (more information on Environmental and Social Framework [ESF] is
available in Section 2.1), the standard is still relevant to the Project since IPs may get direct
or indirect benefits from the Project activities.
Therefore, engagement and consultations by the MoRA PIU at the central level with
representatives of IP communities, school committee (representatives of student parents,
school/madrasah and local leader) for Project activities will be crucial. This central-level
consultation will take place at least as part of the mid-term review and as part of the project
completion process. Additional consultations may take place as needed and as informed by
Project monitoring.
2.1 INDIGENOUS PEOPLES
There is no universally accepted definition of IPs. In different countries, IPs may be referred
to by terms such as ‘Indigenous ethnic minorities’, ‘aboriginals’, ‘hill tribes’, ‘minority
nationalities’, ‘scheduled tribes’, or ‘tribal groups’. In ESS7,2 the term ‘Indigenous
Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities’ is
used in a generic sense to refer exclusively to a distinct social and cultural group possessing
the following characteristics in varying degrees:
(a) Self-identification as members of a distinct indigenous cultural group and recognition
of this identity by others; and
(b) Collective attachment to geographically distinct habitats, ancestral territories, or areas
of seasonal use or occupation, as well as to the natural resources in these areas; and
(c) Customary cultural, economic, social, or political institutions that are distinct or
separate from those of the mainstream society or culture; and
(d) A distinct language or dialect, often different from the official language or languages of
the country or region in which they reside.
In Indonesian, the term ‘Indigenous Peoples’ is often associated with Masyarakat Hukum Adat
(or MHA - Customary Law Communities) which is a common terminology used in Indonesian
laws and regulations to describe groups of people with similar characteristics as those of IPs
specified above. Ascertaining whether a particular group is considered as IP for the purpose
of this principle may require technical judgment from a social expert.
2 EES7 is the World Bank’s ESF relating to the policy for addressing impacts on IPs as result of an
activity/project funded by the World Bank. ESF is available at http://www.worldbank.org/en/projects-
operations/environmental-and-social-framework
5
MoRA does not have a database of the location of schools under its responsibility3 but location
of IPs in Indonesia is issued by the Ministry of Social Affairs in 2017–2019. The Ministry of
Environment and Forestry also issues a list of community forests belonging to IP. The
recognition by the state through the Decision of the Constitution Court (Mahkamah Konstitusi)
dated May 16, 2013, that state forest does not include customary forest requires further
consideration.
List of IP locations based on the three resource documents can be accessed through MoRA
website and is available at http:// …….
3. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT
ACTIVITIES
MoRA had a loan with Asian Development Bank (ADB) during December 2006 to February
2014 for the Madrasah Education Development Project. The project was implemented in three
provinces and 27 districts, with 500 madrasahs selected for upgrading—453 were private
madrasahs and 47 were public madrasahs. SEP was not available for the project because in
2006 it was not yet an ADB requirement.
During 2011–2015, MoRA collaborated with IAIN Sunan Ampel Surabaya to implement
curriculum development and selected lecturers were given their Doctorate and Master’s
degrees. This was part of the activities of the project for the Development and Quality
Improvement of the Institute for Islamic Studies (IAIN) Sunan Ampel Surabaya and also
supported the quality and relevance of the higher education institutions through activities such
as curriculum development and acquisition of equipment. However, SEP was not available for
the project.
3 Formal schools under MoRA include Buddhist schools, Hindu schools, Christian schools, and Kong Hucu
schools as well as Islamic schools (madrasahs). These schools follow the same curriculum as other schools in
Indonesia but spend additional hours on religious subjects in the national curriculum.
