Ukraine

The Ministry for Development of Economy, Trade and Agriculture of Ukraine
The National Agency of Ukraine for Civil Service

Strengthening Public Resource Management Project. Phase 2 

International Bank for Reconstruction and Development
EU Public Finance Management Support Programme for Ukraine (EU4PFM)

Stakeholder Engagement Plan (SEP)

Kyiv, April 2021

TABLE OF CONTENTS
Acronyms and Abbreviations
1.	Introduction/Project Description
1.1	Introduction
1.2	Project Description
2.	Purpose and Objective of the Stakeholder Engagement Plan
3.	Regulatory Context
3.1	National Legislation
3.2	World Bank Requirements
4.	Brief Summary of Previous Stakeholder Engagement Activities
5.	Stakeholder Identification and Analysis
Table 1: Role, Interest, and Influence of Stakeholders
Table 2: Stakeholders Involved in Each Component
6.	Stakeholder Engagement Program
i)	Purpose and Timing of Stakeholder Engagement Program
ii)	Proposed Strategy for Information Disclosure
iii)	Proposed strategy for consultation
iv)	Proposed strategy to incorporate the view of vulnerable groups
v)	Timelines
vi)	Review of Comments
vii)	Future Phases of Project
7.	Resources and Responsibilities for implementing stakeholder engagement activities
8.	Grievance Mechanism
9.	Monitoring and Reporting
Appendix A. Complaints Procedure and Grievance Form
Public Grievance Form

Acronyms and Abbreviations

CMU                  Cabinet of Ministers of Ukraine
EC                       European Commission
ESF                     Environmental and Social Framework
ESS                     Environmental and Social Standard
EU                      European Union
GRM		Grievance Redress Mechanism 
HR                     Human Resource
HRMIS		Human Resource and Payroll Management Information System
HQ                   	Head Quarters
IFI                      International Financial Institution
MEDTA	Ministry for Development of Economy, Trade and Agriculture of Ukraine 
MoF                  Ministry of Finance
NACS 		National Agency of Ukraine for Civil Service
NGO		Non-governmental organization
PAR                   Public Administration Reform
PIM		Public investment management
PIU		Project implementation unit
SEP		Stakeholder Engagement Plan
SES                    Stakeholder engagement specialist
SOE		State-owned enterprise
SPFU                 State Property Fund of Ukraine
WB                    World Bank

1.	Introduction/Project Description

1.1	Introduction 
The Government of Ukraine implements a wide-scale reform agenda which is supported, including financially, by international development partners. The European Commission (EC) and the World Bank greatly support Ukraine in implementing most of key reforms in fiscal sphere, anti-corruption, health, energy, land markets, public sector and institutional reforms.

The EC in partnership with the WB provides continuous support for Public Administration Reform and Public Finance Management Reform aiming to improve efficiency and better management of public resources. The first EC and Bank-funded project focusing on PAR and PFM reforms “Strengthening Public Resource Management Project” was implemented during 2017-2021. Now, the Government of Ukraine will implement the Strengthening Public Resource Management Project. Phase 2 (the Project) with the involvement of the Ministry for Development of Economy, Trade and Agriculture of Ukraine (MEDTA) and the National Agency of Ukraine for Civil Service (NACS). 

As the Project will be implemented within the Bank’s Grant it shall follow the Bank rules and procedures, including in part of Environmental and Social Standards (ESSs). To this end, the Environmental and Social Commitment Plan (ESCP) and Stakeholder Engagement Plan (SEP) are being prepared.

This document represents the SEP that may be revised during the Project implementation to reflect adaptive management of Project changes and unforeseen circumstances. 
1.2	Project Description
The Project “Strengthening Public Resource Management Project. Phase 2” administered by the World Bank is a part of hybrid Trust Fund within the EU Public Finance Management Support Programme for Ukraine (EU4PFM) Component 2 Activities financed by the European Union. This EU-funded TF includes both WB and Recipient-executed (RE) activities aiming at supporting Ukraine in better management of public resources. The RE-activities will be implemented under € 3,8 mln. World Bank Grant from about May 2021 through May 2023. 
Project Objectives is to support to the Government of Ukraine to better manage public resources through i) launching of a country-wide Human Resource Management Information System (HRMIS); ii) reassessing and improving the efficiency of the Public Investment Management (PIM) system, iii) improving the governance of state-owned enterprises (SOEs).
Project actions aimed at country-wide roll out of HRMIS will be executed by the National Civil Service of Ukraine (NACS) – project implementing agency – under the Project’s Component 1 “Country-wide Launch of HRMIS”. 
Project actions aimed at improving PIM and governance of SOEs will be implemented by the Ministry for Development of Economy, Trade and Agriculture of Ukraine (MEDTA) within the Project Component 2 “Enhancing Public Investment Management” and Component 3 “Better Governance and Oversight of SOEs”.  
The Project outcome-level results include:
•	Improved transparency and efficiency in human resource and payroll management in the civil service of Ukraine;
•	Improved preparation, appraisal, selection, implementation, monitoring and evaluation ex-post of public investments in line with strategic policy priorities of the Government;
•	Increased transparency, accountability and fiscal discipline among SOEs.

