This document establishes Development Dynamics’ (DD) formal mechanism for receiving, investigating, and resolving grievances related to adverse human rights impacts, and for remediating harm where DD has caused, contributed to, or is directly linked to negative impacts on people. It operationalises our commitment under the UN Guiding Principles on Business and Human Rights (UNGPs), the International Bill of Human Rights, and the ILO Declaration on Fundamental Principles and Rights at Work.

This Protocol is explicitly aligned with B Corp Standard HR 3.3: 

1.1 Purpose

To provide a legitimate, accessible, predictable, equitable, transparent, rights-compatible, and continuously learning grievance mechanism that meets the UNGP Effectiveness Criteria and B Corp HR 3.3 requirements.

1.1.1 B Corp Human Rights Response Objective

DD will not evaluate the effectiveness of this mechanism solely by the number of grievances received or the speed at which cases are closed. DD will assess whether grievances are safely raised, appropriately investigated, effectively remedied, and whether the response addresses the underlying causes and reduces the likelihood of recurrence. Evaluation findings will be used to strengthen policies, practices, training, supplier relationships and other relevant controls. 

1.2 Scope

• All DD associates (employees, consultants, interns, board members).
• Workers in our supply chain (suppliers, subcontractors, and their employees).
• Affected communities where DD or our suppliers operate.
• Clients and end-users of our services and products.
•  Whistleblowers reporting human rights concerns in good faith.

1.3 Guiding Principles

All grievance handling and remediation activities are guided by the UNGP Effectiveness Criteria for non-judicial grievance mechanisms:

Legitimate: Trusted, fair, and accountable, with clear governance and independence from implicated parties.

Accessible: Known, easy to use, free of charge, and provided in appropriate languages and formats.

Predictable: Clear procedures with defined timeframes at every stage.

Equitable: No disadvantage to users; support provided to navigate the process.

Transparent: Regular communication on progress, with public reporting on trends and systemic issues.

Rights-compatible: Consistent with international human rights standards and local labour law.

Source of continuous learning (B Corp HR 3.3): Analysis of grievance data drives systemic improvement, policy adjustments, and prevention measures. 

2. GRIEVANCE MECHANISM

2.1 What Constitutes a Grievance

A grievance is any concern, complaint, or allegation that DD’s operations, supply chain, or projects have negatively impacted or risk impacting human rights

3. GRIEVANCE HANDLING PROCEDURE

Overview: RECEIPT → ACKNOWLEDGMENT → TRIAGE & ASSESSMENT → INVESTIGATION → RESOLUTION → REMEDIATION → CLOSURE → FEEDBACK → LEARNING → SYSTEMIC IMPROVEMENT

3.1 Step 1: Receipt and Logging (Same Day)

• Receive grievance (First receiver): Any staff member who receives a grievance must log it immediately in the Grievance Register. No grievance may be dismissed or discouraged.
• Assign unique ID (HR Lead / Designated Officer): Format: DD-GR-[YYYY]-[NNN] (e.g., DD-GR-2026-001).
• Record in Grievance Register (HR Lead): Date, channel, category, complainant contact (if provided), initial description, anonymity status, DD’s role (caused / contributed / directly linked).
• Initial safety check (HR Lead): Assess if immediate danger exists (e.g., ongoing violence, threat to life).

Immediate Actions if Safety Risk Identified:

• Suspend relevant activity or remove a person from harm’s way immediately.
• Notify the CEO within 2 hours.
• Engage emergency services or protection agencies if required.
• Document all actions taken in the Grievance Register.

3.2 Step 2: Acknowledgement (24–48 Hours)

• Confirm receipt: Send acknowledgement via complainant’s preferred channel.
• Explain process: Outline next steps, timeframes, and their rights (including right to appeal and right to external recourse).
• Offer support: Provide information on counselling, legal aid, medical support, or protection services where appropriate.
• Set expectations: Provide a realistic timeline for next contact.
•  Anonymous cases: Post acknowledgement on a public notice board or website if the complainant requested public acknowledgement.

3.3 Step 3: Triage and Assessment (3–5 Days)

Categorise severity (HR Lead): Category 1 (Minor), 2 (Serious), or 3 (Critical) — see Section 3.8.

Assess conflict of interest (HR Lead): If the HR Lead or Project Lead is implicated, escalate to CEO or Independent Ombudsman immediately.

Determine jurisdiction (HR Lead): Is this a DD responsibility, supplier responsibility, or joint? Document DD’s role per UNGP framework (caused/contributed / directly linked).

Develop investigation plan (HR Lead): Scope, methods, timeline, resources needed, and independence safeguards.