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4. ASSESSMENT OF POTENTIAL ENVIRONMENTAL AND SOCIAL
IMPACTS
Component Activity (based on the
readiness criteria)
Potential Environmental and
Social Impact
Inclusion in Environmental
and Social Commitment Plan
(ESCP)
Component 1
Nationwide
implementation of
electronic
performance-
based budgeting
system
▪ Support the
measurement of the
achievement of the NES
for MoRA schools
▪ Support and provide
technical assistance to
the districts and
provinces to analyse and
report data based on the
e-RKAM
▪ Support medium
rehabilitation & repairs
works for learning needs
on existing building and
on existing land
▪ Provide training for
implementation of
Component 1
▪ Hire individual specialist
consultant as e-RKAM
expert
▪ Hire event organizer for
organizing training
▪ Hire contractor for civil
works
▪ Minor environmental impact
▪ No social impact
▪ Need to hire consultants to
support operations of
Component 1
▪ Develop Labor
Management Procedure
(LMP) as guidance for the
Project Implementing Unit
(PIU) to recruit and select
the workers (consultants &
contractors)
▪ Develop SEP for
consultation with
stakeholders on the design
of the Project and
environmental & social risk
management
▪ Develop ECOP for medium
rehabilitation & repairs
works.
Component 2
Implementation of
a national, census-
based student
assessment in 4th
grade
▪ Assess student learning
in grade 4 using a
census- and paper-based
approach or, where
possible, a computer-
based test
▪ Provide training for
implementation of
Component 2
▪ Hire individual specialist
consultant as learning
assessment expert
▪ Hire event organizer for
organizing training
▪ No environmental impact
▪ May be direct or indirect social
impact
▪ Yearly monitoring. The Project
can identify benefits for IP from
the results of yearly monitoring.
Need to review the overlap of
IP locations with school location
that conducts learning
assessment for 4th grade
students. However, field studies
are needed to check whether
the IPs in the list meet the
characteristics of ESS7 or they
belong to other groups, for
example, disadvantaged
students from poor families that
need further attention.
▪ Develop SEP for
consultation with
stakeholders on the design
of the Project and
environmental & social risk
management, including
representatives from IP
communities, school
committee, NGO/CSOs
▪ Social impact assessment
at mid-term review and
completion of the Project.
Initial screening to identify
overlap of IP locations with
school locations that
conduct learning
assessment for grade 4
students
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▪ Need to hire labor to support
operations of Component 2
▪ Develop LMP as guidance
for PIU to recruit and select
the workers (consultants)
Component 3
Policy and
continuous
professional
development for
teachers, school
directors, and
supervisors
▪ Strengthen and expand
access to peer working
groups for teachers,
school directors, and
supervisors
▪ Develop, pilot, and roll
out face-to-face in-
service training sessions
for educational personnel
▪ Design and develop key
in-service training
courses, resources, and
materials in identified
areas
▪ Strengthen capacity of
key educational
personnel
▪ Provide training for
implementation of
Component 3
▪ Hire individual specialist
consultant as teacher
capacity building expert
▪ Hire event organizer for
organizing training
▪ No environmental impact
▪ No direct but may be indirect
social impact and need for
yearly monitoring. Project can
identify indirect benefits for IP
from the results of yearly
monitoring. However, field
studies are needed to see (i)
whether the IPs in the list meet
the characteristics of ESS7 or
they if they belong to another
group that needs further
attention; and (ii) whether the
specific training methods
received by teachers in the
remote area can provide benefit
that can be applied in the class
or there are other benefits for IP
students.
▪ Need to hire labor to support
operations of Component 3.
▪ Develop SEP for
consultations with
stakeholders regarding the
design of the Project and
environmental & social risk
management, including
representatives of IP
communities, NGO/CSO
▪ Social impact assessment
at mid-term review and
completion of the Project.
Initial screening to identify
an overlap of IP locations
with school location for
teachers from the remote
area receiving training.
▪ Develop LMP as guidance
for PIU to recruit and select
the workers (consultants).
Component 4
Strengthen
systems to support
quality
improvement
▪ Strengthen MoRA data
systems
▪ Provide grants to under-
performing MoRA to
encourage improved use
of finances to achieve the
NES
▪ Provide technical
assistance for additional
systems - strengthening
activities within MoRA
▪ Provide training for
implementation of
Component 3
▪ Hire individual specialist
consultant as
management expert for
schools under MoRA
▪ Hire event organizer for
organizing training
▪ There are likely some activities
related to procurement of
information and communication
technology (ICT) software and
hardware for central, regional,
district, and provider levels,
however the Project is not
expected to generate
significantly more e-waste than
would be the case in absence
of the Project
▪ Need midyear and yearly
monitoring to evaluate
performance of e-waste
management
▪ No social impact
▪ Develop LMP as guidance
for PIU to recruit and select
the workers (consultants).
