China Plastic Waste Reduction Project (P174267) – Ningbo SIA Report (Batch 2) World Bank-financed Ningbo Municipal Solid Waste Smart Sorting, Collection and Recycling Project Ningbo PMO July 20, 2022 Executive Summary The Ningbo Municipal Solid Waste Smart Sorting, Collection and Recycling Project (hereinafter, the “Project”) is a subproject of the China Plastic Waste Reduction Project (P174267), which consists of policy work and institutional strengthening, physical investment in smart solid waste management and plastic recycling systems, and project management and capacity building. At the preparation stage, Ningbo PMO conducted an SIA on Batch 1 subprojects which do not involving major civil works (Batch 1 subprojects1). According to the project implementation plan, Batch 2 subprojects include: 1) WWTP of the Ningbo resource recycling base; 2) centralized plastic waste sorting and processing plant; 3) bulky and decoration waste disposal plant; and 4) four recyclables sorting centers. Methods such as literature review, FGD, key informant interview and questionnaire survey are employed for this SIA. During the SIA development, the social team visited the project areas in Ningbo, held 15 FGDs with local residents, persons affected by LAR, project workers, government agencies concerned, project owners, and related enterprises, and conducted 70 men-times of key informant interviews to learn the stakeholders’ attitudes, needs, and suggestions on the Project. The social team has screened Batch 2 subprojects for social risks and impacts according to the ESSs in the ESF, and the ESMF approved by the Bank, and found that Batch 2 subprojects not located in minority communities, and no minority community is collectively attached to the project area, and therefore the ESS7 does not apply; the Project is not a financial intermediary, so ESS9 does not apply; the Project does not involve any cultural relics, and therefore the ESS8 shall not apply. The applicable ESSs are ESS1, ESS2, ESS4, ESS5 and ESS10. Associated social risks include LAR risks, labor and working condition risks, stakeholder engagement risks, and NIMBY risks. To mitigate such risks, a social action plan, labor management plans (LMPs) and a stakeholder engagement plan (SEP) have been developed. Identified potential social risks include: 1. LAR risks: Among Batch 2 subprojects, only the centralized plastic waste sorting and processing plant involves LAR. A total 85.8 mu of collective woodland in Xuanpei and Bailiangqiao Villages, Dongqiao Town of Haishu District will be acquired for this subproject, affecting no local residents. The land for the other subprojects is state-owned construction land, where the WWTP will be constructed on the existing site, involving no LAR. The social audit has found the following outstanding issues: (i) Some structures and equipment in the bulky and decoration waste disposal plant have been compensated for but not relocated, and the PIU has not obtained the right to use state-owned land; and (ii) The four recyclables sorting centers are located on state-owned construction land, but the land use plan will be adjusted for sanitation authorities, and the PIU has not obtained the right to use state-owned land. Therefore, the Project’s LAR risks are “substantial”. 2. Community health and safety risks: In Batch 2 subprojects, project activities are mostly concerning solid waste treatment, which is somewhat environmentally sensitive and 1Including construction of an urban smart waste management system, integration of the Ningbo domestic waste management platform with the existing recycling network “Dabashou”, and output-based incentive mechanism I involving lot of civil works. Potential adverse impacts of construction on nearby communities mainly include environmental impacts, traffic congestion and safety impacts. At the operation stage, plastic, bulky and decoration waste may pose noise, flying dust, waste spillage, traffic accidents and other relevant risks to nearby communities during transport. The WWTP of the Ningbo resource recycling base, centralized plastic waste sorting and processing plant, and bulky and decoration waste disposal plant are located in the Ningbo resource recycling base, and their construction sites are over 1km away from sensitive communities; the 4 recyclables sorting centers are also far away from communities and small in scale, with minor disturbances to communities and the environment. Trucks will run through provincial and special highways, and avoid communities, schools, towns, hospitals and other social sensitive sites. The Project’s community health and safety risks are “moderate”. 3. Labor and working condition risks: Project workers include direct workers of the PMO and PIUs, contract workers and primary suppliers’ workers. Labor risks at the construction stage mainly include hazardous operations, machinery operation risks, mechanical construction noise, emergencies, safety accidents, health and infection risks, salary and benefit risks, etc. Labor risks at the operation stage mainly include OHS risks, toxic and harmful gases, emergencies, infection risks, salary and benefit risks, etc. The Project is located in the economically developed areas of Ningbo, where enterprises operate lawfully, workers have a strong sense of rights protection, and a sound enterprise employment management and supervision system is in place. The Project’s labor and working conditions risks are “moderate”. 4. Stakeholder engagement risks: Inadequate stakeholder engagement may affect the realization of the project objectives, especially the NIMBY effect during the site selection of polluting facilities, which should be fully consulted with nearby communities. In addition, old people and women in nearby communities may be affected more seriously by the spreading of harmful substances during waste transfer, sorting and treatment. Since the Project involves large civil works, LAR may affect livelihoods of low-income population. Since an extensive community participation mechanism was established in the previous municipal solid waste management project in Ningbo (P123323), and the SIA received extensive support from all stakeholders, the Project’s inadequate stakeholder engagement risks are “moderate”. 5. NIMBY Risks: NIMBY is a cross-cutting issue, where nearby residents have concerns about impacts of waste collection, transfer and treatment facilities on their health, environment and local development, and may file complaint or even resist construction, thereby leading to community conflicts. It can be seen from an analysis of the above risks that subsequent LAR and construction activities of the centralized plastic waste sorting and processing plant, truck operations, and the persistent negative attitude of local residents to waste disposal facilities may lead to NIMBY risks. The Ningbo resource recycling base is an important outcome of the World Bank-financed Ningbo Municipal Solid Waste Minimization and Recycling Project (P123323) which was closed in 2020. Ningbo Municipal Government has gained rich experience in improving the local living environment, and strengthening pollution supervision and control in conjunction with new countryside building. Therefore, NIMBY risks are “moderate”. Social risk mitigating measures include: II For the five types of social risks, a social management plan (SMP) has been prepared in consultation with the project owners to minimize negative impacts. 1. LAR risks: ① LA for the centralized plastic waste sorting and processing plant has not begun, and Ningbo PMO and PIU should consult land use with the agencies concerned, prepare an RAP according to ESS5 and the ESMF, and apply for land use and supply with the competent authorities as soon as possible; ②land for the bulky and decoration waste disposal plant has been acquired, and Ningbo PMO and PIU should complete the land use procedure as soon as possible. Some structures and equipment on the site have been compensated for but not relocated. Ningbo PMO and PIUs should clear and relocate such structures and equipment in coordination with the agencies concerned to ensure land supply; and③ land for the sorting centers does not comply with the master land utilization plan /sanitation facility land use plan, the PIU should strengthen communication with the competent authorities to ensure that the land complies with the relevant plan, and obtain the long-term right to use state-owned land before construction (or equipment installation). 2. Community health and safety risks: The PIU should improve the construction plan and make rational construction arrangements to minimize impacts on community; keep high- noise equipment, main discharge ports, etc. away from nearby sensitive sites; strengthen international supervision and management to avoid pollutant leakage; take measures to manage trucks and drivers, and develop and enforce management requirements, such as pre- job training, threshold setting and sign setup, to reduce traffic accidents; establish a formal community communication mechanism to strengthen community communication, and respond to community concerns timely; appoint a qualified social management consulting agency to monitor and evaluate social management measures regularly, and make improvement based on suggestions. 3. Labor and working condition risks: Establish an appropriate LMP and implement as per Appendix 2; detect workplace occupational hazards regularly, and take measures based on results; strengthen OHS training and workers’ safety awareness, conduct emergency drills regularly, and guide workers to use PPE properly; conduct occupational health checkups annually; conduct a fire safety emergency drill annually; further improve the GRM for workers (including direct and contracted workers), handle feedback and grievances of workers, and keep written records; appoint a qualified social management consulting agency to monitor and evaluate labor risks regularly, and make improvement based on suggestions. 4. Inadequate stakeholder engagement risks: The PIUs should act on the SEP and GRM, disclose them to the public, and provide sufficient resources to ensure their effective implementation; ensure that nearby communities participate in project design, construction and operation, where the participation rate should not be less than 70%, with particular attention paid to vulnerable groups’ needs; take full advantage of online platforms, and set up an online disclosure and discussion module for stakeholders to share project information; the PIUs should assign someone to handle the GRM for nearby residents, and disclose grievance contact information to nearby communities before project implementation; The PIUs should establish a communication mechanism with communities during construction and operation to respond to community requests (monthly during construction and quarterly during operation). Environmental monitoring data should be disclosed to stakeholders timely. III 5. NIMBY risks: The PIUs should disclose project information by means of official website, on-site billboard and community bulletin board within one month before construction, assign someone to handle the GRM for nearby residents, and disclose grievance contact information to nearby communities before project implementation. The PIUs should establish a communication mechanism with communities during construction and operation to respond to community requests (monthly during construction and quarterly during operation). Environmental monitoring data should be disclosed to stakeholders timely. An SMP has been prepared on the basis of stakeholder engagement to minimize negative impacts and maximize social benefits, as detailed in Table 7-1. For the measures outlined in the SMP, monitoring indicators have been designed. Ningbo PMO will assign full-time staff to collect and compile information on social management, track the implementation and social performance of the subprojects regularly, and give advice for improvement. In addition, Ningbo PMO will appoint a third-party agency to perform independent M&E during project implementation. IV Contents 1 INTRODUCTION ..................................................................................................................................................................... 