Grievance Redress Mechanism (GRM)

Project Mercury Data Centre - Johor Bahru, Malaysia

This document sets out the project-level mechanism through which project-affected people, workers, neighbouring land users, contractors and other stakeholders may submit concerns or complaints relating to the development and operation of Project Mercury.

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1. Purpose

This Grievance Redress Mechanism (GRM) is established to provide a transparent, accessible and timely process for receiving, assessing, resolving and documenting grievances raised in relation to the development and operation of Project Mercury.
The mechanism is intended to meet the requirements of the Asian Infrastructure Investment Bank (AIIB) Environmental and Social Framework (ESF), notably ESS 1 on Environmental and Social Assessment and Management and, where relevant, ESS 2 on Involuntary Resettlement, while also reflecting good international industry practice and applicable Malaysian legal requirements.

The GRM is designed to:

• ensure concerns are addressed promptly, fairly and in a manner proportionate to their seriousness;

• strengthen stakeholder trust, transparency and two-way communication;

• identify recurring environmental and social issues and support corrective action;

• promote accountability, learning and continuous improvement in project management.

2. Scope

The GRM applies to environmental and social grievances arising from the project, including but not limited to:

• environmental impacts, including noise, emissions, waste, stormwater, resource use and nuisance;

• social impacts, including traffic disruption, community safety, security conduct and disturbance to neighbouring users;

• land access or use issues, where relevant;

• labour and working conditions, where channelled through the community GRM rather than the worker-specific mechanism;

• conduct of contractors, subcontractors and security providers;

• actual or perceived non-compliance with AIIB requirements or applicable Malaysian regulations.

The mechanism is open to local communities, nearby businesses, workers, civil society organisations and any other interested stakeholders who may be affected by or concerned about the project.

3. Principles

The GRM shall be operated in accordance with the following principles:

• Accessible - multiple entry points, free of charge, and available without discrimination.

• Transparent - procedures, timeframes and points of contact communicated publicly.

• Confidential - identity protected upon request and sensitive information handled appropriately.

• Non-retaliatory - no retaliation or disadvantage for submitting a grievance in good faith.

• Culturally appropriate - respectful of local context and communication preferences.

• Timely - defined service standards for acknowledgement, investigation and response.

• Fair and impartial - facts reviewed objectively and outcomes documented.

• Trackable - each grievance logged, assigned and monitored to closure.

4. Grievance Uptake Channels and Contact Details

Where a grievance is first received verbally, the project shall record it in writing and confirm the details with the complainant to the extent possible.

5. Overview of the Grievance Handling Process

The grievance process follows a structured eight-step sequence designed to ensure accountability, proportionality and timely close-out. A simple process flow is provided below, followed by the detailed procedural narrative in Section 6.

• Step 1: Receipt — Login

• Step 2:  Acknowledgement — Within 5 working days

• Step 3:  Screen — Type, Severity, Urgency

• Step 4:  Investigate — Facts and Evidence

• Step 5: Propose resolution — Within 15 or 30 working days

• Step 6:  Communicate — Explain findings and actions

• Step 7:  Implement and follow up — Track completion and seek feedback

• Step 8:  Close — Close when resolved and exhausted

6. Detailed Procedural Narrative

The GRM process shall be administered as follows.

7. Escalation and Appeals

Where a complainant is dissatisfied with the proposed outcome or where a grievance cannot be resolved at project level within the stated timeline, the matter may be escalated through the following channels:

• review by project senior management;

• use of an independent third-party mediator, where appropriate and acceptable;

• access to available Malaysian administrative, legal or judicial remedies;

• access to AIIB's Project-affected People's Mechanism (PPM), in accordance with AIIB's applicable procedures.

Use of the project GRM does not prevent access to judicial or administrative remedies and does not replace statutory rights.

8. Special Provisions for Workers

A separate and confidential Worker GRM shall be maintained for project workers, including contractor and subcontractor personnel. The worker mechanism shall:

• be available to all project workers, including contracted workers;

• permit anonymous reporting to the extent practicable;

• be managed independently from direct line supervisors where feasible;

• cover issues such as wages, working hours, occupational health and safety, accommodation, harassment, discrimination and disciplinary concerns;

• be communicated during induction and refresher training.

9. Roles and Responsibilities

10. Monitoring and Reporting

All grievances shall be tracked in a central register or database. The database should allow categorisation, status tracking, date-stamping and retention of supporting documents.

• number of grievances received by month and by category;

• number and percentage acknowledged within target timeframe;

• number and percentage resolved within target timeframe;

• average and median resolution time;

• number of open, overdue, escalated and repeat grievances;

• qualitative trends, systemic issues and lessons learned.

Internal reporting should be undertaken at least monthly, with external reporting to lenders such as AIIB undertaken where required by financing agreements or reporting commitments.

11. Disclosure and Awareness

To ensure accessibility, the project shall disclose the existence and operation of the GRM through suitable channels and in language that is readily understood by intended users.

• community meetings and stakeholder engagement activities;

• site signage and noticeboards;

• worker inductions and toolbox talks for worker-related channels;

• project and company web channels, where appropriate;

• written materials distributed in relevant locations.

12. Continuous Improvement, Record Keeping and Data Protection

The GRM shall be reviewed periodically to assess accessibility, timeliness, quality of response and user satisfaction. All GRM records shall be retained in a secure and organised manner, with access limited to authorised personnel. Records shall include, as applicable:

• grievance forms and intake notes;

• screening and investigation notes;

• correspondence with complainants and contractors;

• evidence of corrective actions and closure decisions;

• summary reports and trend analyses.

Periodic training shall be provided to project staff and contractors so that the mechanism remains effective, consistently applied and responsive to stakeholder feedback.