▪ Develop Environmental
Code of Practice (ECOP)
as guidance for PIU in
managing e-waste properly
▪ Train PIUs on the
implementation of ECOP for
e-waste management
▪ Develop SEP in
consultation with
stakeholders on the design
of the Project and
environmental & social risk
management, including
representatives of interest
groups on e-waste
management.
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5. STAKEHOLDER IDENTIFICATION
To define a communication process with the stakeholders, several groups that may be
interested and/or affected by the Project implementation have been identified. There are
a number of groups of people and social groups who are interested in the Project on
different levels. In particular for this Project, these may be identified as people, social
groups, and organizations who will directly or indirectly benefit from the Project. This
includes Cluster Working Groups for Teachers and Principals, Subject Matter Teacher
Consultative Group, Group for Principals, School Committee, Representatives of IP, and
so on.
Agencies who may influence and make decisions on implementation of the Project and/or
may have an interest in the Project include governmental entities such as MoRA (at
provincial and district/city level), Ministry of Finance, Bappenas, and Ministry of
Environment and Forestry.
The main groups of stakeholders identified so far are listed in the table below. The list can
be updated and modified during the Project implementation.
Level of Stakeholder Interest/Involvement in the Project
Stakeholders who may directly or indirectly
benefit from the Project Role
MoRA - Carry out the Project activities to improve (i) planning and
budgeting system, (ii) student assessment system, (iii) teacher
competency, and (iv) education data system.
- Monitor on a regular basis and provide semester and annual
implementation report of the Project
- Prepare a Project Manual for ECOP/SPPL to handle unused
equipment (if any) by recycling, trade in to the vendors, or to
dispose them properly as per Indonesian regulations on e-
waste
- Monitor progress of e-waste management and report about it in
the semester report (as part of the midyear implementation
report)
- Prepare a ECOP/SPPL for medium rehabilitation and repair
works of classrooms, librarries, laboratories.
Ministry of Environment and Forestry Issue permit for licensed company eligible for disposing or
recycling e-waste
Ministry of Finance - Provide approval for annual planning and budget
- Part of Steering Committee will monitor the performance and
accountability of the Project
- Provide verification whether e-waste can be abolished from the
list of state-owned assets by means of recycling or disposing e-
waste or trade in to the vendors.
National Planning Body (Bappenas) - Provide approval for annual planning and budget
- Part of Steering Committee will monitor the performance and
accountability of the Project
Dinas Lingkungan Hidup dan Kebersihan
Kabupaten/Kota
Provide Temporary Collection Facility (Tempat Pembuangan
Sementara/TPS)
2
Stakeholders who may directly or indirectly
benefit from the Project Role
Regional office of MoRA at provincial level
(Kanwil Kemenag Provinsi)
- Host the implementation of Component 3 for teachers from
remote areas
- Conduct field supervision of implementation
- Prepare quarterly, midyear, and annual designated activity
reports and send to PIU
- Involve in public consultation of the SEP
MoRA office at district/city level (Kantor
Kemenag Kabupaten/Kota)
- Conduct field supervision of implementation
- Prepare the quarterly, midyear, and annual designated activity
reports and send to PIU
- Involve in public consultation of the SEP
Provincial government (People’s Welfare
Division under Secretariat of Governor Office)
Involve in public consultation of the SEP
District/city government (People’s Welfare
Division under Secretariat of Bupati/Mayor
Office)
Involve in public consultation of the SEP
School Committee (representatives of student
parents, madrasah, and local leader)
Involve in public consultation of the SEP
Representatives of teachers from remote
areas
- Involve in public consultation of the SEP
- Involve in monitoring and evaluation
Representatives of IP communities - Involve in public consultation of the SEP
Representatives of KKG - Involve in public consultation of the SEP
Representatives of MGMP - Involve in public consultation of the SEP
Representatives of Pengawas Group - Involve in public consultation of the SEP
Representatives of Kepala Sekolah Group - Involve in public consultation of the SEP
NGO/CSO in Jakarta and city level - Involve in public consultation of the SEP
6. COMMUNICATION METHODS WITH STAKEHOLDERS
A variety of methods of communication with the stakeholders will be carried out at three
levels: Jakarta, province/district/city, and at the school or village level. The purpose of
using various methods with each stakeholder group is to ensure easy, transparent, direct,
open, and interactive communication with all stakeholders and to get feedback during the
Project preparation and implementation phases. For the remote stakeholders, it may be
necessary to provide for separate meeting or additional documents such as summary
documents and reports that should be placed in the public domain, such as meetings,
official correspondence, or MoRA office at district/city.