1 1.1 BACKGROUND ..............................................................................................................................................................................................1 1.2 PURPOSE OF SIA .........................................................................................................................................................................................2 1.3 SCOPE ...........................................................................................................................................................................................................3 1.4 METHODS .....................................................................................................................................................................................................3 1.5 LIMITATIONS ...............................................................................................................................................................................................4 1.6 REPORT STRUCTURE ..................................................................................................................................................................................4 2 PROJECT DESCRIPTION ...................................................................................................................................................... 6 2.1 SUMMARY.....................................................................................................................................................................................................6 2.2 BASIC INFORMATION OF ASSOCIATED FACILITIES ............................................................................................................................. 15 2.3 SOCIAL AUDIT FINDINGS ........................................................................................................................................................................ 15 3 SOCIAL BASELINE ............................................................................................................................................................... 18 3.1 SOCIOECONOMIC PROFILE OF NINGBO CITY ....................................................................................................................................... 18 3.2 SOCIOECONOMIC PROFILE OF THE PROJECT AREA ............................................................................................................................ 20 3.2.1 Dongqiao Town ........................................................................................................................................................................ 20 3.2.2 Affected Villages ....................................................................................................................................................................... 20 3.3 CURRENT SITUATION OF WASTE SORTING ......................................................................................................................................... 22 3.4 CURRENT SITUATION OF MUNICIPAL SOLID WASTE COLLECTION AND TRANSFER .................................................................... 23 3.5 PROFILE OF THE NINGBO RESOURCE RECYCLING BASE.................................................................................................................... 24 3.6 PRACTICAL EXPERIENCE IN NIMBY RISK MITIGATION OF THE NINGBO RESOURCE RECYCLING BASE .................................. 25 4 SOCIAL MANAGEMENT POLICY FRAMEWORK ........................................................................................................ 27 4.1 INTRODUCTION ........................................................................................................................................................................................ 27 4.1.1 Social Risk Management System ....................................................................................................................................... 27 4.1.2 LAR ................................................................................................................................................................................................ 28 4.1.3 Labor Management ................................................................................................................................................................ 31 4.1.4 Information Disclosure and Public Participation ....................................................................................................... 38 4.2 GAPS FROM ESSS AND REMEDIES......................................................................................................................................................... 42 4.2.1 Social Risk Management....................................................................................................................................................... 42 4.2.2 LAR ................................................................................................................................................................................................ 42 4.2.3 Labor Management ................................................................................................................................................................ 42 4.2.4 Information Disclosure and Public Participation:...................................................................................................... 42 5 SOCIAL RISKS AND IMPACTS SCREENING ................................................................................................................. 44 5.1 METHODS .................................................................................................................................................................................................. 44 5.2 RESULTS .................................................................................................................................................................................................... 44 5.2.1 Irrelevance ................................................................................................................................................................................. 44 5.2.2 Relevance .................................................................................................................................................................................... 45 6 STAKEHOLDER ENGAGEMENT ...................................................................................................................................... 51 6.1 STAKEHOLDER IDENTIFICATION ........................................................................................................................................................... 51 6.2 PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES ....................................................................................................................... 56 6.3 KEY FINDINGS .......................................................................................................................................................................................... 57 6.4 FUTURE SEP ............................................................................................................................................................................................ 57 7 SOCIAL IMPACT ANALYSIS .............................................................................................................................................. 60 7.1 SOCIAL BENEFITS .................................................................................................................................................................................... 60 7.2 SOCIAL IMPACTS ...................................................................................................................................................................................... 60 7.2.1 LAR risks ..................................................................................................................................................................................... 60 7.2.2 Labor and working condition risks .................................................................................................................................. 67 7.2.3 Community health and safety risks .................................................................................................................................. 80 7.2.4 Inadequate stakeholder engagement risks ................................................................................................................... 86 7.2.5 NIMBY risks ............................................................................................................................................................................... 90 8 SMP.......................................................................................................................................................................................... 94 9 INSTITUTIONAL ARRANGEMENTS AND CAPACITY BUILDING ........................................................................ 111 9.1 INSTITUTIONAL ARRANGEMENTS ...................................................................................................................................................... 111 I 9.2 CAPACITY BUILDING ............................................................................................................................................................................ 112 10 M&E ....................................................................................................................................................................................... 115 10.1 INTERNAL MONITORING ................................................................................................................................................................ 115 10.2 EXTERNAL MONITORING ............................................................................................................................................................... 115 10.3 REPORTING SYSTEM ....................................................................................................................................................................... 116 APPENDIX 1 PUBLIC CONSULTATION RECORDS ............................................................................................................. 117 APPENDIX 2 LMP FOR PIUS .................................................................................................................................................... 121 APPENDIX 2.1 LMP FOR BULKY AND DECORATION WASTE TREATMENT PLANT ............................................................................... 121 APPENDIX 2.2 LMP FOR CENTRALIZED PLASTIC WASTE SORTING AND PROCESSING PLANT, AND RECYCLABLES SORTING CENTERS ............................................................................................................................................................................................................ 133 APPENDIX 2.3 LMP FOR WWTP OF THE NINGBO RESOURCE RECYCLING BASE ................................................................................ 145 APPENDIX 2.4 LMP FOR RECYCLABLES SORTING CENTERS .................................................................................................................... 157 APPENDIX 3 CONCLUSIONS AND SUGGESTIONS OF THE SOCIAL AUDIT REPORT .............................................. 169 APPENDIX 4 STAKEHOLDER ENGAGEMENT RECORDS ................................................................................................. 177 II List of Tables TABLE 1-1 PROPOSED PROJECT ACTIVITIES...........................................................................................................................................................1 TABLE 1-2 FRONT-END COLLECTION AND TRANSFER SYSTEM FOR THE BATCH 2 SUBPROJECTS ..................................................................1 TABLE 2-1 BASIC INFORMATION OF THE BATCH 2 SUBPROJECTS ......................................................................................................................7 TABLE 2-2 OVERVIEW OF THE BATCH 2 SUBPROJECTS AND ASSOCIATED FACILITIES .................................................................................. 