The Project will be organized around three components as described below. The Project activities will include development and implementation of IT systems, as well as development methodological documents and staff training. The Project will not cover any activities including civil works that might create some direct environmental and social impacts, as well as no activities that would lead to further investment operations that might directly or indirectly cause such risks and/or impacts.
Component 1. Country-wide Launch of HRMIS
The objective of the Component is to roll-out the HRMIS in the civil service of Ukraine at the national and subnational levels. The HRMIS is implemented in line with the Government’s Public Administration Reform Strategy up till 2021 and HRMIS Implementation Concept as of December 2017 as amended. The HRMIS is implemented in two Phases following incremental functional and institutional coverage enlargement. The Phase 1 covered the design and development of core HRMIS functionalities and system implementation in the first group of 21 institutions, including 16 ministries and up to 40,000 end-users. The Phase 1 implemented under the World Bank Grant within the EU Program for the Reform of Public Administration and Finances (EURoPAF) is completed on March 31, 2021. 
This Project will support the Phase 2 of the HRMIS implementation and entails: i) the functional enlargement of the System with performance appraisal, development of professional competences, and analysis and reporting modules as well as functionalities which were not included in the Phase I but required by the Government authorities; ii) System`s country-wide roll out in the remaining central agencies and decentralized administration, iii) end-user training and change management; iv) improving the policy and methodological framework for HRMIS implementation; v) carrying out annual technological upgrades and HRMIS adaptive and evolution changes, and upgrade of the HRMIS infrastructure. 

The HRMIS’s roll out to the national and subnational levels of the civil service of Ukraine will be made by phases: Phase 2a will include HRMIS implementation in public institutions with 100% coverage of the staff; and Phase 2b will include HRMIS implementation in public institutions and entities with the mixed staffing. It will be subject to the Project Steering Committee decision based on the results of the Bank’ study on potential enlargement of HRMIS coverage beyond the civil service to be conducted at the beginning of Phase 2.
Component 2. Enhancing the Public Investment Management System  
This Component will support the (i) establishment of a comprehensive database of the public investment portfolio and automation of the public investment decision making and management process; (ii) capacity building of participating stakeholders for better management of public investment projects, their coordination and monitoring; and (iii) strengthening of MEDTA capacities to coordinate and monitor public investments and support the change management process.
The automation of PIM processes will include (a) carrying out analysis of automation options for PIM based on benchmarking against good international practices; (b) developing functional requirements for the PIM automation solution, its procurement and installation, and (c) training of users.
The activities aiming at capacity building of public officials in PIM will include developing guidelines for project implementation management and training strategy, and curriculum aimed at skills development for selection, appraisal, and implementation of public investment projects. The MEDTA will conduct trainings for all line ministries and agencies on curriculum developed. It is expected that upon successful completion of each training module civil servants will be issued a training certificate. The MEDTA will decide on an option (a platform) to ensure web-based accessibility of the training modules and certificates. This will ensure a long-run sustainability and expand the training modules availability to the broader list of public entities, including local level authorities. If procurement of such a platform will be needed, it will be done based on the World Bank rules and under the Bank supervision.
The strengthening of MEDTA capacities to coordinate and monitor public investments will include functional review of the MEDTA’s Investment Department to identify existing (as-is) business processes and necessary (to-be) functions and business processes. The report, summarizing the business process analysis will also provide recommendations on the staffing level, types of required competences, institutional and procedural changes to ensure high quality and timely services. This will inform the relevant legal and regulatory documents. Study visits will be organized for the MEDTA, Ministry of Finance and some other stakeholders’ representatives to learn good international practices. 
Component 3. Better Governance and Oversight of SOEs
The Component will support the streamlining and aggregation of SOEs financial data for performance assessment and improved risk analysis.   This will enable automation and aggregation of SOEs financial data, focusing on TOP-100 enterprises, at single platform with the MEDTA’s SOE Monitoring and Reform Support Unit. The activity will support ongoing efforts of the MEDTA in digitalization and aggregate analysis of financial data submitted by individual SOEs, allowing for faster fact finding, performance monitoring and risk assessment. MEDTA will work to embed an existing off-the-shelf online business intelligence (BI) platform compatible with the existing software used by all entities in Ukraine, including largest SOEs, to submit their financial statements to the Statistical Committee. The review of key financial performance indicators and developing dashboard for SOE performance assessment will include developing a methodology and tools for reviewing SOEs’ audited financial statements; and designing a dashboard to analyze SOE financial performance, analysis of International Financial Reporting Standards (IFRS), training of staff in the use of such dashboard, guidelines and methodology.
2.	Purpose and Objective of the Stakeholder Engagement Plan
The purpose of the SEP is to ensure appropriate stakeholder consultation and information disclosure in the context of Ukraine. The goal of the SEP is to help decision-making and facilitate project implementation by involving beneficiaries and other stakeholders in a way that gives these groups the opportunity to provide feedback and express their views on intended project outcomes, benefits and potential adverse consequences. The SEP is a useful tool to manage communication between the project and its stakeholders.
The main objectives of the SEP are the following: 
•	To understand the stakeholder engagement requirements of the Ukrainian legislation; 
•	To identify key stakeholders that are affected, and/or able to influence the Project and its activities; 
•	To develop a stakeholder’s engagement process that gives stakeholders the opportunity to participate and influence project design and implementation;
•	To define the information disclosure provisions under the project;
•	To establish a formal Grievance Redress Mechanism under the project;
•	To define roles and responsibilities for the implementation of the SEP; 
•	To define the monitoring arrangements to ensure that the SEP remains an effective and up-to-date tool for stakeholder engagement. 