3
The methods used may vary according to the target groups, for example,
• Regular meetings within government institutions (at central and
province/district/city level)
• Interviews with representatives of IP communities and relevant organizations
• Public meetings (at province, district/city, village), workshop, and/or focus group
on specific topics
• Survey, questionnaire
Engagement and consultations with workers will also be considered. To operate the four
components optimally, the Project requires workers. It is expected that all workers are
from the Indonesian labor force. The requirement for workers will be outlined in the LMP
as guidance for the PIU to recruit and select the workers.
In view of environmental and social impacts, the Project activities under Component 1,
sub-component 1.4 will involve civil works or construction. This is medium rehabilitation
and repair works of classrooms and other learning support rooms such as libraries and
laboratories. The type of construction is simple construction works and not a multi-year
project. All the civil works will be conducted on existing building and land. Therefore it
could not have an adverse impact to the social but may minor impact to the environment.
The Project Operation Manual will include simple guidance on how to monitor the activity
of medium rehabilitation and repair works.
Under Component 4 Improve Education Data Management System, there will be some
activities related to procurement of ICT software and hardware for central, regional,
district, and provider levels. The Project is not expected to generate significantly more e-
waste than would be the case in absence of the Project. In addition, most of the ICT
procurement is planned to be virtual (such as the purchase of a small number of servers
which may be virtual, for example, Amazon or MS Cloud in the case of cloud servers). The
Project Operations manual will include some simple technical guidelines (ECOP) on how
to handle the unused equipment (if any) by recycling, trade in to the vendors, or to dispose
them properly as per Indonesia regulations on e-waste. In addition, energy efficiency could
also be introduced during procurement and use of equipment (energy-saving PCs, and so
on). Lastly, training program for ECOP implementation and procurement for PIU staff at
the provincial and district MoRA offices who are responsible for the procurement and
disposal of electronic equipment and for the purchase of energy-saving equipment. This
will be part of the Project Operations Manual and training and development plan at
provincial/district level.
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7. RESOURCES AND RESPONSIBILITIES FOR IMPLEMENTING
STAKEHOLDERS ENGAGEMENT ACTIVITIES
The Project will establish the PIU with a Project Director under the responsibility of the
Directorate General for Islamic Education, MoRA. This PIU will engage and cooperate with
stakeholders to build and maintain a constructive coordination/relationship with them. All
members of the PIU are representatives within MoRA.
Implementation of the SEP will be covered by MoRA funds under the control of the Project
Director.
The main task of the PIU Central is to be responsible for the overall project
implementation, resolution of problems with the Project, and collaborating with the
Steering Committee.
The PIU Central will work with the PIU Province for achieving communication with the
MoRA office at the district/city level and other stakeholders and will use these to:
• Provide updates and keep stakeholders/public informed on progress of the
Project.
• Inform relevant stakeholders about grievance mechanism and procedures as
detailed within this SEP and receive any grievances and complaints from public
in accordance with the grievance procedure discussed in Chapter 8.
• Consult with interest groups and ensure that consultations are inclusive and
accessible both in format and location according to the characteristics of these
group. As necessary, representatives of IP communities will be adjusted to the
location where the schools under MoRA are located.
