JDR Cable Systems Ltd. recognises that a formal grievance procedure can be stressful for all those involved. Stakeholders1 and their representatives are ideally placed to raise any issues with JDR and our Subcontractors2 and potentially solve a dispute informally as it is occurring. In our experience localised solutions tend to be most attuned to local culture, the concerns of those whose rights are impacted, and opportunities for sustainable solutions.
Should this not be possible then this policy allows for a more formal approach to be taken. We recognise external investigations of complaints by brand companies or multi-stakeholder initiatives are an important and necessary back-stop to individual site processes, but formal processes should be used if it is not possible to resolve a particular complaint informally.
Often the issues raised are complex. This means it takes time to investigate and check facts, and in some cases, there is no clear-cut right or wrong answers. In other instances, complaints cannot be addressed by JDR Cable Systems Ltd. in isolation, as they may require wider engagement with JDR Subcontractors and other Stakeholders, including third parties also operating locally.
What would constitute a complaint under the external stakeholder grievance policy?
A complaint is defined as any expression of dissatisfaction or grievance caused by JDR or any of JDR Subcontractors directly or indirectly by an external stakeholder individual or organisation in relation to the Project V Construction of the JDR Subsea HV Cable Facility in Cambois near Blyth.
The complaint should be evidence based. This means that the complainant should be able to provide sufficient information to demonstrate the relevance and seriousness of the complaint, and specifically how this relates to JDR or those acting on our behalf.
JDR and the JDR Main Construction Works subcontractor will jointly sign up to the Considerate Constructors Scheme (CCS).
The Scheme’s Code of Considerate Practice has three areas: Respect the Community, Care for the Environment and Value their Workforce. See Appendix A.
4.1 Stage 1 – Considerate Constructors Scheme Complaint
In the first instance when an External Stakeholder wants to raise a complaint they must follow the Considerate Constructors Scheme complaints procedure as outlined below and in https://www.ccscheme.org.uk/affected-by-work/complaints-procedure-monitor-affected-works/
1. All complaints received by the Scheme from any source, regarding a Registered Activity, are recorded.
2. When a complaint is raised with the Scheme that is relevant to the Code of Considerate Practice, a contact designated by the Registered Activity (usually a Site Manager or Company contact) will be informed of the nature of the concern and (only with permission from the complainant) the name and contact details of the complainant. Areas for consideration in addressing the complaint might also be offered to the designated contact regarding factors to consider when dealing with the complaint.
3. Where the complainant has not granted permission for their contact details to be given, the Scheme will liaise with the designated contact on their behalf.
4. The Scheme will stay in contact with the complainant until the Registered Activity has investigated and responded to the complaint either addressing the complaint to the complainants satisfaction, or the Scheme feels reasonable efforts have been made by the Registered Activity to address the complaint, at which point the complaint will be closed.
5. The Registered Activity must promptly act on any third party complaint received through the Scheme, taking appropriate remedial action including, issuing an acknowledgement to the complainant within 24 hours and aiming to conclude within ten working days to our satisfaction and in accordance with this complaints procedure.
6. If the designated contact does not deal with a complaint in a satisfactory manner, the complaint will be referred to the construction company’s head office contact (as provided at registration). Complaints not addressed satisfactorily will be elevated to the Registered Activity’s Company Director level.
7. The Scheme may attempt to mediate between the parties during this process. If, at any time, the Scheme considers that a reasonable agreement has been reached, the complaint will be closed.
8. Where necessary, and at the discretion of the Scheme, an experienced Scheme Monitor may visit the complainant and designated contact to seek further information.
9. If the Registered Activity fails to deal with a problem in an effective manner the Scheme’s Chief Executive may suspend, or in extreme circumstances terminate, the registration with the Scheme.
10. Where a decision to terminate a Registered Activity’s registration with Scheme is made, the Registered Activity, client and complainant will be informed of the termination.
11. If the complaint does not relate to an issue covered by the Scheme’s Code of Considerate Practice (for example, the Scheme cannot get involved with planning issues or in decisions relating to compensation) the complainant will be signposted in an appropriate direction.
To raise a complaint about a activity registered with the Scheme, you can email us at publicsupport@ccscheme.org.uk or call 0800 783 1423.
4.2 STAGE 2 – ESCALATION
It is hoped that all complaints can be dealt with using the CCS Complaints Procedure however, if in the event that this is still not met with a satisfactory outcome the External Stakeholder can escalate the complaint directly with JDR Cable Systems Ltd by the following approach.
1. Contact JDR Cable Systems Ltd.’s Compliance Officer by email, or in writing
Email address: jdrcompliance.officer@jdrcables.com
Postal address: Compliance Officer
JDR Cable Systems Ltd.
177 Wisbech Road
Littleport
Cambridgeshire
CB6 1RA
United Kingdom
The CCS Complaints procedure must be followed through to completion before escalation to Stage 2 otherwise it will revert back to stage it is currently at within the CCS Complaints procedure.
The complaint can be submitted in the individual’s or organisation’s own language. We endeavour to acknowledge receipt of all emails received into this mailbox within two (2) working weeks, or five (5) working weeks if in a language other than English.
4.2.1 Investigating and Understanding Complaints
Once a stage 2 complaint has been reported and confirmed the CCS Complaints procedure has concluded, a unique case number is generated which allows for confidential dialogue to take place between the parties (e.g. should there be any further questions to ask). This includes situations where the party wishes to remain anonymous. It also enables feedback to be provided (e.g. progress status).
All stage 2 complaints raised are reviewed by JDR Cable Systems Ltd.’s Compliance Officer who will assign the case to a Designated Investigation Officer (DIO) who will first review the outcome of the CCS Complaints procedure.
Our goal will always be to assess and then investigate all legitimate complaints and promote their resolution in the quickest possible timeframe. The complaint will be considered to have been resolved at an initial stage if and when the parties agree on a plan for remedial action to address the issue. Complaints vary in scale, complexity and geographical origin so it is not possible to say how long it will take to reach a resolution.
We will, however, always strive to keep all parties regularly informed (in their local language) on the steps that are being taken and the results of the process.
Stage 2 Escalation Complaint Framework
We use a generic framework which is applied depending on the nature of the issue and local circumstances.
The below details our standard process steps.
Within our Complaint Framework, our primary concern will always be to safeguard the rights and wellbeing of any person who has raised the complaint. Everyone is entitled to be treated with respect, JDR Cable Systems Ltd and our Subcontractors will not tolerate abusive or insulting behaviour from anyone. Intimidation or harassment of witnesses will not be tolerated.
Retaliation can take many forms:
• Loss of employment
• Demotion
• Involuntary transfer
• Harassment
• Intimidation, etc.
If a person or organisation believes that they have been subject of retaliation because of registering a complaint with JDR Cable Systems Ltd, then through the CCS Complaints procedure or directly, they should contact us immediately and provide the specific details of what has occurred. We will investigate and if there is clear evidence of retaliation against them, we will take action to remedy the situation.
APPENDIX A – CCS – Code of Considerate Practice
1 The term ‘Stakeholder’ is defined in this procedure as any individuals, groups or organisations directly involved with, or indirectly affected by the Project V Construction of the JDR Subsea HV Cable Facility. This includes but is not limited to: Local residents, members of the public at large, statutory parties, landlord, local council and government.
2 The term ‘JDR Subcontractor’ is defined in this procedure as any company which is under direct contract by JDR and/or any company which is under direct contract of the JDR Main Construction Works Subcontractor in relation to the Project V project.