14 TABLE 3-1 SOCIOECONOMIC PROFILE OF THE PROJECT AREA (2020) .......................................................................................................... 19 TABLE 3-2 EXISTING RECYCLABLE SORTING CENTERS ..................................................................................................................................... 22 TABLE 4-1 APPLICABILITY OF ESSS ...................................................................................................................................................................... 27 TABLE 4-2 LEGAL FRAMEWORK FOR SOCIAL RISK MANAGEMENT ................................................................................................................. 28 TABLE 4-3 LEGAL FRAMEWORK FOR LAR........................................................................................................................................................... 29 TABLE 4-4 LEGAL FRAMEWORK FOR LABOR MANAGEMENT ........................................................................................................................... 33 TABLE 4-5 LEGAL FRAMEWORK FOR INFORMATION DISCLOSURE AND PUBLIC PARTICIPATION .............................................................. 39 TABLE 5-1 SOCIAL IMPACT SCREENING RESULTS............................................................................................................................................... 48 TABLE 6-1 IDENTIFICATION AND ANALYSIS OF PROJECT-AFFECTED PARTIES .............................................................................................. 51 TABLE 6-2 IDENTIFICATION AND ANALYSIS OF OTHER INTERESTED PARTIES ............................................................................................. 53 TABLE 6-3 IDENTIFICATION AND ANALYSIS OF VULNERABLE GROUPS .......................................................................................................... 56 TABLE 7-1 STATISTICS OF LAR RISKS OF SUBPROJECTS IN THE PARK ........................................................................................................... 62 TABLE 7-2 LAND USED FOR THE SORTING CENTERS ......................................................................................................................................... 62 TABLE 7-3 RATINGS OF LAND USE RISKS ............................................................................................................................................................ 66 TABLE 7-4 DESIGN OPTIMIZATION AND MITIGATION MEASURES (LAR RISKS) .......................................................................................... 67 TABLE 7-5 ACTIVITIES AND PIUS OF THE BATCH 2 SUBPROJECTS ................................................................................................................. 68 TABLE 7-6 TYPES AND ESTIMATED NUMBERS OF PROJECT WORKERS .......................................................................................................... 72 TABLE 7-7 CONTACT INFORMATION OF SERVICE PROVIDERS .......................................................................................................................... 75 TABLE 7-8 RATINGS OF LABOR AND WORKING CONDITION RISKS ................................................................................................................. 75 TABLE 7-9 DESIGN OPTIMIZATION AND MITIGATION MEASURES (LABOR AND WORKING CONDITION RISKS) ..................................... 76 TABLE 7-10 INFORMATION ON RECYCLABLE TRANSFER TRUCKS................................................................................................................... 81 TABLE 7-11 RATINGS OF COMMUNITY HEALTH AND SAFETY RISKS .............................................................................................................. 82 TABLE 7-12 DESIGN OPTIMIZATION AND MITIGATION MEASURES (COMMUNITY HEALTH AND SAFETY RISKS) .................................. 84 TABLE 7-13 RATINGS OF INADEQUATE STAKEHOLDER ENGAGEMENT RISKS ............................................................................................... 87 TABLE 7-14 DESIGN OPTIMIZATION AND MITIGATION MEASURES (INADEQUATE STAKEHOLDER ENGAGEMENT RISKS) .................. 88 TABLE 7-15 RATINGS OF NIMBY AND INADEQUATE STAKEHOLDER ENGAGEMENT RISKS....................................................................... 91 TABLE 7-16 DESIGN OPTIMIZATION AND MITIGATION MEASURES (NIMBY RISKS) ................................................................................. 92 TABLE 8-1 SMP FOR THE WWTP OF THE NINGBO RESOURCE RECYCLING BASE ....................................................................................... 95 TABLE 8-2 SMP FOR THE CENTRALIZED PLASTIC WASTE SORTING AND PROCESSING PLANT ................................................................. 98 TABLE 8-3 SMP FOR THE BULKY AND DECORATION WASTE DISPOSAL PLANT ........................................................................................ 103 TABLE 8-4 SMP FOR THE 4 RECYCLABLE SORTING CENTERS ...................................................................................................................... 107 TABLE 9-1 SCHEDULE FOR SOCIAL MANAGEMENT CAPACITY BUILDING .................................................................................................... 113 I List of Figures FIGURE 1-1 MAP OF THE PROJECT AREA ................................................................................................................................................................1 FIGURE 2-1 LOCATION MAP OF THE SUBPROJECTS ...............................................................................................................................................8 FIGURE 2-2 LAYOUT PLAN OF THE WWTP............................................................................................................................................................9 FIGURE 2-3 LAYOUT PLAN OF THE CENTRALIZED PLASTIC WASTE SORTING AND PROCESSING PLANT .................................................. 10 FIGURE 2-4 LAYOUT PLAN OF THE CENTRALIZED PLASTIC WASTE SORTING AND PROCESSING PLANT .................................................. 12 FIGURE 3-1 DISTRIBUTION OF SETTLEMENTS AROUND THE NINGBO RESOURCE RECYCLING BASE ......................................................... 20 FIGURE 3-2 XUANPEI VILLAGE (LEFT), BAILIANGQIAO VILLAGE (RIGHT) .................................................................................................... 21 FIGURE 3-3 HUIJIANG VILLAGE (LEFT), YUSHANTOU VILLAGE (RIGHT) ....................................................................................................... 22 FIGURE 3-4 SANLI VILLAGE .................................................................................................................................................................................... 22 FIGURE 3-5 PLAN OF THE NINGBO RESOURCE RECYCLING BASE .................................................................................................................... 25 FIGURE 6-1 DISCLOSURE OF DRAFT E&S DOCUMENTS..................................................................................................................................... 59 FIGURE 6-2 DISCLOSURE OF FINAL E&S DOCUMENTS ...................................................................................................................................... 59 FIGURE 7-1 SITE OF THE CENTRALIZED PLASTIC WASTE SORTING AND PROCESSING PLANT ................................................................... 61 FIGURE 7-2 SITE OF THE BULKY AND DECORATION WASTE DISPOSAL PLANT............................................................................................. 62 FIGURE 7-3 CURRENT SITUATION OF SORTING CENTERS ................................................................................................................................. 65 FIGURE 9-1 ORGANIZATIONAL CHART............................................................................................................................................................... 111 II Acronyms and Abbreviations E&S Environmental and Social EIA Environmental Impact Assessment ESF Environmental and Social Framework ESCP Environmental and Social Commitment Plan ESMF Environmental and Social Management Framework EHSG World Bank’s Environment, Health and Safety Guidelines ESS Environmental and Social Standard GIIP Good International Industrial Practice GAP Gender Action Plan GRM Grievance Redress Mechanism LMP Labor Management Procedure M&E Monitoring and Evaluation NDWSGC Ningbo Municipal Solid Waste Separation Guidance Center NMII Ningbo Municipal Public Utilities Investment Co., Ltd. OHS Occupational Health and Safety PIU Project Implementation Unit PMO Project Management Office PLG Project Leading Group PPE Personal Protection Equipment SAP Social Action Plan SIA Social Impact Assessment SEP Stakeholder Engagement Plan TA Technical Assistance ToRs Terms of References USD US Dollar WBG World Bank Group WWTP Wastewater Treatment Plant III 1 Introduction 1.1 Background China and the World Bank are working closely to implement the lately approved China Plastic Waste Reduction Project (P174267), which aims to strengthen national and sub- national policies, institutions and operations towards reduced plastics pollution from municipal solid waste streams. In Ningbo– one of the demonstration cities of the new project, the Ningbo Municipal Solid Waste Smart Sorting, Collection and Recycling Project (hereinafter, the “Project”) will be implemented, as part of the overall new project. The gross investment in the Project is 1.616 billion yuan (about US$241 million), of which the Bank loan is US$150 million. The Project has a construction period of 5 years, and will be implemented from 2021. The Project will be implemented in 6 urban districts (Yinzhou, Haishu, Zhenhai, Beilun, Jiangbei and Fenghua), High-tech Development Zone (demonstration area) and the Dongqian Lake area (demonstration area). See Figure 1-1. Figure 1-1 Map of the Project Area 1 The Project will support the establishment of a smart municipal solid waste separation, collection, treatment and recycling system in Ningbo that starts from smart waste separation and collection at drop-off and ends by less waste to disposal and more waste recycled and reused. The project will help Ningbo achieve its 2025 targets to increasing the proportion of precise waste separation to 80%, the recycling rate of municipal waste to 60%, and recycled plastic waste to 20% as of all recyclables. The Project has three components: (1) policy work and institutional strengthening; (2) investment in smart solid waste management and plastic recycling system, hardware and operation; and (3) project management and capacity building. According to the implementation arrangements, the Project will be implemented in batches, as detailed in Table 1-1. 