Annex 1 provides a list of KAT4 based on the list of IPs in 2017–2019 published by the
Ministry of Social Affairs and the location of Hutan Rakyat belonging to IPs issued by
Ministry of Environment and Forest and the list of IP according to AMAN.5
All individual meetings will be undertaken by the PIU and all outcomes agreed through the
individual meetings will be recorded and documented by the PIU in the Project Office in
Jakarta. The objective of such meetings is to review, agree, and implement the monitoring
and evaluation related Project activities.
4 The Ministry of Social Affairs uses the term/characteristic IP as KAT= Kelompok Adat Terpencil (Remote
Adat Group). 5 AMAN = Aliansi Masyarakat Adat Nusantara (Indigenous Peoples' Alliance of the Archipelago). AMAN is
an Indonesian indigenous peoples' human right and advocacy organization founded in 1999.
5
8. PUBLIC DISCLOSURE
Documentation and information on updates from the Project activities and the result of
consultation with stakeholders will be disclosed by PIU in some places:
• MoRA website → https://kemenag.go.id. A web page for the Project will be
created at the start of the Project.
• Project Office/PIU Office, Direktorat Jenderal Pendidikan Islam, Gedung
Kementrian Agama, Lt 6, Jl. Lapangan Banteng Barat No 3-4, Jakarta Pusat.
9. GRIEVANCE REDRESS MECHANISM
Transparency and accountability are the core elements of the Support to Indonesia's
Ministry of Religious Affairs for Improved Quality of Education Project. For this purpose,
the Project will include a GRM. The goal of the GRM is to strengthen accountability to
beneficiaries and to provide channels for Project stakeholders to provide feedback and/or
express grievances related to Project-supported activities. The GRM is a mechanism that
allows for the identification and resolution of issues affecting the Project. By increasing
transparency and accountability, the GRM aims to reduce the risk of the Project
inadvertently affecting citizens/beneficiaries and serves as an important feedback and
learning mechanism that can help improve Project impact.
The mechanism focuses not only on receiving and recording complaints but also on
resolving them. While feedback should be handled at the level closest to the complaint, all
complaints should be registered and follow the basic procedures set out in this chapter.
GRM is a process for receiving, evaluating, and addressing Project-related complaints
from citizens and affected communities at the level of the Project.
The design of the Project-level GRM will build upon the existing system of handling
complaints. The design of the GRM is described below.
9.1. DEFINITION OF GRM
For the purposes of these operational guidelines, GRM is a process for receiving,
evaluating, and addressing Project-related complaints from citizens and affected
communities at the level of the Project. The terms ‘grievance ‘and ‘complaint’ are used
interchangeably.
9.2. GRM SCOPE AND USE
Scope: GRM will be available for Project stakeholders and other interested parties to
submit questions, comments, suggestions and/or complaints, or provide any form of
feedback on all Project-funded activities.
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GRM’s users: Project beneficiaries, project-affected people (that is, those who will be
and/or are likely to be directly or indirectly affected, positively or negatively, by the Project),
as well as the broader citizenry can use the GRM for the above purposes (see Scope).
GRM’s management: The GRM will be managed by MoRA’s PIU, under the direct
responsibility of the Project Director
Submission of complaints: Complaints can be submitted at any time throughout Project
implementation.
9.3. PROCEDURES
Channels to make complaints
MoRA will establish the following channels through which citizens/beneficiaries/Project
Affected Persons (PAPs) can make complaints regarding project-funded activities:
(a) Social media: Twitter, Facebook (will be ready before the Project starts)
(b) By Email: Project’s email addresses (will be ready before the Project starts)
(c) By writing to the Project/PIU Office: Direktorat Jenderal Pendidikan Islam,
Gedung Kementrian Agama, Lt 6, Jl. Lapangan Banteng Barat No 3-4, Jakarta
Pusat.
(d) Hotline number: This will be ready before the Project starts (can be text - WA or
SMS)
The Project shall ensure flexibility in the channels available for complaints, as well as
ensure access to the contact information for individuals who make complaints.