3.	Regulatory Context
3.1	National Legislation 
The Law of Ukraine "On Access to Public Information" № 2939-VI dated January 13, 2011, as amended, regulates the rights and obligations of State authorities on the provision of information to the public regarding transparency of their activities performed.
The Law of Ukraine "On Citizens' Appeals" № 393/96-ВР dated October 02, 1996, as amended, stipulates that State and local governmental bodies, as well as their officials, heads, and officials of enterprises, institutions, organizations regardless of their form of ownership and citizens' associations whose authority includes consideration of applications (petitions) are obliged to consider them objectively and on time, verify the facts set out therein, take decisions in line with current legislation and ensure their enforcement, and inform citizens on the results of their (petitions) consideration.
The procedure for promotion public expertise of the executive authorities’ activities (Resolution of the Cabinet of Ministers of Ukraine № 976, 2008, as amended). It regulates the duties of public expertise bodies at the request of public organizations, other associations, public organizations, trade unions, employers and representatives of local administrative bodies.
The CMU Resolution “On Ensuring Public Participation in Formation and Implementation of State Policy” (№ 996, dated November 3, 2010, as amended) adopts procedure for public consultations on state policy formation and implementation as well as standard regulation on public councils under ministries, contract executive bodies, Oblast and Rayon State Administrations. 
The Aarhus Convention was adopted to promote the protection of the human right of present and future generations to live in an environment favourable to their health and wellbeing, and each Party guarantees the rights of access to information, on public participation in decision-making and access to justice in environmental matters, following the provisions of the aforementioned Convention.
CMU Resolution “Some Issues of Public Investment Management” № 571 dated 22.07.2015. Request for experts to provide research on procedure and feasibility study regarding preparation, analyzing public investment projects and prepare recommendations in regards of these (with actual experience of investment project development).
(Resolution № 571 provides detailed guidelines on how to prepare the public investment project, its structure but it should be revised for real-time projects and today’s business needs. That is why to revise the current resolution in event of an accurate and detailed amendment would assist in quality draft and preparation of the public investment project. It helps well-prepare projects which will be the foundation for the correct decision regarding the financing of the project from the state budget and use in more cost-effective way. 
Investment activity regulation. Request on Revision the Law of Ukraine “On Investment Activity”. Conduction of the report with detailed analysis on the Law of Ukraine “On Investment Activity” № 1560-XII adopted on 18.09.1991, last amendments was conducted on 20.10.2019. However, the many changes that have been made its current version could requires adjustment. Paying attention to flaws in current legislation and identify requirement for its changes. 
3.2	World Bank Requirements
The World Bank has a long history of multi-stakeholder engagement and strategies to promote effective project preparation, project implementation and project monitoring, which entails empowering citizens to participate in the development process and integrating citizen voice in development programs as key enablers to achieving results.
In August 2016, the World Bank’s Board of Executive Directors approved the Environmental and Social Framework (ESF), which went into effect in 2018 and progressively replaced the Bank’s Safeguards. The ESF protects people and the environment from potential adverse impacts that could arise from Bank-financed projects and promotes sustainable development. Within the ESF, ten Environmental and Social Standards highlighted responsibilities for Borrowers. The Standards are designed to help Borrowers manage project risks and impacts as well as improve environmental and social performance, consistent with good international practice and national and international obligations. 
The Environmental and Social Standard on Stakeholder Engagement and Information Disclosure (ESS 10) defines the requirements for stakeholder engagement which are the following: 
•	Establish a systematic approach to stakeholder engagement that helps Borrowers identify stakeholders and maintain a constructive relationship with them; 
•	Assess stakeholder interest and support for the project and enable stakeholders’ views to be taken into account in project design;
•	Promote and provide means for effective and inclusive engagement with project-affected parties throughout the project life-cycle; 
•	Ensure that appropriate project information is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner. 
4.	Brief Summary of Previous Stakeholder Engagement Activities 
The NACS has been conducting communication and stakeholder’s engagement activities regarding the design, requirements, and needed improvements to the HRMIS starting from the launch of HRMIS development.  Two-phased approach for HRMIS implementation was discussed and agreed with the EU Delegation and the WB and finally approved by the Cabinet of Ministers of Ukraine. Functional requirements of the HRMIS were coordinated within working groups, consisting of the HR- and Payroll specialties of the target governmental authorities. The NACS’s is in regular communication with the Secretariat of the CMU on i) the current status of HRMIS implementation and its roll-out plans during Phase 2 and ii) HRMIS -related targets for new PAR Strategy. The series of educational videos on HRMIS was created and published at Facebook for communication of the importance of HRMIS for different stakeholders. Updates on HRMIS progress are placed on the NACS’ web-site and social media pages HRMIS public portal reflecting basic key analytics generated by the system is open for proposals regarding its coverage enlargement during the Phase 2 and NACS started relevant consultations with some stakeholders.

