Feedback Grievance Redress Mechanism (FGRM) Policy and Procedures

Last updated: December 11, 2023

The Company has developed this public-facing Feedback Grievance Redress Mechanism (FGRM) Policy for the projects and programs it supports, and steps for submitting grievances on funded projects and programs, and guidelines for responses and resolution. We seek to promote positive social and environmental impact from funding projects and incorporate robust environmental and social risk identification and mitigation policies, procedures, and strategies to avoid causing harm.

Terra Global’s work often focuses on the most marginalized and vulnerable populations across the world, where they are often being supported to adopt new practices and approaches. Thus, Terra Global has an obligation to integrate community and stakeholder views, cultural values, and ways of life into the activities being funded. Therefore, it is imperative that Terra Global is receptive to the concerns of the communities and stakeholders in the areas in areas of operation. Further, Terra Global is accountable for responding to and resolving any and all grievances linked to the activities promoted with the provided funding.

Types of Grievances

The following types of grievances related to projects and programs funded by Terra Global will be addressed:

Environmental, social, community health, safety, and security;
Procurement of goods and services;
Gender bias and harassment;
Labor, compensation, and any issues that may arise due to interactions between the labor workforce and host communities;
Resettlement-related grievances, such as the valuation of assets, amount of compensation paid, level of consultation, non-fulfillment of contracts, and timing of compensation, amongst others, will also be handled by this process.

Grievance and Complaint Process

Any community or group (at least two or more people) that believes it is or may be negatively affected by a failure on the part of Terra Global to follow its safeguards in the design or implementation of a Terra Global funded project may file a complaint. Representatives filing a complaint on behalf of a group or community must provide concrete evidence of authority to represent them. Complainants can request confidentiality. Anonymous complaints will be considered.

Grievances that will not be considered include:

Complaints submitted two years after the Terra Global funded project or program has concluded, and,
Complaints submitted two years after the date that the complainant became aware of the negative impacts of a Terra Global funded project or program.

Required Complainant Information

Complaints are required to include the following information:

Complainant’s name and contact information (optional if filing anonymously).
If not filed directly by the complainant, proof that those representing the affect people or communities have the authority to do so.
The specific Terra Global project or program of concern and type of grievance.
The harm that is or may be resulting from the project.
Timeframe that the reporting complaint occurred.
Any other relevant information or documents.
Any actions taken so far to resolve the program, including contacting Terra Global or other local project partners or implementers.
Proposed solutions.
Whether confidentiality is requested (stating reasons).

Complaints may be submitted in the community/group’s native language.

How to File a Grievance Complaint

Anonymous complaints may be submitted here.

Email: grievances@terraglobalcapital.com

Mailing Address:

Terra Global Capital, LLC

6114 La Salle Avenue, Suite 441

Oakland, CA 94611

Complaint Review Process

A complaint is received (via anonymous form submission, e-mail, or mail).
The complaint is recorded in Terra Global’s Feedback Grievance Redress Mechanism (FGRM) Tracker, and the complainant is notified of receipt and informed of next steps.
Terra Global will assess the eligibility of the complaint and provide a response as to whether it is eligible within 15 days, ineligible complaints will be recorded in the Tracker with rationale for ineligibility.
Project Team is informed (an initial assessment may be required to understand who the involved parties are). On occasion, an involved party, particularly the complainant, may be informed later in the assessment phase, to preserve information and review baseline facts before notice.
The complaint is assessed by the Terra Global Compliance Unit as it is made. This may involve interviewing additional parties to collect more information or bringing in third parties to support the investigation and assessment. The investigation is conducted by a Compliance Unit member (e.g., CFO/COO, Corporate Operations, Associate), whom is entirely independent of the Project Team.
A response/resolution is decided on by the CEO, Terra Global Ethics Committee, or other decision bodies named under specific policies. The decision is made by someone independent of the Program Team.
Response is communicated to the complaining party (where possible) and to any involved parties.
Resolution is recorded in the FGRM Tracker.
Any lessons are applied internally as appropriate (e.g., updating policies or processes).