Confidentiality and conflict of interest
Complaints may be made anonymously, and confidentiality will be ensured in all instances,
including when the person making the complaint is known. For this reason, multiple
channels to make a complaint have been established and conflicts of interest will be
avoided.
Receipt and recording of complaints
The person receiving the complaint will complete a grievance form (see Annex 2) and will
record the complaint in the Register of Complaints, which the GRM manager oversees.
The complaint is to be submitted immediately in the tracking system for sorting and
redirecting to the appropriate department responsible for investigating and addressing the
complaint, or to the staff if the complaint is related to a specific Project activity. The Project
Director is responsible for determining who to direct the complaint to, whether a complaint
requires an investigation (or not), and the timeframe to respond to it.
When determining who will be the investigating officer, the Project Coordinator should
ensure that there is no conflict of interest, that is, all persons involved in the investigation
7
process should not have any material, personal, or professional interest in the outcome
and no personal or professional connection with complainants or witnesses.
Once the investigation process has been established, the person responsible for
managing the GRM records and enters this data into the Register of Complaints.
The number and type of suggestions and questions should also be recorded and reported
so that they can be analyzed to improve Project communications.
Review of received complaints or/and inquiries
The complaint shall be examined within 10 working days of its receipt. The person
responsible for investigating the complaint will gather facts to generate a clear picture of
the circumstances surrounding the grievance. The investigation/follow-up can include site
visits, review of documents, and a meeting with those who can resolve the issue.
The results of investigation and the proposed response to the complainant will be
presented for consideration to the Project Coordinator, who will decide the course of
action. Once a decision has been made and the complainant informed, the investigating
specialist describes the actions to be taken in the grievance form (see Annex 2), along
with the details of the investigation and the findings and submits the response to the
Project Director for signing.
Response to complainant
The complainant will be informed about the results of verification via letter, email, or by
post, as received. The response shall be based on the materials of the investigation and,
if appropriate, shall contain references to the national legislation.
The deadline for investigating the complaint may be extended by 10–30 working days by
the Project Coordinator, and the complainant is to be informed about this fact, whether:
(a) additional consultations are needed to provide response to the complaint;
(b) the complaint refers to a complex volume of information and it is necessary to
study additional materials for the response.
9.4. AWARENESS BUILDING
Information provided in an accessible format
Information about the GRM will be available on the https://kemenag.go.id website and will
be included in communications with stakeholders.
9.5 STAFFING AND CAPACITY BUILDING
Tasks and responsibilities of the PIU team on the GRM
The Project Director will allocate responsibilities to the PIU staff. These will be documented
in the Project Operations Manual, and kept updated.
8
• Overall management of the GRM system
• Developing and maintaining awareness-building
• Collection of complaints
• Recording complaints
• Notification to the complainant on the receipt and timeline to review a complaint
• Sorting/categorization of complaints
• Thorough examination of the issues, including the causal link between Project
activities and alleged damage/harm/nuisance
• Decision making based on such examination
• Processing appeals or continuous communication with complainants with the
purpose to resolve issues amicably
• Publishing responses to complaints, unless otherwise requested by complainants
due to privacy or other concerns
• Organization and implementation of information materials and awareness
campaigns
• Reporting and feedback on GRM results.
9.6 TRANSPARENCY, MONITORING, AND REPORTING
Transparency
Policies, procedures, and regular updates on the GRM system, the complaints made and
resolved, will be available on https://kemenag.go.id web page. They will be updated on a
midyear basis.
Regular internal monitoring and reporting
The PIU will assess quarterly the functioning of the GRM to:
• Provide a monthly/quarterly snapshot of GRM results, including any suggestions
and questions, to the Project team and the management.
• Review the status of complaints to track which are not yet resolved and suggest
any needed remedial action.
During quarterly PIU meetings, the Project team shall discuss and review the effectiveness
and use of the GRM and gather suggestions on how to improve it.