2 Table 1-1 Proposed Project Activities Component Scope of construction PIU Batch 1.1 Output-based reward 1 1.2.1 Study on plastic pollution reduction 1 action plan for Ningbo 1.2.2 Study on evaluation methods for 1 plastic pollution reduction effects of Ningbo Ningbo Municipal Solid 1. Policy work and 1.2.3 Study on improvement of municipal Waste 1 mechanism 1.2 Technical solid waste collection policies of Ningbo Soft Component Separation strengthening assistance 1.2.4 Study on implementation rules for Guidance 1 waste separation regulations of Ningbo Center 1.2.5 Study on regulation measures for 1 utilities (waste) sector 1.2.6 Public data security study based on 1 smart all-category waste cabins Deploying not less than 4,000 smart collection terminals over three years, covering about 2,200 residential communities, schools, government 2.1.1 Construction of a smart management buildings, enterprises and institutions, commercial Dabashou 1 system for domestic waste in the urban area complexes, farmer’s markets and other public places Company 2. Smart municipal in the entire project implementation area; 2.1 Waste solid waste procurement of 230 recyclables transportation sorting, management and trucks and 600 kitchen waste transportation trucks collection and plastic waste transfer system 2.1.2 Integration of Ningbo’s existing waste recycling Dabashou management system and waste recycling Soft Component 1 Company network Construction of 9 sorting and transfer centers Dabashou 2.1.3 Recyclables sorting center covering to sort out recyclables of paper, plastic, 2 and 3 Company textiles, metals, glass, etc.; 1 Component Scope of construction PIU Batch Construction of a home appliances dismantling 2.1.4 Home appliances dismantling center Dabashou center, with a floor area of 30 mu and a building area 3 and integrated management system Company of 13,000 m2 (including dismantling line) Reconstructed and expanded from an existing leachate treatment plan, including demolishing the existing management room and two-stage A/O wastewater treatment system, constructing a regulating tank, two MBR complexes, a car washing center, a management room, enclosing walls, roads Qingyuan 2.2 WWTP of Ningbo resource recycling base 2 and landscaping, and purchasing and installing Company equipment After completion, the plant’s daily wastewater treatment capacity will be 2,500 m3/d (1,800 m3/d from new construction and 700 m3/d from reconstruction). With a planned land area of 85.5 mu, a building area Haijing 2.3 Centralized plastic waste sorting and processing plant of 60,000 m2 and an annual plastic treatment 2 Company capacity of 40,000 tons With a planned land area of 39,451 m2, a building area of 22,150 m2 and an annual treatment capacity of 300,000 tons of decoration waste; also Meijing 2.4 Bulky and decoration waste disposal plant 2 constructing a 45,000-ton bulky waste treatment Company line, an 82,000-ton RDF treatment line and a 18 million-brick regeneration line 3.1 Technical upgrading of digital waste sorting management Ningbo 1 platform Municipal Solid 3. Project 3.2 Study on publicity evaluation plan for smart waste Waste 1 management and separation in residential communities Soft Component Separation capacity building 3.3 Planning of waste sorting publicity activities Guidance 1 Center 3.4 Print production, training and seminars on waste separation 1 Source: Feasibility Study Report of the Project (final) 2 In the preparation stage, since the details (including site, scale, technical solution, etc.) for some subprojects were still unclear, the E&S documents of the Project are prepared and assessed as follows: • Prepare E&S framework documents for the whole Project, including ESMF, SEF and ESCP; • Prepare detailed E&S management documents for any identified subproject, including SIA report, LMP, SEP, RAP (if required), etc. According to the above principles and methods, Ningbo PMO prepared the E&S management documents (including ESMF, ESCP and SEF) for the Project at the preparation stage (2020-2021), and a detailed SIA report for Batch 1 subprojects. These documents were approved by the Bank in February 2021. Batch 1 subprojects consist mainly of activities that do not involve major construction, including: - 1 Policy work and mechanism strengthening; - 2.1.1 Construction of a smart management system for domestic waste in the urban area; and - 2.1.2 Integration of existing municipal solid waste management platform with the waste recycling network. Ningbo PMO and PIUs have identified Batch 2 subprojects, including: - 2.2 WWTP of the Ningbo resource recycling base; - 2.3 Centralized plastic waste sorting and processing plant - 2.4 Bulky and decoration waste disposal plant; and - 2.1.3 Four recyclables sorting centers See Table 1-2 for waste collection and transfer system for Batch 2 subprojects Table 1-2 Separated waste collection and transfer system for Batch 2 subprojects Subproject Collected by Transfer mode Smart all-category waste cabins under the Recyclable truck and integration of Ningbo’s existing municipal solid Recyclables sorting centers enclosed waste truck (with waste management platform with the waste hooked arm) recycling network Kaicheng Kitchen Waste Plant, Shouchuang WWTP of the Ningbo resource Kitchen Waste Plant, centralized plastic waste Municipal sewer network recycling base sorting and processing plant (Batch 2 (offsite sewer lines) subprojects), and Haishu landfill Centralized plastic waste Recyclable sorting center, bulky and Truck sorting and processing plant decoration waste disposal plant Bulky and decoration waste Recyclable sorting center Truck disposal plant Ningbo PMO and PIUs conducted a social impact assessment (SIA) on Batch 2 subprojects according to the ESCP and ESMF of the Project. In addition, the WWTP of Ningbo resource recycling base will treat wastewater from the Haishu District landfill, Ningbo food waste disposal plant and Ningbo kitchen waste disposal plant, so these wastewater generating facilities and the offsite sewer lines are defined as 1 associated facilities. Among the 4 recyclables sorting centers, the Jiangshan recyclables sorting center in Yinzhou District and Gulin recyclables sorting center in Haishu District will be reconstructed from existing facilities. During the SIA on Batch 2 subprojects, a social audit was conducted on the above associated and existing facilities. On this basis, the potential social impacts and risks of Batch 2 subprojects were assessed systematically, and the project design optimized and mitigation measures proposed based on the mitigation hierarchy in the Bank’s ESF. This SIA report is for Batch 2 subprojects. See the Social Audit Report for the social audit process, findings and suggestions on the associated and existing facilities of Batch 2 subprojects. 1.2 Purpose of SIA The purpose of the SIA is to analyze and evaluate the potential social impacts and risks of the proposed subprojects in the whole project lifecycle (including preparation, construction and operation) according to the Bank’s ESF. As discussed above, during the SIA, a social audit was conducted on the associated and existing facilities of Batch 2 subprojects to systematically assess the Project’s social impacts and risks (including labor and working conditions, LAR, community health and safety, and stakeholder engagement, etc.) to learn the current situation and level of social management of the associated and existing facilities, and lay a foundation for the SIA. The main objectives of the SIA are: • Evaluating potential social impacts and risks in the future construction and operation of the proposed subprojects according to the applicable regulations of China and relevant ESSs based on the social audit and social screening results, including: o Assessment and Management of Environmental Risks and Impacts (ESS1); o Labor and Working Conditions (ESS2); o Community Health and Safety (ESS4); o Land Acquisition, Restriction on Land Use and Involuntary Resettlement (ESS5); o Stakeholder Engagement and Information Disclosure (ESS10). • Developing and implementing an SEP (including GRM), and proposing measures to optimize the project design and mitigate impacts / risks based on their opinions and suggestions through meaningful consultation with all stakeholders; • Learning nearby communities’ attitudes to the proposed subprojects, and concerns to provide a basis for analyzing potential social risks and impacts, and developing more effective mitigation measures; • Proposing suggestions to mitigate social impacts and risks to ensure that the proposed subprojects meet the requirements of the applicable ESSs and Chinese regulations; • Fully consulting with the owners on risk mitigation measures and optimization suggestions, and scheduling such measures; • Developing an SMP, and making clear institutional, staffing, funding, monitoring and reporting arrangements. 2 1.3 Scope Batch 2 subprojects aim to improve the municipal solid waste separation, collection, transfer, recycling and disposal capacity of Ningbo City comprehensively, and hence reduce plastic leakage to the environment from municipal waste streams. This SIA covers Batch 2 subprojects, including: 1) centralized plastic waste sorting and processing plant; 2) bulky and decoration waste disposal plant; 3) WWTP; and 4) four recyclables sorting centers, including: • Reconstructed and expanded from an existing leachate treatment plan, including demolishing the existing management room and two-stage A/O wastewater treatment system, constructing a regulating tank, two MBR complexes, a car washing center, a management room, enclosing walls, roads and landscaping, and purchasing and installing equipment; • Construction of a centralized plastic waste sorting and processing plant with a building area of 60,000m2; • Construction of a bulky and decoration waste disposal plant with a building area of 22,150m2, a 45,000-ton bulky waste treatment line, an 82,000-ton RDF treatment line and an 18 million-brick regeneration line; and • Construction of 4 recyclables sorting centers in a grid management pattern The SIA is focused on the sites of the subprojects, and sensitive communities potentially affected at the construction and operation stages, and potentially affected along recyclables transfer routes at the operation stage. The bulky and decoration waste disposal plant, WWTP, and centralized plastic waste sorting and processing plant are located in the Ningbo resource recycling base, the nearby social sensitive sites mainly include Peixuan, Bailiangqiao, Huijiang, Yushantou and Sanli Villages in Dongqiao Town, and Yunfeng Village in Yinjiang Town, Haishu District, and other social sensitive objects include Tangguo’ao, Jiangkou Sub-district, etc., which are 1.0-3.0km away from the base; the recyclables sorting centers are mostly located in the outskirts, far away from residential areas, mostly surrounded by wasteland or industrial parks, with the nearest village being about 500m away. The SIA will cover these nearby villages to analyze the potential impacts of the subprojects on nearby residents. The SIA screens and assesses potential impacts and risks that may arise at the preparation, construction and operation stages of Batch 2 subprojects, proposes mitigation measures, prepares relevant documents, conducts stakeholder engagement, and also analyzes and evaluates the primary suppliers of the to-be constructed facilities of Batch 2 subprojects. 1.4 Methods During July-September 2021, the social team conducted a participatory SIA survey in the project areas with the assistance of the Project Leading Group (PLG). 1) Determine the relevance of the ESSs, identify relevant social impacts and risks, and conduct scoping based on the social audit on the existing facilities and completed LA activities, and the social screening on the proposed activities. 2) Analyze China’s existing regulatory framework and the relevance of the ESSs, propose mitigation measures, and conduct a baseline survey pertinently based on the identified social impacts and risks. 3 3) Evaluate potential significant social risks and impacts that are related to the proposed subprojects, with focus on significant risks and impacts, propose measures to optimize the project design and mitigate impacts / risks, and prepare the SMP on this basis. 4) Stakeholder engagement will run through the whole SIA process, and the implementation and M&E of social measures after project approval. The SIA methods are as follows: 1) Literature review: including: (i)documents containing basic project information, such as the project proposal and feasibility study report; (ii) relevant approvals, including the boundary map, land allocation decision, LA compensation documents, etc.; (iii) social audit report; and (iv) other social documents and records. 2) Fieldwork: During the SIA, the social team visited the project areas, held 10 FGDs with local residents, persons affected by LAR, project workers, government agencies concerned, project owners, and other related enterprises, and conducted 70 men-times of key informant interviews (including Ningbo PMO, PIUs, government agencies concerned, sub-district offices, community committees, recyclable sorters, recyclable truck drivers, persons affected by LAR, and nearby residents) to learn stakeholders’ attitudes, needs and suggestions on the Project. 