Notify relevant parties (HR Lead): Inform CEO (Category 2-3)

3.4 Step 4: Investigation (7–30 Days)

3.5 Step 5: Resolution and Remediation Decision (5–10 Days After Investigation)

Substantiated: Develop Remediation Plan; implement corrective action; disciplinary action if DD staff involved; supplier corrective action plan if supplier involved.

Partially substantiated: Partial remediation; address confirmed issues; clarify misunderstandings; document learning.

Unsubstantiated: Explain findings to complainant with evidence summary; close case; no adverse action against complainant; offer alternative support if needed.

Outside DD’s control: Refer to appropriate authority (supplier, client, regulator, police); offer support to complainant; document DD’s leverage attempts.

Affected Stakeholder Participation: Where reasonably practicable and appropriate to the circumstances, affected persons or their representatives will be involved in determining appropriate remediation measures, assessing whether proposed remedies adequately address the harm, and evaluating whether remediation has been effective. Participation will be voluntary and will not compromise confidentiality, safety or the integrity of the investigation. 

3.6 Step 6: Closure (Within 5 Days of Resolution)

• Document outcome: Complete case file in Grievance Register with full audit trail.
• Notify complainant: Explain outcome, remediation, right to appeal, and right to external recourse.
• Notify respondent: If DD staff, explain disciplinary or corrective action; if supplier, explain contractual consequences.
•  Update registers: Close case; record days to resolution; trigger Lessons Learned Log entry ( Annex C).

3.7 Step 7: Feedback, Appeal, and Continuous Improvement (B Corp HR 3.3)

This step operationalises B Corp Standard HR 3.3 by ensuring every grievance contributes to organisational learning:

Complainant feedback: Seek structured feedback on satisfaction, safety, and process improvement within 14 days of closure using the Complainant Feedback Form (Annex D).

Right to appeal: Complaint may appeal outcome within 30 days if: 

(a) new evidence emerges, 

(b) procedural error, 

(c) conflict of interest. 

Appeal body: All appeals will be to the CEO. Decision within 21 days.

External recourse: Complainant always retains the right to seek judicial or regulatory remedy regardless of internal outcome.

Lessons learned capture: Each material lesson identified through a grievance investigation must be assessed to determine whether a change is required to DD’s policies, procedures, training, project design, procurement practices, supplier requirements, leadership practices or other controls. Where an action is required, the action owner, deadline and expected outcome must be documented and monitored to completion. 

Systemic improvement trigger: If a grievance of the same type recurs within 12 months, or if a Category 3 grievance occurs, the HR Lead must initiate a formal Adjustment Proposal ( Annex F) to revise policies, procedures, or training.

Annual synthesis: All grievance data is synthesized into the Annual Human Rights Performance Report (Annex D) and presented to the CEO, including trend analysis, root cause patterns, and improvement measures implemented.

Effectiveness Test
A grievance will not be considered fully closed solely because an investigation has been completed. Before closure, DD will assess whether:

1. the immediate harm has been addressed;
2. appropriate remedy has been provided;
3. the affected person has been informed of the outcome;
4. the root cause has been identified where relevant;
5. corrective or preventive actions have been assigned;
6. retaliation risks have been addressed; and
7. measures are in place to prevent recurrence.

4. REMEDIATION PROTOCOL

4.1 When Remediation is Required

4.2 Severity-Based Remediation Framework

Level 1: Low-Severity Remediation

Minor, one-off impact; easily reversible; no lasting harm.

• Immediate action: Stop or correct the harmful practice within 48 hours.
• Restitution: Restore the affected person to the situation before the harm (e.g., back pay, reinstatement, formal apology).
• Compensation: Small financial compensation for direct losses.
• Corrective action: Training, policy clarification, or process adjustment.
• Verification: Confirm with the affected person that harm is resolved.
• Timeline: Within 14 days of substantiation.
• Cost: Borne by DD or responsible supplier.
• Evaluation: Review effectiveness at 3 months (DD-HR-33-001, Section 4.2).
• Prevention: Measures to address the underlying cause of harm and reduce the likelihood of recurrence, including changes to policies, procedures, incentives, contractual arrangements, training, supervision, project design or supplier management. 

Level 2: Medium-Severity Remediation

Significant but localized impact; some harm already occurred; potential for recurrence.