Reporting in midyear and annual progress reports submitted to the World Bank
In the midyear and annual Project implementation reports submitted to the Bank, MoRA
shall include a GRM section, which provides updated information on the following:
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• Status of establishment of the GRM (procedures, staffing, awareness building, and
so on);
• Quantitative data on the number of complaints received, the number that were
relevant, and the number resolved;
• Qualitative data on the type of complaints and answers provided, issues that are
unresolved;
• Time taken to resolve complaints;
• Number of grievances resolved at the lowest level, raised to higher levels;
• Any particular issues faced with the procedures/staffing or use;
• Factors that may be affecting the use of the GRM/beneficiary feedback system;
• Any corrective measures adopted.
10. MONITORING AND REPORTING
Midyear and annual progress report on the Project activities will be available at the Project
office and available on the MoRA web page: https://kemenag.go.id. The specific web page
for the Project will be established before the Project starts.
10
Annex 1: The Summary of Public Consultation on April 23, 2019
Summary of Public Consultation
Madrasah Education Quality Reform Project
23 April 2019, Jakarta
No Time Venue Participants Key issue raised during the
consultation
How the issues will be addressed
in the SEP, ECOP, LMP & Soc
Impact Assessment
1 23 April
2019, jam
09.00 –
11.00
Ditjend PendIs
Room, MoRA
Office
Attended by 25
participants from the
elements:
• Ministry of Finance
• Ministry of Environment
and Forestry
• DKI Jakarta Province (Environmental Services)
• Coordinating Ministry of Human and Cultural Development
• MoRA (relevant Directorates)
• CSOs: Muhammadiyah and Maarif Nahdlatul Ulama (NU)
• The World Bank
Remarks from Director General of Pendidikan Islam:
- Indonesia in the future is highly dependent on quality human resources,
therefore the quality of education must continue to be improved.
- Ministry of Religion already knows its weaknesses and weaknesses in managing
education. One reason is limited budget.
- MoRA conducts an exit strategy to address quality education funding through
collaboration with the World Bank.
- Positive support has been provided by Bappenas and the Ministry of Finance
and is currently awaiting administrative requirements from Bappenas and the
Ministry of Finance to immediately negotiate with the World Bank.
11
No Time Venue Participants Key issue raised during the
consultation
How the issues will be addressed
in the SEP, ECOP, LMP & Soc
Impact Assessment
The consultation was open
by Director General of
Pendidikan Islam. The
consultation moderated
and closed by Director of
KKSK
Madrasah schools under Muhammadiyah
also have limited facilities and
infrastructure, and even many madrasahs
are poor in education facilities in
accordance with quality standards. Does
the Project pay attention to this?
The project does not specifically build
facilities and infrastructure.
Component 1 indirectly provides
development of facilities &
infrastructure. Each school through e-
RKAM must conduct a self-assessment
to plan the use of BOS.
Teachers should not only be given
knowledge of teaching materials but also
learning related to the care of the
surrounding environment, especially for
those who live in remote areas, coastal
such as getting children to wash their
hands before eating, getting children to
brush their teeth in the morning.
Good input and will be considered in
developing learning modules.
Need also to encourage “sekolah ramah anak”/ children friendly school- At the moment some awareness have been made for teachers
12
No Time Venue Participants Key issue raised during the
consultation
How the issues will be addressed
in the SEP, ECOP, LMP & Soc
Impact Assessment
Maarif NU welcomed the plan to improve
the quality of madrasah education. What
is the model of cooperation in managing
e-waste?
The Project will do public campaign
through distributing poster E-COP and
location of Drop Point
The Project will provide capacity
building for PIUs, districts/cities,
schools in managing e-waste.
Electronic waste is specific waste which is
categorized as B3 waste and requires a
Drop Box. For the DKI area, Dropping
Points have been provided for
transportation by licensed companies.
The Project has been taking care
about e-waste through E-COP.
DKI Jakarta has provided Drop Box in
some schools and universities. Need
information the estimation volume of
each location from Component 4 in
Jakarta area. This is to anticipate the Drop
Box capacity when it is full, e-waste will
be taken by a licensed company.