1.5 Limitations • Currently, the PIUs have just been established, their functions are being improved, and there is little information on labor management and capacity building. • The SIA was conducted during COVID-19 pandemic prevention and control period, and the restrictions on travel and inter-person interactions have much limited the face-to- face communications with relevant communities. That may have inevitably affected the depth and breadth of the SIA. 1.6 Report Structure This report has 8 chapters: • Chapter 1 summarizes the background of the Project, and the objectives, methods and scope of the SIA. • Chapter 2 introduces the Batch 2 subprojects, describes the location, service range, activities, employment, land use, and E&S sensitive sites of each subproject. • Chapter 3 compares China’s applicable laws and regulations with the ESSs, and analyzes the policies applicable to the Project. • Chapter 4 analyzes Ningbo City’s socioeconomic profile, and baseline social information related to the proposed subprojects; • Chapter 5 identifies and analyzes stakeholders, conducts information disclosure and public participation, and proposes an SEP for the Batch 2 subprojects. • Chapter 6 identifies social impacts and risks, proposes corresponding mitigation measures, and gives advice on project design optimization and tolerance for vulnerable groups. • Chapter 7 proposes a social action plan for the risk mitigation and benefit enhancement measures identified in Chapter 6. 4 • Chapter 8 describes the Project’s institutional arrangements, capacity building, M&E, and budget. • Attachments: including the LMP, public participation records, etc. 5 2 Project Description 2.1 Summary Batch 2 subprojects 4 major physical development activities: 1) WWTP of Ningbo resource recycling base; 2) centralized plastic waste sorting and processing plant; 3) bulky and decoration waste disposal plant; and 4) 4 recyclables sorting centers. See Table 2-1 and Figure 2-1. 6 Table 2-1 Basic Information of the Batch 2 Subprojects Investment No. Subproject Land use (0,000 PIU Labor Nearby sensitive sites yuan) Direct workers: 36; Reconstructed and expanded within the They are located in Ningbo resource Qingyuan Contract workers: 335; 1 WWTP existing leachate processing plant, with a 18056 recycling base, the nearby social Company Primary suppliers’ floor area of 67 mu sensitive sites mainly include workers: 40 Peixuan, Bailiangqiao, Huijiang, Direct workers: 170-195; Yushantou and Sanli Villages in Centralized plastic Located in the Ningbo resource recycling Dongqiao Town, and Yunfeng Village Haijing Contract workers: 340; 2 waste sorting and base in Haishu District, with a floor area of 37914 in Yinjiang Town, Haishu District, and Company Primary suppliers’ processing plant about 85.8 mu other social sensitive objects include workers: 120 Tangguo’ao, Jiangkou Sub-district, Bulky and Located in the Ningbo resource recycling etc., which are 1.0-3.0km away from Meijing Direct workers: 25; 3 decoration waste base in Haishu District, with a planned land 16927 the base. Company Contract workers: 215; disposal plant area of 59.2 mu Among the 4 sorting centers, the one in Zhenhai District occupies 9 mu of land, that Direct workers: 28; far away from residential areas, 4 recyclables in Beilun District occupies 9 mu, that in Dabashou Contract workers: 180; mostly surrounded by wasteland or 4 64780 sorting centers Yinzhou District occupies 6.97 mu and that Company Primary suppliers’ industrial parks, with the nearest in Haishu District occupies 15 mu, all being workers: 3 village being about 500m away state-owned land. Total 137704 Source: Feasibility Study Report of the Ningbo Project (final) 7 Figure 2-1 Location Map of the Subprojects 8 2.1.1 WWTP of Ningbo resource recycling base The WWTP of Ningbo resource recycling base is located in the existing leachate treatment station in the Ningbo resource recycling base in Dongqiao Town, Haishu District. After completion, the WWTP’s daily wastewater treatment capacity will be 2,500 m3/d (1,800 m3/d from new construction and 700 m3/d from reconstruction) The WWTP will be reconstructed and expanded on an existing leachate treatment plant, including demolishing the existing management room and two-stage A/O wastewater treatment system, constructing a regulating tank, two MBR complexes, a car washing center, a management room, enclosing walls, roads and landscaping, and purchasing and installing equipment. Figure 2-2 Layout Plan of the WWTP This subproject includes both construction and reconstruction. 1) Reconstruction of existing leachate treatment system (1) With the gradual closure of the landfill, leachate output has been reduced gradually to less than 500m3/d, so the 1# A/O system in the north remains unchanged, used to treat landfill leachate (500m3/d). During reconstruction, a 2# 2# MBR complex (200m3/d) will be rebuilt at the northwest corner to replace the 2# A/O system in the south to ensure uninterrupted wastewater treatment. The existing 2# A/O system will be demolished when the 2# MBR complex is put into normal operation. After that, the wastewater treatment system of the 2# MBR complex may be connected to the new wastewater treatment system. (2) Reconstruct the existing ultrafiltration system; (3) Reconstruct the existing leachate system to meet the emission standard in Table 2 of the Standard for Pollution Control of Landfills (GB16889-2008); (4) After reconstruction, the 2# MBR complex and 1# A/O system will operate 9 independently. 2) Construction of wastewater treatment system The new wastewater treatment system has a treatment capacity of 1,800 m3/d, used to treat mixed wastewater except leachate. Treated water will meet the Class B standard in the Wastewater Quality Standards for Discharge to Municipal Sewers (GB/T31962-2015), and then be discharged into the municipal sewer network. The new wastewater treatment system and existing leachate system are two independent systems. The new wastewater treatment system can be divided into a pretreatment system, a biochemical treatment system and an in-depth treatment system. Wastewater from all sources is delivered to the pretreatment system via pipes, and biogas fluid will stay in conditioning tanks for 2-3 days before entering the pretreatment system. Pretreatment uses the grid + primary setting + oil separation + homogenization + floatation process, where leachate runs through a denitrification tank and a nitrification tank to decompose and remove organic matter, ammonia nitrogen and nitrate nitrogen. After slurry mixture in the biochemical system is separated by the ultrafiltration system, clear liquid will be sent to the BAF system for in-depth treatment before discharge. The construction period of this subproject is from June 2022 to August 2023. 2.1.2 Centralized plastic waste sorting and processing plant This plant is located in Ningbo resource recycling base in Dongqiao Town, Haishu District, with a planned land area of 57,229 m2 (about 85.8 mu), where a raw material shop, a production shop, a product shop, an office, a power distribution room, a guard room, etc. will be built, with a building area of about 40,000 m2 and a treatment capacity of 40,000 t/y. Figure 2-3 Layout Plan of the Centralized Plastic Waste Sorting and Processing Plant 10 Two sorting lines and 4 production lines will be built in the production area, including a plastic bottle pre-sorting line, another plastic waste sorting line, a PET plastic cleaning and granulation line, HDPE (PP) cleaning and granulation line (including a high-quality HDPE (PP) cleaning and granulation line, and a low-quality HDPE (PP) cleaning and granulation line), film plastic cleaning and granulation line (including one for clean film plastics and one for dirty film plastics), and a home appliance plastic cleaning and granulation line, with a design treatment capacity of 40,000 t/y. Plastics are mainly from recyclable plastic waste, plastic waste mixed in other wastes, plastic waste from dismantled home appliances, and that separated from decoration waste. 1) Efficient pre-sorting process • Plastic bottle pre-sorting line: Mixed plastic bottles from waste cabins first enter the drum and bouncing sieves to separate metals, stones, impurities, etc., and then sorted manually for preliminary separation. It then enters two optical sorting devices to pick bottles of different materials, and is then sent to different bins after manual review • Sorting line for other plastic waste: Mixed plastics after preliminary sorting first enter the drum and bouncing sieves to separate metals, stones, impurities, etc., and then sorted manually for preliminary separation. It then enters 3 optical sorting devices to pick plastics of different materials, and is then sent to different bins after manual review. 2) PET plastic cleaning and granulation process PET plastics are first delivered to the vertical bale opening machine via the speed- adjustable chain scraper conveyor, then scattered by two mechanical shafts, and then run through the magnetic separator to remove metals. The label remover will rub each bottle to remove the label; plastics and PET bottles are separated through photoelectric sorting and manual review, and cleaned together. Finally, plastic sheets are sorted to further improve impurity, and sent to the granulator for granulation. 3) HDPE and PP cleaning and granulation process • High-quality HDPE (PP) cleaning and granulation line: High-quality HDPE or PP plastics are first delivered to the vertical bale opening machine via the speed- adjustable chain scraper conveyor, then scattered by two mechanical shafts, and then run through the drum and bouncing sieves to remove sand, metals, stones and other impurities. They then go through optical sorting, manual sorting and magnetic separation to remove other plastics and metals. Leveled plastics are crushed, soaked and dehydrated to remove impurities, oil stations and other attachments. Plastics are finally sorted to further improve purity to the cosmetic or food grade. • Low-quality HDPE (PP) cleaning and granulation line: Low-quality HDPE (PP) plastics are scattered, removed of metals and separated to remove impurities and oil stains, and then further sorted to improve purity to the industrial grade for granulation. 4) Home appliances dismantling plastic cleaning and granulation process This line has a design capacity of 3 t/h. Home appliances dismantling plastics are scattered, removed of metals, separated and washed to remove impurities and oil stains, then further sorted to separate PS, PP and ABS plastics, and sent to the 11 granulator for granulation. 5) Film plastic cleaning and recycling line There are two lines for clean and dirty film plastics each, with a design capacity of 1.5 t/h each, in which the clean film plastic line is for used LDPE, LLDPE, HDPE, PP woven bags / waste bags / shopping bags, etc. in daily life, and the dirty film plastic line is for industrial treatment. • Clean film plastic cleaning and granulation line: Clean film plastics are charged evenly via the conveyor, removed of metals, crushed, cleaned repeatedly to remove mud, sand, stones, etc., then dried, and finally sent to the granulator. • Dirty film plastic cleaning and granulation line: Dirty film plastics are charged evenly via the conveyor, removed of metals, preliminarily cleaned and separated, crushed, cleaned repeatedly to remove mud, sand, stones, etc., then dried, and finally sent to the granulator The construction period of this subproject is from January 2023 to June 2024. 2.1.3 Bulky and decoration waste disposal plant This subproject is located in Ningbo resource recycling base in Dongqiao Town, Haishu District, with a planned land area of 39,451 m2, consisting of a raw material shop, a processing shop, a finished product shop, an office, a guard room, etc., with a building area of 22,150 m2 and an annual treatment capacity of 300,000 tons of decoration waste, including a 45,000-ton bulky waste treatment line, an 82,000-ton RDF treatment line and an 18 million-brick regeneration line. Figure 2-4 Layout Plan of the Centralized Plastic Waste Sorting and Processing Plant 12 The production processes include the decoration waste disposal process, bulky waste disposal process, brick making process, and RDF preparation process. 