The World Bank team advised the MEDTA also to create and maintain a project related section on its official web-site with project materials to be open to public review.  
5.	Stakeholder Identification and Analysis
There are several groups of people and social groups who are interested in the Project on different levels. For this Project, these may be identified as following: 
-	People, social groups and organizations who will directly or indirectly be affected by the project: This groups mainly includes employees which are covered by the Civil service law in central and regional governmental authorities; officials responsible for PIM; staff responsible for governance and oversight of SOEs;
•	People, social groups and organizations who may have a possibility to influence and make decisions on implementation of the project and/or may have an interest in the Project. This group mainly includes governmental entities such as the government, IFIs, donors, NGOs etc. 

The main groups of stakeholders identified so far by Project Components are listed below. The list can be updated and modified during the Project development and implementation:

For the Component 1 the stakeholders can be grouped by the structures:
1.	All Ministries to be covered by HRMIS (HQ and Territorial branches)
2.	Executive governmental bodies to be covered by HRMIS (HQ and Territorial branches)
3.	Regional state administrations to be covered by HRMIS 
The target stakeholders are:
1.	Civil servants and any employee covered by Law on Civil service
2.	HR- and Payroll specialists of each governmental body 
3.	Management of the governmental bodies (Decision makers)
4.	HR- and Payroll specialists responsible for planning and forecasting at country level
(incl. at least MoF and NACS) 
5.	High level of country management (at least Cabinet of Ministers of Ukraine)
6.	International partners (International financial institutions/IFIs, Donors)
7.	Publics (national and international)
8.	Sectorial NGOs, Think Tanks
9.	Technical specialists of the governmental bodies

For the Component 2 the stakeholders can be grouped by the structures:
1.	Central level Ministries: MEDTA and MoF
2.	Central and local executive authorities, other public authorities 
3.	Public enterprises, institutions and organizations related to submission of the Public Investment Projects and also PIM selection committee 
The target stakeholders are: 
1.	Employees (management) of the governmental bodies 
2.	Responsible specialists in the Governmental institutions
3.	High level of country management (Cabinet of Ministers and PIM selection committee)
4.	International partners (IFIs, Donors)
5.	Organization and companies (national and international)

For the Component 3 the stakeholders can be grouped by the structures:
1.	Central level Ministries: MEDTA and MoF 
2.	State Property Fund of Ukraine
The target stakeholders are: 
1.	High level of country management (including Cabinet of Ministers)
2.	International partners (IFIs, Donors)
3.	General public 
4.	NGOs, Think Tanks, Academia
5.	Technical specialists of the governmental bodies

Vulnerable and disadvantaged groups: 
•	HRMIS users with disabilities that prevent using the computer systems;
•	Officials including elderly with lack of computer literacy working in governmental bodies; Group of people with low income which have no access to the internet services/providers;
People with limitations to internet access (e.g. villagers living in the rural with limited access to the internet). 

Table below summarizes the potential role, interests and influence for each of the above-mentioned stakeholders.

Table 1: Role, Interest, and Influence of Stakeholders
Stakeholder	Potential Role of Stakeholder	Interest	Influence	
Component 1. Country-wide Launch of the HRMIS	
Civil servants and employees covered by Law on Civil Service	Main beneficiaries of HRMIS	High	Medium	
HR- and Payroll specialists of governmental body 	Provide requirements for HR and Payroll in respect of specific business processes in each body to be covered by HRMIS and system users	High	High	
Technical specialist and support team 	Ensure stable HRMIS operation, support in HRMIS implementation
Support of vulnerable groups in use of HRMIS	Medium	Medium	
Management of the governmental bodies and regional administration	Responsible for HRMIS implementation; provide requirements for data required for management decisions; use HRMIS data for management purposes 	High	Medium	
HR- and Payroll specialists responsible for planning and forecasting at country level (incl. at least MoF and NACS)	Provide requirements for data required for planning and control at highest level	High	Medium	
High level of country management (at least Cabinet of Ministers of Ukraine)	Possess key coordinating authority for HRMIS implementation across the governmental bodies;
Use data for policy making and management purposes;
Provide requirements for reports required for management decisions at highest level	High	High	
EU and other international partners (IFIs, multilateral and bilateral donors)	Monitor the HRMIS implementation; 
Provide investments in similar areas and need to coordinate to avoid overlap and maximize impact	High	Medium	
Public (national and international), including disadvantaged & vulnerable groups	Benefit from accesses to open information that facilitate civil society development, monitoring and control civil service performance	High	Low	
Sectorial NGOs, Think Tanks 	Provide additional policy advice and input on civil service improvement and receive information for research and study	Medium	Low	
Component 2. Enhancing the Public Investment Management System	
Employees (management) of the governmental bodies	Provide requirements for data required for management decisions and implementation	High	Medium	
Responsible Specialists in the Governmental institutions 	Provide requirements for data required for planning and control at highest level	High	High	
High level of country management (Cabinet of Ministers)	Provide requirements for reports required for management decisions at highest level, legislation amendments	High	High	
International partners (International financial institutions, donors)	Provide investments in similar areas and need to coordinate to avoid overlap and maximize impact	High	Medium	
Organizations and companies (national and international)	Requirements for PIM process and advice to simplify the PIM process. Provide investments and requirements for data required	High	Medium	
Component 3. Better Governance and Oversight of SOEs	
Central level Ministries and Agencies: MOF, MEDTA, State Property Fund	SOE oversight policy development and implementation 
Provide comprehensive and timely SOE data	High	High	
NGOs, Think Tanks, Academia	Advice on SOEs reform and improvement of SOEs oversight and management
Provide comprehensive and timely SOE data	High	Low	
IFIs	Advice on SOEs reform and improvement of SOEs oversight and management, coordination with other IFIs related activities
Provide comprehensive and timely SOE data	High	Low	