• DD will conduct and document a root-cause analysis. Where appropriate, Category 1 grievances may also be subject to root-cause analysis where they reveal a recurring pattern, control weakness or systemic risk 
•  Investigation: Root cause analysis to identify why harm occurred.
• Restitution: Restore situations where possible.
• Compensation: Fair compensation for financial losses, medical costs, or suffering.
• Rehabilitation: Medical care, psychological support, or vocational training if needed.
• Satisfaction: Formal apology; acknowledgement of harm; non-repetition guarantee.
• Systemic correction: Policy or procedure change; supplier capacity building; DD practice review.
• Monitoring: 6–12 month monitoring period to verify no recurrence.
• Timeline: Immediate action within 72 hours; full remediation within 60 days.
•  Cost: Jointly borne by DD and supplier if the supplier contributed.
• Evaluation: Mid-term review at 6 months; final evaluation at 12 months (DD-HR-33-001, Section 4.2).

Level 3: High-Severity Remediation

Severe, widespread, or irreversible harm; systemic failure; potential criminal conduct.

• Immediate action: Cease all harmful activity immediately; protect victims; secure evidence.
• Emergency response: Medical evacuation, emergency shelter, police protection if needed.
• Independent investigation: External expert leads investigation; potential regulatory/police referral.
• Victim support: Comprehensive medical, psychological, and legal support; safe housing if needed.
• Comprehensive compensation: Full compensation for all losses, suffering, and future impacts; livelihood restoration.
• Community remediation: Where communities are affected, a community-led restoration plan.
•  Structural reform: Fundamental changes to DD policies, procurement practices, project design, or governance.
• Accountability: Disciplinary action up to termination for responsible staff; contract termination for responsible suppliers; legal action if criminal.
• Independent monitoring: External monitoring of remediation for 12–24 months.
• Transparency: DD will assess whether public disclosure is appropriate, taking into account the interests and safety of affected persons, confidentiality obligations, legal requirements, the risk of identification, and the potential value of transparency. Where disclosure is appropriate, information will be anonymised and limited to the facts, impacts, remediation actions and systemic improvements necessary to demonstrate accountability.
•  
• Timeline: Emergency response within 24 hours; investigation within 30 days; remediation plan within 60 days; implementation ongoing.
• Cost: Borne by DD; recovered from supplier through contract terms if applicable.
•  Evaluation: Quarterly independent review for 24 months; final sustainability verification at 24 months (DD-HR-33-001, Section 4.2).

4.4 Supplier-Linked Remediation

Suppliers and relevant contractors will be informed of DD’s grievance mechanism and expectations through supplier onboarding, contracts, procurement documentation and supplier communications. Where appropriate, supplier agreements will require cooperation with investigations, protection against retaliation, participation in remediation and provision of information necessary to assess and address human rights impacts.

5. PROTECTION AGAINST RETALIATION

5.1 Zero-Tolerance Policy

DD has a strict, zero-tolerance policy against retaliation. Any adverse action taken against a person for raising a grievance in good faith, participating in an investigation, or supporting another’s grievance is prohibited and constitutes a serious disciplinary offense.

5.2 Protection Measures

Confidentiality: Complainant identity protected to maximum extent; anonymous reporting permitted; access to Grievance Register restricted to HR Lead, CEO, and Legal Counsel.

Alternative arrangements: Transfer to different projects, team, or location if requested and feasible.

Legal support: Access to legal counsel for complainants in serious cases (Category 2-3).

Psychological support: Counseling services for complainants and witnesses.

Whistleblower protection: Independent ombudsman for cases involving senior management; Board-level channel available.

Disciplinary action: Any staff member found to have retaliated faces termination and potential legal action.

5.3 Reporting Retaliation

If a person experiences retaliation, they may report it through any grievance channel. Retaliation grievances are automatically treated as Category 2 (Serious) and investigated by the HR Lead or Independent Ombudsman if the HR Lead is implicated.

6. GOVERNANCE AND OVERSIGHT

6.1 Roles and Responsibilities

Board of Directors: Receive quarterly summaries of all grievances; approve Level 3 remediation plans; oversee annual trend analysis; hold CEO accountable for mechanism effectiveness.

CEO (Dr. MaqC Eric Gitau): Receive immediate notification of Category 3 grievances; approve Category 2 remediation; ensure resources are available; review quarterly Board dashboard.

Human Rights Lead (Victor Kimanthi): Own and operate the grievance mechanism; maintain the Grievance Register; conduct investigations; develop remediation plans; lead evaluation and continuous improvement per DD-HR-33-001; report to the Board quarterly.

Legal Counsel: Advise on investigations; review remediation plans; manage regulatory/police referrals; ensure due process; review appeal decisions.

Project Leads: Receive and escalate on-site grievances within 24 hours; implement project-level remediation; ensure grievance channels are visible at project sites; collect complainant feedback.