1) Decoration waste disposal process The subject of construction waste disposal is decoration waste and existing waste2, with separate raw material areas and charging ports, a shared crushing and sieving system, and a shared aggregate making system, with a design capacity of 1,000t/d. (1) Feeding: Raw decoration waste is weighed in the plant, and then delivered to the chain scraper conveyor, by which two operators pick bulk waste, with the remainder entering the next operation. (2) Sieving: The chain scraper conveyor feeds the material to the crush for crushing to below 250mm, and the crushed material is sent to the drum sieve to obtain 0~50mm and 50~100mm undersize materials, and a >100mm oversize material, which are sent to their respective sorting lines. Optically sorted plastics are sent to the plastic storage area, timbers, rubbers, plastics, etc. are sent to the RDF storage area as RDF raw materials, and other materials are sent to the manual sorting station for purification, such as textile removal. (3) Aggregate crushing and sieving: The purified material is removed of magnetic substances (iron mainly), and then sent to the crusher. The crushed material is sieved to obtain 0-15mm and 15-30mm aggregates, and the oversize material is crushed again for further sieving. 2) Bulky waste disposal process Bulky waste is first crushed into small pieces, removed of metals, and then crushed into tiny pieces of less than 80mm and 50mm. A centralized dust removal system is used to ensure a dust-free environment. The flammable mixture after crushing will be burned for power generation. 3) RDF preparation process Timbers, rubbers, plastics, etc. are sorted from bulky and decoration waste. Such materials are of low moisture content and a considerable calorific value, and can be further processed into a biomass fuel for an added value. 4) Brick making process Aggregate of different grades are measured precisely, mixed into dry and hard concrete, and made into various bricks, such as hollow, solid, facing and floor bricks, and special concrete members for use in parks, airports, wharves and rivers. The construction period of this subproject is from January 2023 to January 2024. 2.1.4 Four recyclables sorting centers The sorting centers target recyclables, including plastic bottles, low-value dirty plastics, daily chemical plastic waste, waste paper, waste glass, waste metals, waste textiles, etc. 2Existing waste refers mainly to the part of construction waste transferred to a transfer station for piling without treatment. 13 Currently, the Jiangshan sorting center in Yinzhou District receives about 250 tons of recyclables, and the Gulin sorting center in Haishu District receives about 390 tons of recyclables monthly. For the 4 recyclables sorting centers, a raw material shop, a production shop, a product shop, an office, a power distribution room, a guard room, etc. will be built up to the 3-star green building standard. The layout plans of the sorting centers are generally consistent, being linear along the logistic flow, including the raw material, production and finished product areas. After bulky waste is sorted out at the stockyard, recyclables are sent to the manual sorting platform, bagged and then held. High-value recyclables like plastics and cardboards will be baled in batches for subsequent transport and disposal. The construction period of this subproject is from December 2022 to May 2024. Table 2-2 Overview of the Batch 2 subprojects and associated facilities Primary suppliers No. new Existing facility Associated facilities Land use and workers (drivers) - Haishu District landfill (closed down in August 2017, now The WWTP Reconstruction being a backup and associated and expansion landfill) facilities will To be purchased of the existing WWTP of Ningbo - Ningbo food waste be constructed through bidding, 1 leachate resource recycling base disposal plant on the existing mostly being drug treatment (operating) site. LA has suppliers station in the - Ningbo kitchen been Haishu landfill waste disposal plant completed. (operating) - Offsite sewer lines Plastics are from the proposed recyclable With a floor sorting centers area of 85.8 mainly, so the mu primary supplier is Centralized plastic The land is Dabashou Company, No existing 2 waste sorting and None currently which is one of the facility processing plant collective PIUs of the Project. woodland that Haijing Company has not been will employ drivers acquired. itself or through a third party for transport. Bulky and decoration waste is Bulky and decoration No existing 3 None LA completed from the smart waste disposal plant facility platform under Batch 1 subprojects, 14 Primary suppliers No. new Existing facility Associated facilities Land use and workers (drivers) and there is no primary supplier. Meijing Company will employ drivers itself or through a third party for transport. New Land reserved Zhenhai construction, None by the Recyclables are from District no existing government the smart facility community waste New cabins under Batch 1 Land reserved Beilun construction, subprojects, and None by the 4 District no existing there is no primary government Recyclables facility supplier. 4 sorting Jiangshan Existing site, Land reserved Dabashou Company centers Town, reconstructed by the will employ drivers None Yinzhou from existing government, itself or through a District facility now leased third party for transport. Dabashou Gulin Existing site, Land reserved Company will offer Town, reconstructed by the None trucks. Haishu from existing government, District facility now leased Source: PMO and fieldwork 2.2 Basic Information of Associated Facilities According to the definition in the Bank’s ESF, Haishu District landfill, Ningbo food waste disposal plant (Phase 2), Ningbo kitchen waste disposal plant (Phase 2) and offsite sewer lines are identified as associated facilities of Batch 2 subprojects. Wastewater from above facilities will be delivered to the WWTP in Batch 2 subprojects for treatment. According to the Bank’s ESF, during the SIA, Ningbo PMO and PIUs conducted a social audit on the associated facilities of Batch 2 subprojects. See Table 2-2. 2.3 Social Audit Findings During the SIA on Batch 2 subprojects, a social audit was conducted on the existing and associated facilities of Batch 2 subprojects. The main findings of the social audit are as follows: Except the 4 recyclables sorting centers, Batch 2 subprojects and associated facilities are all located in Ningbo resource recycling base in Dongqiao Town, Haishu District, with a planned area of 2.58 km2, and with no community within 1km around. Among Batch 2 subprojects, the existing facilities are the WWTP to be reconstructed, and two recyclables sorting centers (Jiangshan recyclable sorting center in Yinzhou District and Gulin recyclables sorting center in Haishu District). The existing facilities have no high social risk. 15 WWTP: It will be reconstructed on the existing site, and its LAR risks are “low”. The company has entered into labor contracts with laborers, is free from child and forced labor, and has established an EHS department and an OHS system, including the construction and maintenance of occupational health protection facilities, PPE, occupational health monitoring and evaluation, publicity, worker health monitoring, etc. Based on the field survey and interviews, OHS risks are “low”. However, the company’s LMP has no specific requirement for contractor and primary supplier management. Recyclables sorting centers: Based on the currently selected sites, the land used has been acquired and reserved by the government, but the land use plan needs to be adjusted due to nonconformity with the sanitation facility land plan, and the PIU has not received a certificate of land use right, so land use risks are “moderate”; since all recyclables are from smart waste separation cabins in communities, they are relatively clean. During waste sorting, worker occupational health risks are relatively minor, and the recyclable sorting centers have developed on-site operating regulations, and offer PPE for free to reduce occupational hazards. The PIU3 has established a sound LMP, but the social team found during the survey that some workers did not wear PPE (face masks, gloves, etc.) as required at work, and temporary workers might have not entered into a labor contract. Sound traffic risk control measures have been taken for vehicles, such as GPS speed monitoring, speed limit, voice prompt and anti- fatigue, and waste collection and transfer routes are kept away from densely populated communities. Therefore, traffic and community safety risks are “low”. Bulky and decoration waste disposal plant: It will be built on land acquired and reserved by the government, but it was found during the survey that some attachments on site were to be cleared, and the PIU (Meijing Company) had not received a certificate of land use right, so its LAR risks are “moderate”. For the associated facilities, a certificate of the right to use state-owned land has been obtained for the Haishu District landfill, Kaicheng Kitchen Waste Plant, and Shouchuang Kitchen Waste Plant, so its LAR risks are “low”. The company has entered into labor contracts with laborers, is free from child and forced labor, and has established an EHS department and an OHS system, including the construction and maintenance of occupational health protection facilities, PPE, occupational health monitoring and evaluation, publicity, worker health monitoring, etc. Based on the field survey and interviews, OHS risks are “low”. However, the company’s LMP has no specific requirement for contractor and primary supplier management. The Kaicheng Kitchen Waste Plant and Shouchuang Kitchen Waste Plant have developed strict waste collection and transfer management measures, and use fully sealed vehicles for transport via fixed routes, with minor community disturbances. The offsite sewer lines will be constructed by Qingyuan Company 4 using domestic counterpart funds, with a total length of about 2km. The offsite sewer lines will be constructed along Route B in the Ningbo resource recycling base, and there is no village or resident along the lines. The main social impact is temporary road occupation. 3 It is also a PIU of Batch 1 subprojects. 4 This company is the PIU of the WWTP in Batch 2 subprojects. 16 In addition, it is found that adequate information disclosure and public participation were conducted for the existing and associated facilities of Batch 2 subprojects during the EIA, social stability risk assessment, and LAR. However, compared to the Bank’s ESF, the existing and associated facilities of Batch 2 subprojects need to be strengthened in community health and safety, communication, grievance redress, etc., such as disclosing E&S monitoring reports to the public regularly (especially water and air quality data), and responding to community concerns positively. The social team has proposed the following suggestions on the basis of adequate communication with Ningbo PMO and PIUs to comply with both the domestic regulations and the Bank’s ESF: • Labor and working conditions: The PIUs and associated facility operators should improve the requirements for contracted and primary suppliers’ workers in the Labor Management Procedure (LMP), and strengthen the protection of their rights and obligations according to ESS2. • Community health and safety: The PIUs and associated facility operators should conduct E&S monitoring on Batch 2 subprojects, especially water and air quality, disclose monitoring data to nearby communities timely, and communicate with nearby communities regularly to handle their concerns (e.g., odor). • LAR: Before the beginning of construction, the PIUs should obtain a certificate of the right to use state-owned land or approval. • GRM: The PIUs and associated facility operators should improve the GRM, conduct information disclosure and public participation, and respond to community concerns positively according to ESS10 and the Stakeholder Engagement Plan (SEP) of the Project. Appendix 3 summarizes the issues identified in this social audit and the corresponding suggestions. See the Social Audit Report for the Batch 2 subprojects for more information. 