The table below summarizes the stakeholders involved in each project component and sub-component for ease of reference.
Table 2: Stakeholders Involved in Each Component

Project Component	Target Stakeholders	Area of interest by target stakeholders	Other Interested parties	
Component 1. Country-wide Launch of the HRMIS	
HRMIS: Development of the additional functional modules	HR- and Payroll specialists of each governmental body;
Management of the governmental body;
HR- and Payroll specialists responsible for planning and forecasting at country level (incl. at least MoF and NACS);
High level of country management (at least Cabinet of Ministers);
International partners (International financial institutions, Donors)	Access to public data, which can be obtained from the HRMIS 

	Sectorial NGOs, Think Tanks
Publics (national and international), including disadvantaged & vulnerable groups
HR- and Payroll specialists of each body;
Civil servants and any employee covered by Law on Civil service.

	
HRMIS: Implementation	Civil servants and any employee covered by Law on Civil service. 
HR- and Payroll specialists of each body (internal).

High-level country management.
International partners

	Application of the self-service Cabinet and day-to day use of the HRMIS

Implementation of the HRMIS according to time and planned size 

Data for policy development and decision making	Management of the governmental bodies;
HR- and Payroll specialists responsible for planning and forecasting at country level (incl. at least MoF and NACS);
High level of country management (at least Cabinet of Ministers);
International partners (IFIs, Donors);
Sectorial NGOs, Think Tanks;
Disadvantaged & vulnerable groups;
Publics (national and international).	
Component 2. Enhancing the Public Investment Management System  	
Development and implementation of PIM automation solution and installation.	Central level Ministries: MEDTA and MoF

Central and local executive authorities, other public authorities

Public enterprises, institutions and organizations related to submission of the Public Investment Projects and also PIM selection committee
	Access to developed software and tested to be used by the main parties of the investment process

Developed training modules 	Employees (management) of the governmental bodies 

Responsible Specialists in the Governmental institutions

High level of country management (Cabinet of Ministers and
PIM selection committee)

International partners (IFIs, Donors)	
Strengthening the MEDTA capacity to coordinate and monitor public investments.	MEDTA	Developed legal amendments and implemented

Web-based version of the training modules is introduced	Employees (management) of the governmental bodies 

Responsible Specialists in the Governmental institutions

High level of country management (Cabinet of Ministers)	
Component 3. Better Governance and Oversight of SOEs	
Digitalization and aggregate analysis of SOEs, including financial data submitted by individual SOEs, allowing for faster fact finding, performance monitoring and risk assessment.	MEDTA, MOF, State Property Fund, Cabinet of Ministers	Access to comprehensive and up to date SOE information 	NGOs, General Public, including disadvantaged & vulnerable groups, Academia, IFIs	

6.	Stakeholder Engagement Program

i)	Purpose and Timing of Stakeholder Engagement Program
Decisions on meetings, locations have not been yet made. The NACS and MEDTA will clarify detailed stakeholder engagement plan and communicate it to all stakeholders via inter alia existing administrative communication channels. 

