Sustainability

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Grievance Mechanism

1. Introduction

The purpose of this document is to formalize the management of grievances from Malaysia Smelting Corporation Berhad’s stakeholders to minimize the supply chain risks to the business. The grievance process, outlined in the document, provides an avenue for stakeholders to voice their concerns and gives transparency on how grievances will be managed internally, all of which aims to improve MSC’s responsible sourcing of minerals and its supply chain.

2. Scope

The grievance mechanism procedure applies to all external stakeholders related to the mineral extraction, trade, handling and export in a conflict affected and high-risk areas. This procedure does not cover grievances raised by internal stakeholders, such as employees, who should refer to Malaysia Smelting Corporation Berhad’s internal grievance procedure.

3. Terms/Definitions

Grievance
An issue, concern, problem, or claim (perceived or actual) that an individual or community group wants addressed by the company in a formal manner.
Grievance Mechanism
A formalized way to accept, assess, and resolve community complaints, concerning performance or behaviour of the company, its contractors, or employees, including adverse supply chain, environmental and social impacts.
Internal Stakeholders
Groups or individuals within a business who work directly within the business, such as employees and contractors.
External Stakeholders
Groups or individuals outside a business who are not directly employed or contracted by the business but are affected in some way from the decisions of the business, such as customers, suppliers, community and the government.

4. Grievance Reporting Channels

MSCB will communicate this procedure to its external stakeholders to raise awareness and offer transparency of how stakeholders can voice their grievances. Various channels for external stakeholders to voice their grievances include:

  • Telephone : Stakeholders can contact stakeholder contact officers as follows
    PIC no 1 : Raveentiran Krishnan
    PIC no 2 : Roslim Noor
    PIC no 3 : Michelle Yong
  • Email: Grievances can be sent to: [email protected]

5. Roles and Responsibilities

Roles
Responsibilities
Stakeholder Contact Officer
  • Receives grievances and assigns a grievance owner.
  • Ensures the grievance mechanism procedure is being followed correctly.
  • Liaise with the external stakeholder(s).
  • Maintains grievance register and monitors any correspondence.
  • Monitors grievances and report findings to COO.
  • Raises internal awareness of the grievance mechanism among employees and contractors.
Grievance Owner
  • Investigates the grievance and liaise with the stakeholder contact officer.
  • Develops resolution and action to rectify any issue/s.
  • Follow up and track progress of grievance.

6. Grievance Mechanism Process

The flowchart below describes the grievance mechanism process to resolve any grievance: Grievance Process Flow

6.1 Receive Grievance

Over the phone

If a grievance is received over the phone, the stakeholder contact officer will complete a Grievance Lodgement Form for further processing.

Electronic

The stakeholder contact officer receives all grievances that come through via email or Malaysia Smelting Corporation Berhad’s website. The stakeholder contact officers will review the grievance form and process the grievance in accordance to this procedure.

6.2 Acknowledge

A grievance will be acknowledged by the stakeholder contact officer, within five working days upon receipt of a grievance. Communication will be made either verbally or in written form. Stakeholders will outline their preferred method of contact on the Grievance Lodgement Form.

The grievance acknowledgment should include a summary of the grievance, method that will be taken to resolve the grievance and an estimated timeframe in which the grievance will be resolved. If required, the stakeholder contact officer may ask stakeholder/s for any additional information or to clarify any issue.

6.3 Evaluate and Investigate

Grievances will be evaluated depending on the level of severity in order to determine the grievance owner and how the grievance is approached. See below table categorizing the different levels:

Grievance
Description
Grievance Owner
Level 1
When an answer can be provided immediately and/or MSCB are already working on resolution.
Stakeholder Contact Officer
Level 2
One off grievance that will not affect MSCB's reputation.
Supervisor level or above
Level 3
Repeated, extensive and high profile grievances that may damage MSCB's reputation.
COO or above

The grievance owner together with the stakeholder contact officer are responsible for investigating the grievance. The investigation may require the grievance owner to make site visits, consult employees, contact external stakeholders and complete other activities.

Minutes of meeting, discussion and activities need to be recorded during the investigation. Information gathered during the investigation will be analysed and will assist in determining how the grievance will be handled and what steps need to be taken in order to resolve the grievance.

6.4 Collaborative Resolution

In consultation with the stakeholder and any other actor, the stakeholder contact officer will propose a solution and presents it to the grievance owner.

6.5 Implement Resolution

The grievance owner is responsible for initiating action, monitors action taken to ensure it meets the deadline. Once all actions have been completed and the grievance owner feels that the grievance has been resolved, the grievance owner will then inform the stakeholder contact officer to further advise the external stakeholder/s via the preferred method of contact.

6.6 Follow up and close out

The stakeholder contact officer will contact the external stakeholder/s four weeks after the grievance is resolved to verify that the outcome was satisfactory and also gather feedback if any on the grievance process.

If required, the stakeholder contact officer may need to follow up with the external stake-holder to confirm that all parties are satisfied.

7. Appeal

If the external stakeholder(s) do not agree with the resolution and/or does not agree with the proposed actions, then the stakeholder contact officer needs to bring the matter to the attention of the COO who will review the grievance and documents gathered throughout the investigation and determine whether further actions are required to resolve the grievance.

If MSCB are unable to resolve a complaint or a stakeholder is not satisfied with the outcome, MSCB may seek advice from other independent parties.

8. Reporting

Information outlining the number of grievances, resolution time and outcomes of grievances will be reported to COO on a monthly basis. MSCB will evaluate and update the Grievance Mechanism procedure every three years (or when required) to continually improve its stakeholder engagement.

9. Storing of Grievances

All records, including grievance forms, investigation notes, and minutes of meetings will be securely stored on Malaysia Smelting Corporation Berhad’s internal server with suitable encryption to ensure privacy and confidentiality is maintained for all parties involved.

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