Good information and very useful. The
Project through PIU will follow up and
need data the location of Dropping
Points in Jakarta Province from Dinas
LH under DKI Jakarta.
So far education data in DG Pendis is very
difficult to be accessed by the public,
including by government agencies. The
existing EMIS, Simpatika applications are
updated. It is highly expected that
through Component 4 the existing
Through Component 4 the Project will
make improvements to data and
applications. Existing systems (such as
EMIS and Simpatika) will be integrated
with the latest applications and data.
The Project will open access to
13
No Time Venue Participants Key issue raised during the
consultation
How the issues will be addressed
in the SEP, ECOP, LMP & Soc
Impact Assessment
applications will be synergized with new
applications and the data will be up dated
according to existing conditions and easily
accessible to all parties.
information for the public, including
data on teachers, students and
madrasahs/schools that have received
training or assistance from the Project
and regular project reports and other
information relating to the operational
of the Project.
For the grievance redress mechanism
will be opened various accesses
through:
• twitter, facebook (will be ready before the Project starts)
• Email: Project’s email address (will be ready before the Project starts)
• Kantor Proyek/PIU, Direktorat Jenderal Pendidikan Islam, Gedung Kementrian Agama, Lt 6, Jl. Lapangan Banteng Barat No 3-4, Jakarta Pusat.
• Hotline number: can be text through WA or SMS (will be ready before the Project starts)
Data on education in MoRA is very
minimal and the level of use of the budget
is also still low. This is one of the
constraint in related to providing BOS
Agree, Component 4 is designed to
solve those problem as well as
Component 1 through e-RKAM.
14
No Time Venue Participants Key issue raised during the
consultation
How the issues will be addressed
in the SEP, ECOP, LMP & Soc
Impact Assessment
support. Hopefully with Component 4
there is a significant improvement in data
and is able to use the budget properly.
If the Project start in 2019 please be sure
MoRA has proposed allocation proper
budget to MoF to cover activities in 2019
till 2024.
The Ministry of Religion has proposed
a project budget that is not too large
for 2019. The budget for project
launch activities and the formation of
a Project Team (functional team) while
the budget for 2020 and so on
requires a larger allocation than the
first year.
Closing:
1. MoRA will do bigger public consultation to discuss more detail on substance 2. Involving more CSO, not only NU and Muhammadiyah 3. Also to involve professional such as teacher association – to get input from
education perspective
15
The list of attendees of the Public Consultation, April 23, 2019
16
17
18
Public Consultation on April 23, 2019
19
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ANNEX 2: GRIEVANCE/INQUIRY RECORD
GRIEVANCE/INQUIRY RECORD (Form A)
Instructions: This form is to be completed by staff receiving the inquiry or grievance and kept in the Project’s file. Attach any
supporting documentation/letters as relevant.
Date Grievance Received:
Name of Staff Completing Form:
Grievance Received (check √):
□ National □ City/Town □ Municipality □ Village
Mode of Filing Inquiry or Grievance (check √):
□ In person □ Telephone □ E-mail □ Phone Text Message □ Website
□ Grievance/Suggestion box □ Community meeting □ Public consultation □ Other ______________
Name of Person Raising Grievance: (information is optional and always treated as confidential)
Gender: □ Male □ Female
Address or contact information for Person Raising Grievance: (information is optional and confidential)
Location where grievance/problem occurred [write in]
National:
Town/City: Province: Village:
Brief Description of Grievance or Inquiry: (Provide as much detail and facts as possible)
Category 1 Social Safeguards
Category 2 Environmental Safeguards
Category 3 Grievances regarding violations of policies, guidelines and procedures
Category 4 Grievances regarding contract violations
Category 5 Grievances regarding the misuse of funds/lack of transparency, or other financial management concerns
Category 6 Grievances regarding abuse of power/intervention by Project or government officials
Category 7 Grievances regarding staff performance
Category 8 Reports of force majeure
Category 9 Grievance about Project interventions
Category 10 Other
Who should handle and follow up on the grievance:
Progress in resolving the grievance (e.g answered, being resolved, settled):