Target selection	Stakeholder Engagement Actions	Expected discussions/
decisions	Timing	Communication methods	
				Round tables / Meetings	Individual meetings	Letters	Document disclosure	Inform. campaign	
All	Agreement on / Disclosure of the SEP	Stakeholders have been consulted and informed on the SEP and GRM process	May 2021						
All	Update of SEP		Semi-annually						
HR-, Payroll, planning and monitoring specialists of all governmental bodies;
high level of country management;
international partners. 
Technical specialists of the governmental bodies	Discussion and coordination of the requirements for the new reporting and appraisal functionalities of HRMIS
 	Agreement on criteria for data.
Agreement on requirements of the terms of reference (blueprints).
Agreement on implementation timetable.
	April - July 2021	yes	yes	yes	yes		
High level of country management.
International partners	Agreement and approval of HRMIS implementation time plan and strict control of adherence with that plan 
	Implementation plan as a resolution of the government.
Effective meetings of the Steering committee.
Control over the project implementation and resolving the critical for implementation issues 	April - July 2021	yes	yes	yes	yes		
HR-, Payroll, planning and monitoring specialists of all governmental bodies, decision makers, 
international partners,
technical specialists	Defining the optimal decision on HRMIS implementation time plan and strict adherence with that plan 
	Agreement on technical solution of interoperability issues between ministries	April - July 2021	yes	yes	yes	yes		
Civil servants and employee covered by Law on Civil service.
Publics (national and international).
Sectorial NGOs, Think Tanks	Awareness raising of the stakeholder’s needs and comfortability of HRMIS use	-	Quarterly	yes	yes	yes	yes	yes	
Government, Public, including vulnerable and disadvantage group, International Partners	HRMIS Implementation and use	Discussion on HRMIS progress, benefits, and implementation corrections required	Semi-annually 	yes			yes	yes	
MEDTA, governmental institutions, PIM Committee, Sectoral NGO	Automation of PIM processes	Seek input on the functionalities of PIM automated solution	Ad-hoc	yes		yes	yes		
Relevant officials of MEDTA, consultants and other government institutions	Discussions on analytical or methodological outputs and good international practices	Analysis of public investment project management processes based on the legislative framework in PIM system	Ad-hoc	yes	yes	yes	yes		
MEDTA, government institutions, public companies	Capacity building in PIM	Presentation of Guidelines and Training Curriculum for Public Investment Project Management 	Ad-hoc	yes			yes		
MEDTA, MoF, SPF, SOEs	Automation of SOE financial data performance 	Seek advice /input on functional requirements to BI solution 	Ad-hoc	yes	yes		yes		
MEDTA, MoF, SPF, SOEs, government institutions who manage SOEs; NGO, 	Review of SOE key performance indicators	Presentation and discussion of methodology for SOE financial reports review	Ad-hoc	yes			yes		
MEDTA, NACS, International partners (Project donors)	Implementation progress 	Discussion on progress, results achieved, and actions needed	Semi-annually Ad-hoc		yes	yes	yes		
All	Informing on Implementation of SEP	Report on the progress and outcome indicators of the project	Semi-annually	yes			yes		
All	Informing of the GRM	Stakeholders have been consulted and informed on the SEP and GRM process	Semi-annually	yes			yes		

ii)	Proposed Strategy for Information Disclosure
The detailed description of the formats, methods how the information will be communicated to each of stakeholder group will be defined during the inception phase of the project. The table below reflects the draft approach for information disclosure
The means of communication will include but not limited:
•	Newspapers, posters, radio, television.
•	Website, social media.
•	Personal meeting.
•	Information centers and exhibitions or other visual displays.
•	Brochures, leaflets, posters, nontechnical summary documents and reports.
•	Official correspondence, meetings, conferences, special events.

Project component	List/Type of information to be disclosed	Methods of disclosure proposed	Timing / Frequency	Target stakeholders	Responsible stakeholders	
All	Proposed Project Design; 	Email, Web – site, Social media	Before project effectiveness	All	NACS
MEDTA	
All	ESMF documentation that is required for disclosure by the WB, including Stakeholder Engagement Plan, GRM description 
	Email, Web – site, Social media	Before project effectiveness	All	NACS
MEDTA	
Component 1. Country-wide Launch of the HRMIS	
HRMIS: Development of the additional functional modules	Set of criteria for development of the Terms of reference (ToR); draft ToR

Proposed requirements for HRMIS additional functionalities
	Periodic meetings of the working groups, round tables, emails

Round tables
	Weekly

Once developed	HR- and Payroll specialists of each body (internal)
Management of the governmental body
HR- and Payroll specialists responsible for planning and forecasting at country level (incl. at least MinFin and NACS)
High level of country management (at least Cabinet of Ministers) 
International partners (IFIs, Donors)	NACS
	
HRMIS: Implementation	Video presentation on HRMIS functionality and its necessity of use

Successful cases of HRMIS implementation  

Forum for the exchange of experience 

Administrative regulations 
	Posts on the web-sites and social media, email lists, TV and Radio news 
etc.
	Quarterly

Semi-annually 

Semi-annual

Upon issue	All HRMIS stakeholders including vulnerable groups.

Central and regional level

	NACS

 
CMU	
Components 2.  Enhancing Public Investment Management 	
Automation of PIM processes 	Presentation on the functionalities of PIM automated tool	Post on ministerial website; roundtables or workshops	Once developed 	MEDTA Government executive bodies
CMU
 Project Donors	MEDTA
	
Capacity building in PIM	Guidelines and Training Curriculum on Project Implementation Management

Regulations on MEDTA’s Department 	Post on ministerial website; e-mails with information to stakeholders or linkages to information; roundtables or workshops
Post on ministerial website	Once developed 	All stakeholders

All stakeholders	MEDTA	
Component 3. Better Governance and Oversight of SOEs	
Improved SOEs accountability and performance assessment	Analytical Module with KPI dashboard

