Grievances

Grievance Redress Mechanism

Generation Investment Management (Generation) is committed to identifying, assessing and managing environmental and social risks across our investments. We recognise that our activities have the potential to affect a broad range of stakeholders, including communities, workers and vulnerable groups, and we take seriously our obligation to listen and respond to concerns.

Our Grievance Redress Mechanism (GRM) provides a formal channel for stakeholders to raise concerns in good faith about specific, identifiable harms or failures arising from Generation’s investment activities or those of our portfolio companies. Grievances are investigated by our General Counsel or their designee, acting independently of Generation’s investment decision making and environmental and social (E&S) management functions.

A grievance, for the purposes of this mechanism, is an allegation that Generation or a portfolio company has caused or may cause harm to a party who is or may be negatively affected by its activities, or that Generation or a portfolio company has failed to meet an applicable environmental, social or governance standard or commitment – whether under our own policies, applicable law or the requirements of a specific funding arrangement. While all will be treated respectfully, expressions of opinion, policy disagreement or general advocacy do not constitute grievances under this mechanism.  

Types of grievances

This GRM is available to parties who have genuine demonstrable concerns arising from activities related to the implementation of Generation’s projects, programmes or activities, including parties who are, or may be, negatively affected by them. These grievances could be related to, but are not limited to:

• Environmental, social, community health, safety and security;
• Gender and other bias and harassment;
• Labour, compensation and any issues that may arise due to interactions between the labour workforce and host communities;
• Fraud, corruption and other prohibited practices;
• Procurement of goods and services; and
• Resettlement-related grievances, such as the valuation of assets, amount of compensation paid, level of consultation, non-fulfilment of contracts and timing of compensation.

Eligibility

All submissions will be acknowledged upon receipt within 5 business days. Generation reserves the right to determine whether a submission falls within the scope of this mechanism prior to initiating a formal investigation. Therefore, while all submissions will be considered fairly, not all submissions will be considered in scope for further investigation.  For example, if a submission proceeds on the basis of a factual inaccuracy as to Generation’s role in a particular activity.

A grievance should be submitted within two years of the complainant becoming aware of the relevant impact, or within two years of the closure of the relevant project, programme or activity.

Generation prohibits retaliation of any kind against any person who submits a grievance in good faith or who assists in its investigation or resolution.

Grievance process

1. A grievance is received via email or mail as indicated on this page.
2. The grievance is recorded in Generation’s Grievance Redress Mechanism Tracker (the “Tracker”), and the complainant is notified of receipt.
3. Generation assesses whether the submission falls within the scope of this mechanism. The submitter is informed of this determination.
4. Where the submission is in scope, involved parties are informed. An initial assessment may be required to understand who the involved parties are. On occasion, an involved party may be informed later in the assessment phase, in order to preserve information and review baseline facts before notice.
5. The grievance is assessed by Generation’s General Counsel, or their designee, who conducts the investigation independently of the investment decision making and E&S management functions. Any individual with a conflict of interest in the matter (including anyone within the relevant investment or E&S execution line) is excluded from the investigation, and the General Counsel will recuse where a conflict arises. This assessment may involve interviewing additional parties or commissioning third parties to support the investigation.
6. A response and resolution is decided on by the Chief Operating Officer, acting independently of the investment and programme line and recusing (in favour of a named alternate) where conflicted.
7. The response is communicated to the submitting party (where possible) and to any involved parties. Our aim is to investigate and conclude eligible grievances raised under this mechanism within a reasonable timeframe.
8. The resolution is recorded.
9. Any lessons learned are applied internally as appropriate, for example through updates to policies or processes.
10. Generation aims to provide a substantive response within 30 business days of acknowledging a grievance, or to explain any delay and give a revised timeframe.

Sexual Exploitation, Abuse and Harassment (SEAH)

Generation maintains a zero-tolerance policy towards all forms of sexual exploitation, sexual abuse and sexual harassment (SEAH). Where a grievance alleges SEAH, child safeguarding issues or other related harms, Generation will apply a survivor-centred approach and confidentiality safeguards.

The Tracker entry for such cases will be restricted-access and limited to non-identifying data where appropriate. The grievance will be routed promptly to the appropriate internal function(s) for action and escalation. Where allegations relate to Generation personnel, the matter will be managed under HR procedures. Where allegations relate to portfolio company activities, Generation will engage the relevant portfolio company or will be handled directly as appropriate.

Any SEAH allegation will be documented in a separate, secure and restricted-access log and kept separate from the general Tracker. Information will be shared on a strictly need to know basis, with survivor-centred confidentiality and anonymised trend reporting for oversight.

Internal grievance mechanism

Generation maintains a separate internal grievance mechanism for employees and other internal stakeholders. This is managed by our People function and operates under Generation’s Grievance Procedure, Non-Discrimination and Anti-Harassment and Bullying Policy, and Disciplinary Procedure. Internal stakeholders should refer to those policies directly rather than this external GRM.

How to lodge a grievance

Generation is committed to ensuring that grievances can be raised through accessible channels, including by post or our online form. Grievances may be submitted in English or in the complainant’s local language. Anonymity will be preserved where requested, or where identification could lead to harm, intimidation or fear; anonymous submissions are accepted, although Generation may be unable to respond directly where no contact details are provided.

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Attn: Grievance Mechanism | Generation Investment Management LLP | 20 Air Street | London | W1B 5AN | United Kingdom

Grievance form

Please use this form to share a grievance regarding Generation Investment Management’s investing activities.