17 3 Social Baseline 3.1 Socioeconomic Profile of Ningbo City Ningbo (also called Yong), is a sub-provincial level city in Zhejiang Province, a specifically designated city, an important seaport on the southeast coast of China approved by the State Council, and an economic center in the south wing of the Yangtze River Delta. As of 2019, the city has 6 districts, 2 counties, and 2 county-level cities under its jurisdiction, with a total area of 9,816 km2. In 2020, Ningbo’s GDP was 1.24087 trillion yuan, up 3.3% year on year, in which the added value of primary industries was 33.84 billion yuan, that of secondary industries 569.39 billion yuan, and that of tertiary industries 637.64 billion yuan, with a ratio of 2.7:45.9:51.4. By the end of 2020 5, Ningbo had a registered population of 6.137 million, including an urban registered population of 3.063 million, with a gender ratio of 110:100, a population growth rate of 7.12‰, and a natural population growth rate of 0.75‰. In 2020, the per capita disposable income of residents was 59,952 yuan, up 5.2% year on year, that of urban residents 68,008 yuan, up 4.8%, and that of rural residents 39,132 yuan, up 6.8%; the per capita nonproductive expenditure of residents was 34,455 yuan, up 1.5%, that of urban residents 38,702 yuan, up 1.1%, and that of rural residents 23,481 yuan, up 3.0%. By the end of 2020, among the 9.404 million permanent residents of Ningbo, the migrant population was 2.457 million, and the total registered population was 6.137 million. The urbanization rate of Ningbo was 78%6 The female population was 3.108 million, accounting for 50.6% of the registered population. The senior population (over 60 years old) was 1.56 million7, accounting for 25.64% of the registered population. See Table 3-1. Ningbo is a typical area where there are scattering ethnic minority households without concentrated communities. As of the end of 2020, the city has 53 ethnic minorities (no Uzbek and Loba), with a minority population of more than 537,000 (6.29% of total permanent population). Among this population, about 36,000 people are local registered residents (0.59% of total registered population), more than 501,000 are floating population. The Miao, Tujia, Buyi, Zhuang people are among the ethnic groups with most people. There is no ethnic minority area in Ningbo. 5 Source: 2020 Statistical Bulletin on the National Economic and Social Development in Ningbo 6 Source: 2019 Statistical Bulletin on the National Economic and Social Development in Ningbo 7 Source: Ningbo Municipal Seniors Committee 18 Table 3-1 Socioeconomic Profile of the Project Area (2020) Per capita Sub- Residential Resident Flowing Registered Female Minority Urbanization MLS disposable Division districts / Communities areas population population population population population rate population income townships (yuan) Unit / / / 0,000 0,000 0,000 0,000 / % / yuan Zhejiang / / / 5850 851 4999 2429.5 2217714 70 655000 52397 Province Ningbo City 100 612 2497 940.4 245.7 613.7 310.8 537000 78 59000 59952 Project area 64 442 1763 505.42 138.7 304.7 151.4 19.94 70 10909 61151 total Yinzhou 20 156 630 160.9 49.8 95.5 49.0 48681 79.8 2595 73860 District Haishu District 17 101 376 104.12 31.8 63.7 32.4 43013 84.2 2507 64838 Zhenhai 6 44 194 51.0 17.5 27.0 12.8 19725 62.8 908 56346 District Beilun District 10 49 291 82.9 21 43.5 20.7 42181 67.9 2048 62775 Jiangbei 8 66 187 48.8 15 27.1 13.9 12893 80.2 1344 62123 District Fenghua 3 26 85 57.7 3.6 47.9 22.6 32973 45.6 1588 46964 District Source: 2020 Statistical Bulletins on the National Economic and Social Development of Zhejiang Province and districts (data of High-tech Development Zone and the Dongqian Lake area included in that of Yinzhou District 19 3.2 Socioeconomic Profile of the Project Area The proposed subprojects are located in Ningbo resource recycling base, and the social sensitive sites around the Project (environmental impacts and NIMBY effect mainly) mainly include Xuanpei, Bailiangqiao, Huijiang, Yushantou and Sanli Villages, Qiaodong Town, Haishu District. The Xuanpei Village Committee is 70m southeast of the Ningbo resource recycling base. It has not been relocated but is no longer in service. Therefore, the social sensitive site closest to the base is Bailiangqiao Village about 1km north of the base. Figure 3-1 Distribution of Settlements around the Ningbo Resource Recycling Base 3.2.1 Dongqiao Town Dongqiao Town 8 is located in southern Haishu District, with a land area of 35.39 km2, governing 19 villages and one community, and a resident population of about 52,000. The town generates more than half of the city’s municipal waste, and has received many honors for waste disposal. In 2019 and 2020, the town’s gross industrial output value exceeded 10 billion yuan. In Q1 2021, the town’s fiscal revenue was 208 million yuan, up 28.5% year on year, general public budgetary revenue 107 million yuan, up 11.4%, and GDP 1.135 billion yuan, up 36.5%. 3.2.2 Affected Villages 1) Xuanpei Village Xuanpei Village has 7 groups, and 535 households with 1,271 persons, and was merged from Xuanjia and Pei’ao Villages in 2004. It is a civilized, ecological, hygienic and beautiful village. 8 Source: Qiaodong Town Government 20 To accelerate landfill construction, Xuanpei Village was moved to Dongxuan Garden in 2015 and 2018, and 6 groups (except Pei’ao) signed relocation agreements in June 2018. Figure 3-2 Xuanpei Village (Left), Bailiangqiao Village (Right) 2) Bailiangqiao Village Bailiangqiao Village was merged from Bailiang and Liangqiao Village. It has a registered population of 1,380 and a floating population of over 1,000. In recent years, Bailiangqiao Village has been affected by frequent LA. About 70% of the land acquired for the landfill is from Bailiangqiao Village, including 100 mu of land and 300 mu of forest, and 100 mu of land has been acquired for the Ningbo-Jinhua Expressway. Currently, the village has 2,200 mu of land, including about of 500 mu of hilly land. Cultivated land has been transferred to major cultivation households, and the proportion of agricultural income to household income is low. Bailiangqiao Village has over 60 enterprises, including plastics, automobile parts, clothes, etc. The largest enterprise Liangqiao Rice Co., Ltd. has a workforce of over 100 and an annual turnover of 1 billion yuan. 7 or 8 enterprises have an annual turnover of over 30 million yuan. 3) Huijiang Village Huijiang Village has 6 groups, a registered population of over 1,600, and a land area of 2,014 mu, including 1,244 mu of cultivated land, in which 34 mu of land and 409 mu of forest has been acquired. The main crops are paddy rice and watermelon. 21 Figure 3-3 Huijiang Village (Left), Yushantou Village (Right) 4) Yushantou Village Yushantou Village is located in southwestern Qiaodong Town, and enjoys convenient traffic. The village has a registered population of 1,108, a floating population of over 1,000, 761 mu of cultivated land and 564 mu of forest. 60% of the village’s land has been acquired, and the remaining cultivated land transferred to one major cultivation house for paddy rice cultivation. Per capita annual income is 25,900 yuan, in which agricultural income accounts for about 15%. There are 62 enterprises in the village, dealing with machinery and food mainly. There are 3 industrial zones in the village, namely Changfeng, Maojia and Qiaoqian. 5) Sanli Village Sanli Village is located in southern Qiaodong Town, merged from Sanjia and Lijiada Villages, and enjoys convenient traffic. The village has a population of 810, and 1,800 mu of cultivated land, which is transferred to one major cultivation household, and 1,500 mu of forest. There are over 30 enterprises in the village, with a total annual output value of over 100 million yuan. Figure 3-4 Sanli Village 3.3 Current Situation of Waste Sorting There are 4 recyclables sorting centers run by NBSMC Renewable Resources Technology Co., Ltd. in Ningbo. Seven recyclables sorting centers are to be constructed under the Project, including one demonstration, to dispose of recyclable waste of the whole city, and serve 120 residents in 8 districts covered by the Project. The existing 4 sorting centers run by NBSMC Renewable Resources Technology Co., Ltd. are: Jiangshan sorting center (with a floor area of about 5,382 m2), Zhenhai District sorting center (with a floor area of about 3,300 m2), Beilun District sorting center (with a floor area of about 7,000 m2), and Haishu District sorting center. Since these sorting centers do not involve cleaning, so no wastewater treatment equipment is provided. They only sort, pack, store, load and unload recyclables, and do not generate considerable wastewater, waste gases, odor and noise. Table 3-2 Existing Recyclables Sorting Centers 22 Sorting Operating Building No. Name Address Existing land use capacity (t) area (m2) area (m2) Jiangshan sorting South of Jingting Bus 1 center in Yinzhou Stop in Jiangshan 36000 6000 3600 Land lease District Town Zhenhai District Free use of old 2 No.131 Zhaolong Road 30000 3500 3000 sorting center workshop No.252 Hengpu Beilun District Free use of old 3 Village, Xinqi Sub- 60000 7000 6000 sorting center workshop district Gulin sorting center Guoxia Village, Gulin 4 38000 8500 3800 Land lease in Haishu District Town Source: Ningbo PMO, PIUs and fieldwork summary 3.4 Current Situation of Municipal Solid Waste Collection and Transfer Currently, kitchen waste in Ningbo still mix with plastic waste when it is transferred by trucks to the disposal plant for anaerobic composting. Anaerobic treated compost still contains a lot of microplastics, which may enter soil, sediments and freshwater with compost, thereby generating long-term negative impacts on ecosystems, and flowing into seas through groundwater or rivers. Other types of waste are also mixed with a lot of plastic waste, and would be transferred to transfer stations, and then to the incineration plant after compression. Recyclable waste includes waste paper, waste plastics, waste textiles, waste glass, etc. Such waste is transferred by vans to the recyclable sorting center simple manual sorting and compression, and then sold to terminal waste re-utilization enterprises. Bulky waste is collected in a door-to-door manner through online appointment, and transferred by the sorting center by vans. Due to insufficient dismantling capacity, bulky waste, decoration waste, waste household appliances cannot be recovered and disposed of effectively, so that plastics contained cannot be separated and treated effectively, and large quantities of recyclable plastics cannot be utilized effectively. In the Project, waste of all kinds can be utilized effectively through all-category smart waste cabins deployed in communities. The cabins with AI first judge if kitchen and other waste dumped by residents contain plastics, give feedback to residents to improve waste sorting quality, and recover plastic bottles, low-value dirty plastics and daily chemical plastic waste through 3 dedicated recovery bins, thereby improving waste sorting accuracy effectively. In addition, the smart solid waste management system under the Project will dispatch recyclable trucks, transfer all types of (plastic bottles, low-value dirty plastics, daily chemical plastic waste, waste paper, waste glass, waste metals, waste textiles, etc.) from holding sites to the to-be constructed or reconstructed recyclable sorting centers for: (1) semi-automatic unloading; (2) transfer to different conveyor belts; (3) manual + automatic sorting on conveyor belts; (4) compression, packing and storage; and (5) preparation for sale (where plastic waste is transferred to the centralized plastic waste sorting and processing plant under the Project). In addition, the above system will realize the door-to-door recovery of waste household 23 appliances, bulky waste and decoration waste through appointment, where waste household appliances and bulky waste will be transferred by vans, and decoration waste will be transferred by dedicated recovery bins and hook arm trucks. Waste household appliances will be dismantled at the dismantling