Methodology for reviewing SOEs financial reports	Post on ministerial website; e-mails with information to stakeholders or linkages to information; roundtables or workshops	Once developed and operational	All stakeholders	MEDTA	
Coordination, Monitoring and Evaluation 	Project Progress Reports including ESMF, SEP and GRM Monitoring sections 	MEDTA / NACS project web-site, distribution via email to the stakeholders	Semi-annually or annually as appropriate for the type of reporting 	All stakeholders 	NACS/MEDTA	

iii)	Proposed strategy for consultation
Methods used may vary according to target audience and include:
•	Interviews with stakeholders and relevant organization
•	Surveys, polls, and questionnaires
•	Public meetings, workshops, and/or focus groups on specific topic
•	Participatory methods
•	Other traditional mechanisms for consultation and decision making.

iv)	Proposed strategy to incorporate the view of vulnerable groups
Special requirements to the user interface of the software will be implemented. User support teams for IT solutions to be implemented within the Project framework will work with relevant vulnerable groups in government institutions to get info on their needs and provide further relevant support in practical use of solutions.  Project will contact relevant groups of selected disadvantaged people to inform them on HRMIS and civil service development progress via Councils for public engagement established in government institutions at central and regional levels.

v)	Timelines
MEDTA and NACS will provide appropriate background and relevant technical information to stakeholders’ whose feedback is sought on various project issues with sufficient advance notice (5-10 business days) so that the stakeholders have enough time to prepare to provide meaningful feedback. The PIUs will collect, review and report back to stakeholders on how the comments were incorporated or the rationale for not incorporating them within 10 to 30 working days from the stakeholder engagement event.

vi)	Review of Comments
Special comments collection mechanism will be developed by the stakeholder engagement specialist. This mechanism may encompass inter alia electronic submission and tracking of the comments based at the existing experience of Jira like software use.

vii)	Future Phases of Project
The stakeholders will be kept reported on developments and progress periodically but not less than on semi-annual basis depending on results intensity. The Donor / World Bank will receive progress reports on monthly basis.
7.	Resources and Responsibilities for implementing stakeholder engagement activities

The overall coordination role in the implementation of the SEP will be carried out by the MEDTA and NACS in respective areas. 
For the Project implementation the ministry will be established Project Implementation Units (PIU) for the management of the execution of this Project. This NACS has already experience in Bank-funded project implementation and ensures compliance with the applicable Bank procedures. For the MEDTA it will be formally first Bank-funded project to implement. PIUs will include both relevant officials of MEDTA and NACS, as well as external individual consultants to be hired and financed under the Project.  
Given the nature of the proposed package of interventions to be funded by the Project and the new Environmental and Social Framework applicable to the Project, the PIUs will include also a Stakeholder Engagement and communication specialist (SES) who will ensure compliance with the World Bank’s ESF guidelines and implementation of this SEP. In addition, to these professionals, the implementation agencies will be allowed to hire as many individual consultants as needed to help with the implementation of specific project activities over the course of the project, including for raising awareness and SEP implementation. The Project Coordinators from both MEDTA and NACS will be liaison persons between the MEDTA/NACS and the World Bank and will be held accountable for the compliance with ESF guidelines agreed upon under the project.
The PIU would be responsible for day-to-day project management activities, including monitoring and reporting on project progress to all the relevant stakeholders (see the table on Information Disclosure). For this purpose, the PIU will organize, at regular intervals, workshops involving representatives of all stakeholders to present project progress and seek stakeholder input. The costs for all these activities are budgeted under the Project operational costs.
8.	Grievance Mechanism
For the purposes of this SEP, a Grievance Redress Mechanism (GRM) is a process for receiving, evaluating, and addressing project-related complaints from citizens and affected communities at the level of the project. The terms ‘grievance ‘and ‘complaint’ are used interchangeably

The NACS has a grievance department which is responsible for citizens appeals. In the MEDTA the judicial department (Law department) and the department for documents management and control are responsible for all complaints from citizens and affected communities are. The implementing agencies follow the Law of Ukraine «On Appeals of Citizens» (1996, № 394/96), as most recently amended in 2016 (№ 1404/16)). According to this law, citizens can appeal either via personal appointment, via the hot line number or via a written letter. In accordance with Article 20 of this Law, appeals are considered and resolved no later than one month from the date of receipt, and not later than 15 days from the date of receipt, where no further investigation is required. If issues raised in the appeal cannot be resolved within a month, then the recipient will be informed about the further timeline needed to resolve the issue. The grievance department registers all letter and emails in an electronic database. 

The existing grievance procedure will be used as a tool to assist the timely and successful resolution of stakeholder concerns, as well as to monitor the Project’s relationship with the affected stakeholders throughout all Project phases. It is important that the mechanism is impartial, transparent and fair. A summary of complaints and the measures taken to resolve them will be made public on a regular basis. 

The appointed Stakeholder engagement specialist (SES) will be responsible for coordination and handling of all grievances received from the community within the Project. 