HR / People Team: Handle employment-related grievances; support complainants; manage disciplinary processes; coordinate with HR Lead on investigations.

Communications: Manage external transparency; publish anonymised annual data; maintain grievance webpage; coordinate public disclosure for Level 3 cases where appropriate.

All Staff: Receive grievances with respect and urgency; never dismiss or discourage reporting; maintain confidentiality; complete annual grievance mechanism training.

6.2 Grievance Register

Grievance records will be collected, accessed, retained and disposed of in accordance with DD’s Data Protection and Privacy requirements and applicable Kenyan data protection law. Personal information will be limited to what is necessary for investigation, remediation, legal compliance and organisational learning. Where information is used for reporting or learning purposes, it will be anonymised or aggregated wherever practicable. The HR Lead maintains a secure Grievance Register tracking:

• Case ID: Unique identifier (DD-GR-YYYY-NNN)
• Date received: Receipt date and time
• Channel: How grievance was submitted
• Category: Labour, SEAH, community, data/privacy, procurement pressure, retaliation, etc.
• Severity: 1, 2, or 3
• Complainant: Name or anonymous ID
• Project/Supplier: Relevant project or supplier
• Description: Brief summary of allegation
• DD’s role: Caused, contributed, directly linked
• Investigation status: Pending, ongoing, completed
• Outcome: Substantiated, partially substantiated, unsubstantiated
•  Remediation status: Pending, in progress, completed
• Closure date: Date case closed
• Days to resolution: Total elapsed time
• Appeal: Yes/No; status if yes
• Lessons learned log ID: Cross-reference to DD-HR-33-001 register
• Evaluation outcome: Effectiveness rating per DD-HR-33-001 criteria

Access: Restricted to HR Lead, CEO & Legal Counsel. 

Data retained for 10 years for high-risk cases; 7 years for standard cases.

7. COMMUNICATION AND TRANSPARENCY

7.1 Internal Communication

• All staff trained on grievance mechanisms during onboarding and annually.
• Annual report to staff on mechanism effectiveness, trends, and improvements.

7.2 External Transparency

• Annual publication of anonymized grievance data on dd.africa (number received, categories, severity, outcomes, average resolution time).
• Annual Human Rights Performance Report includes grievance mechanism analysis and continuous improvement measures (B Corp HR 3.3 evidence).
•  Serious incidents (Category 3) disclosed publicly unless victim safety would be compromised.

7.3 Confidentiality Limits

Never disclose: Complainant identity without explicit written consent; details that could endanger victims or witnesses.

May disclose: General trends, systemic issues, and remediation outcomes in anonymized form; aggregate statistics for B Corp and stakeholder reporting.

Must disclose: To regulators or police where legally required; where serious criminal conduct is involved; where court order compels disclosure.

8. CONTINUOUS IMPROVEMENT (B CORP HR 3.3 ALIGNMENT)

This section explicitly operationalizes B Corp Standard HR 3.3 by embedding evaluation and learning into the grievance and remediation process.

8.1 Annual Review

Every 12 months, the HR Lead conducts a formal review of:

• Grievance data and trends (category, severity, geography, project, supplier)
• Investigation quality and timeliness (against KPIs in DD-HR-33-001)
• Remediation effectiveness (stakeholder satisfaction, recurrence rates, cost-efficiency)
• Stakeholder feedback (complainants, staff, suppliers, communities)
• Benchmarking against sector best practice and evolving B Lab standards
•  Comparison with Year 3 / Year 5 tracking data from client/project assessments 

8.2 Stakeholder Consultation

DD consults affected stakeholders (workers, communities, suppliers) on the design and effectiveness of this mechanism at least every 24 months, or after any significant incident (Category 3). Consultation results feed directly into the Adjustment Proposal process under DD-HR-33-001.

8.3 Integration with Response Evaluation Procedure 

This Protocol is not a standalone document. It operates within the broader evaluation framework established in DD-HR-33-001. Specifically:

• Every Remediation Plan (Section 4.3) includes evaluation criteria drawn from DD-HR-33-001, Section 3.1 (Relevance, Timeliness, Adequacy, Effectiveness, Sustainability, Stakeholder Satisfaction, Unintended Consequences, Cost-Efficiency).
• All grievance closures trigger a Lessons Learned Log entry (DD-HR-33-001, Annex C) within 30 days.
• Annual grievance data is incorporated into the Annual Human Rights Performance Report ( Annex D).
•  If evaluation reveals that a particular type of grievance is recurring, the HR Lead initiates the Adjustment Process (DD-HR-33-001, Section 6) to revise policies, training, or procurement practices.