Multiple channels to submit complaints have been established and conflicts of interest will be avoided. A central grievance register will be created by the SES, to record and manage any raised grievances. 
Any concerns / views can be brought to the attention of the PIU via following channels: 
NACS	MEDTA	
By email: zagal@nads.gov.ua
In writing: 01601, Kyiv, 15, Prorizna Str.
Other: https://nads.gov.ua/zvernennya-gromadyan
	Email:  zvernennya@me.gov.ua
In writing: 12/2 Hrushevskoho St., Kyiv 01008,
Phone: 044 200 47 53
https://www.me.gov.ua/Documents/
Detail?lang=en-GB&id
=ae251b3d-18a2-4650-ac75-dec40bd5d355&title=
Procedureforfilingcitizensappeals&isSpecial=truehttps://www.me.gov.ua/Feedback/
SendMessage?lang=en-GB&tag=ZvorotniiZviazok	
An electronic and hard copy of the complaint’s procedure and grievance form (Appendix A) is available in this SEP for use by the public. The grievance form will also be available on the websites of NACS and MEDTA.  The grievances received via communication channels will be treated as confidential and complainant will not be disclosed, if the corresponding request will be indicated in the grievance form. 
All received complaints will be recorded in the grievance register within 15 working days and responded to within a maximum period of 30 working days. Both signed and anonymous grievances will be accepted. However, if the person filing a grievance wants to receive a written reply, they must provide reliable contact details. Each complaint will initially be screened, and the facts of the case verified by the SES. 
Any employee or member, including any supervisor or manager, who believes any employee has been subjected to sexual harassment/sexual abasement or who receives a complaint from an employee alleging such harassment, must present the complaint as promptly as possible with the SES after the alleged harassment occurs, even when the employee complaining asks to keep the allegation confidential and take no action. Every complaint of harassment will be investigated promptly, thoroughly, and in an impartial manner. The grievance procedure will be conducted in confidential manner if otherwise is not requested by the complainant.
Procedure 
The person receiving the complaint will complete a grievance form (see Annex A) and will record the complaint in the Register of Complaints. Then, the complaint is to be submitted immediately to relevant Project Coordinator.  
Within one week of receiving the complaint, Project Coordinator must have forwarded the complaint to the department/individual expected to address it. 
Project Coordinator is responsible for determining who to direct the complaint to, whether a complaint requires an investigation (or not), and the timeframe to respond to it. 
When determining who will be the investigating officer, the Project Coordinator should ensure that there is no conflict of interest, i.e. all persons involved in the investigation process should not have any material, personal, or professional interest in the outcome and no personal or professional connection with complainants or witnesses. 
Once the investigation process has been established, the person responsible for managing the GRM records enters this data into the Register of Complaints, and informs the complainant that his/her grievance was received and the timeframe expected for the response. 
The number and type of suggestions and questions should also be recorded and reported so that they can be analyzed to improve project communications. Once a month, the Project Coordinator should submit to relevant Grant Coordinators in MEDTA/NACS a list of all complaints received, the follow-up required, and the status of complaints from the previous month (“on-going” or “addressed”).
The agreed solution or response will be signed off by the SES and where applicable the PIU. The corrective action and status of a complaint (closed, open) will be recorded in the grievance registry. The SES is responsible for maintaining this register. All claims and answers will be kept at the organizations. Any gender specific complaints will be addressed confidentially and will be handled by a relevant person. 
In cases where the complainant is not satisfied with the way their grievance has been dealt with, will invite representatives of the relevant local community / business to SES in the process so that a mutually agreed solution is identified and implemented in a timely manner. At all times, complainants can seek a legal remedy in accordance with the laws and regulations of Ukraine. 
9.	Monitoring and Reporting
Policies, procedures and regular updates on the GRM system, the complaints made and resolved, will be available on the NACS’s and MEDTA web site. They will be updated quarterly. 

The Project coordinator will assess quarterly the functioning of the GRM in order to: 
•	Provide a monthly/quarterly snapshot of GRM results, including any suggestions and questions, to the project team and the management. 
•	Review the status of complaints to track which are not yet resolved and suggest any needed remedial action. 
During semi-annual meetings NACS and MEDTA project team shall discuss and review the effectiveness and use of the GRM and gather suggestions on how to improve it.
The NACS and MEDTA will implement the SEP and will update it regularly during the different stages of the Project. The SES in collaboration with the PIU is responsible for management and monitoring of the SEP. The PIU will also review the SEP regularly to ensure that all the consultation activities are implemented and are in accordance with the planned schedule. 
In the semi-annual project implementation reports submitted to the World Bank, NACS and MEDTA shall include a GRM section, which provides updated information on the following: 
•	Status of establishment of the GRM (procedures, staffing, awareness building, etc.); 
•	Quantitative data on the number of complaints received, the number that were relevant, and the number resolved; 
•	Qualitative data on the type of complaints and answers provided, issues that are unresolved; 
•	Time taken to resolve complaints; 
•	Number of grievances resolved at the lowest level, raised to higher levels; 
•	Any particular issues faced with the procedures/staffing or use; 
•	Factors that may be affecting the use of the GRM/beneficiary feedback system; 
•	Any corrective measures adopted. 

Appendix A. Complaints Procedure and Grievance Form

Figure 1. Complaint submitting and handling mechanism

Public Grievance Form