center, and plastic waste disposed of at the centralized plastic waste sorting and processing plant under the Project, and other dismantled materials sold or delivered to waste utilization and hazardous waste disposal terminals. After bulky and decoration waste is sorted at the bulky and decoration waste disposal plant under the Project, separated plastic waste will be delivered to the centralized plastic waste sorting and processing plant under the Project to make recycled building aggregates, recycled bricks, RDF, etc. 3.5 Profile of the Ningbo Resource Recycling Base Ningbo resource recycling base that broke ground in 2013 is located in southern Qiaodong Town, with a total planned area of 2.58 km2, based on the former Ningbo solid waste disposal center. The base is responsible for the disposal and recycling of kitchen waste in the urban center, and other urban domestic waste in Haishu and Yinzhou Districts. Three projects in the base have been put into operation, which are the Haishu District waste-to-energy plant (design capacity 2,250t/d), Ningbo kitchen waste disposal plant (Phase 1) (total capacity 660t/d, 440t/d in Phase 1), and Ningbo food waste disposal plant (Phase 1) (total capacity 800t/d, 400t/d in Phase 1). While improving the resource recycling industry in the core zone, a surrounding development zone is taking form. The Haishu District landfill (Phase 2), Ningbo kitchen waste disposal plant (Phase 2), and Ningbo food waste disposal plant (Phase 2) are planned. In addition, some high-level resource recycling projects are planned on hilly land around the landfill, and the space east of the kitchen waste disposal plant, such as waste-to-energy, construction waste recycling, low-value recycled resource decomposition and utilization, and waste plastic cleaning and reuse. The base will be able to dispose of, recycle and reuse various types of solid waste, such as domestic waste, construction waste, landscaping waste, bulky waste and sludge. 24 Figure 3-5 Plan of the Ningbo Resource Recycling Base 3.6 Practical Experience in NIMBY Risk Mitigation of the Ningbo Resource Recycling Base Ningbo resource recycling base is an important achievement of the previous Bank waste management project in Ningbo 9 , which has been selected as one of the Batch 2 PPP demonstration projects of the Ministry of Finance, a key provincial, municipal and district project, a provincial industrial tourism demonstration base, and a municipal popular science base, and received the Best Practice Award of the Circular Economy of China in 2017. The early- stage NIMBY risk mitigation experience of the base has been extended throughout the province by the provincial government as a typical case. In March 2020, Dongqiao Waste-to-energy Project Social team was established under the Haishu District Resource Recycling Base Leading Group, responsible for policy processing, social stability, procedural coordination, etc., which improved the environmental awareness of the base in nearby sensitive communities, and laid a good foundation of social stability for Batch 2 subprojects. For nearby residents’ common concerns about long-term development, the municipal and district governments have explored compensation policies for interest balancing, and a long- 9 During 2013-2020, the World Bank-financed Ningbo Municipal Solid Waste Minimization and Recycling Project (P123323) was implemented. 25 term ecological compensation mechanism for domestic waste input and output areas. For example, a domestic waste output district contributes to environmental improvement funds based on waste output, and such funds are disbursed to the input district for landscaping, infrastructure construction and maintenance, economic development, publicity and supervision, etc. around the waste treatment facility. In addition, the PIU will set aside a certain portion from the gross investment to create benefits for nearby residents. 26 4 Social Management Policy Framework The implementation of the Project needs to comply with the requirements of the Bank's ESF, and also needs to comply with China's domestic laws and regulations in the field of E&S risk management. This chapter summarizes the applicable requirements of the Bank ESSs in the Project, and China's existing E&S management laws and regulations, technical specifications, and applicable standards that are most relevant to the Project, compares these with the Bank ESSs, and proposes remedies for gaps. The social team has identified the relevance of the ESSs with Batch 2 subprojects: • Batch 2 subprojects do not involve any minority community, so ESS7 shall not apply. • The construction and operation of Batch 2 subprojects involve LAR risks, OHS risks, community health and safety risks, NIMBY risks, etc., which require extensive public support and participation, and a smooth GRM. Therefore, the applicable ESSs include ESS1 (Assessment and Management of Environmental Risks and Impacts), ESS4 (Community Health and Safety), ESS5 (Land Acquisition, Restriction on Land Use and Involuntary Resettlement), and ESS10 (Stakeholder Engagement and Information Disclosure). In addition, these subprojects involve direct workers, contract workers and primary suppliers’ workers, so ESS2 (Labor and Working Conditions) is also relevant. Table 4-1 Applicability of ESSs Centralized plastic waste sorting Bulky and decoration Recyclables sorting ESS WWTP and processing plant waste disposal plant centers ESS1 √ √ √ √ ESS2 √ √ √ √ ESS4 √ √ √ √ ESS5 √ √ √ √ ESS7 Not applicable ESS9 Not applicable ESS10 √ √ √ √ 4.1 Introduction 4.1.1 Social Risk Management System Appropriate social management systems have been established for investment projects in China. The social risk management system of a project requires that the project must aligned 27 with the basic interests of most people, and major decisions, major fixed asset investments and LA should be subject to social stability risk assessment. A sound management body has been established for project social stability risk assessment in China. The owners should prepare or appoint a consulting agency to prepare the social stability risk assessment report; and the local government should review and evaluate such report. See Table 4-2. Table 4-2 Legal Framework for Social Risk Management Consistency ESS No. Name Version Applicability evaluation and requirements remedies Major administrative decisions shall be made under the principle of democratic decision-making, opinions shall be fully solicited from all parties, Interim and it shall be guaranteed that the Regulations on people participate in decision-making Major 1. 2019 through various channels and forms. Administrative Partly If any major administrative policy may consistent Decision-Making affect social stability and public Procedures security adversely, the undertaker or The Bank requires Since China any other agency responsible for risk that the borrower requires that a assessment shall assess the risk should conduct an social stability controllability of the draft decision. E&S assessment risk assessment according to ESS1 report be China requires that a social stability to evaluate, prepared for risk assessment be conducted around identify and major projects, the legitimacy, rationality, feasibility minimize E&S and the Bank and controllability of a project, and risks and impacts requires that an major decisions and surveys should at all stages. Social Stability SIA report be cover all local stakeholders, and fully Risk Assessment prepared, so an collect their opinions, including 2. for Major Fixed 2012 SIA report has rational and irrational, realistic and Asset Investment been prepared. potential needs. Projects On the basis of a risk survey, risk factors potentially leading to social stability risks shall be analyzed in cases of stakeholder objection to propose mitigation measures. 4.1.2 LAR For LAR and compensation, etc., China has established a complete legal framework and policy system, including the Land Administration Law of the PRC (3rd amendment in 2019), and the Regulations on the Expropriation of Buildings on State-owned Land and Compensation (Decree No.590 of the State Council, 2011). Within this framework, local governments have promulgated local regulations and policies. 28 Table 4-3 Legal Framework for LAR Consistency ESS No. Name Version Applicability evaluation and requirements remedies If land collectively owned by farmers is to be acquired for public interests, ESS5 proposes to acquisition may be implemented avoid or according to law. minimize involuntary If a people’s government at or above resettlement. the county level is to apply for land Timely acquisition, it shall conduct a current compensation Partly consistent status survey and a social stability risk assessment, and disclose the for loss of assets range and purpose of acquisition, at replacement APs are current status, compensation rate, should be identified in resettlement mode, social security, provided to different ways. etc. in the township (town), village ensure that In China, illegal and village group for at least 30 dayslivelihoods of buildings are not to collect comments from the affected displaced compensated rural collective economic persons are for. organization and its members, village improved or at committee and other interested least restored to pre- Except large and parties. medium water displacement If most members of the affected rural resources and levels. collective economic organization hydropower think that the land compensation and Affected persons projects, no RAP Land who have no resettlement program does not is to be 1 Administration 2019 conform to the laws and regulations, recognizable prepared, and Law of the PRC the people’s government at or above legal right to independent the county level shall organize a land or assets resettlement public hearing, and modify the should be subject M&E is not program according to the laws, to compensation required. regulations and public hearing. and resettlement. Owners or users of the land to be An RAP has been acquired shall, within the time limit prepared as specified in the announcement, go Depending on required by the through compensation registration the degree of Bank, and on the strength of the real estate impacts, a independent ownership certificate. The people’s comprehensive resettlement government at or above the county or abbreviated M&E will be level shall organize the department RAP will be conducted concerned to estimate the relevant prepared. during costs and make them fully available, implementation. enter into compensation and Independent resettlement agreements with the resettlement owners and users of the land to be M&E will be acquired. conducted The people’s government at or above during the county level shall apply for land implementation. acquisition only when the 29 Consistency ESS No. Name Version Applicability evaluation and requirements remedies preparatory work has been completed. Fair and reasonable compensation shall be granted for land acquisition to ensure that the living standard of the affected farmers is not reduced, and their long-term livelihoods are secured. Where a building of any entity or individual on state-owned land is expropriated for public interest, the owner of the expropriated building (hereinafter referred to as the “owner”) shall be fairly compensated. The principle of “democratic decision-making, due process and open results” shall be followed in the building expropriation and Regulations on the compensation. Expropriation of 2 Buildings on 2011 The compensation for the value of State-owned Land houses to be expropriated shall not and Compensation be less than the market price of the real estate comparable to the houses to be expropriated on the date of the public notice of the house expropriation decisions. The value of the houses to be expropriated shall be assessed and determined by real estate appraisal agencies with appropriate qualifications in accordance with the procedures for evaluating houses to be expropriated. In case of land acquisition, the municipal (county, city) government shall organize a social stability risk assessment, implement risk prevention measures, and develop a Regulations of contingency plan. Zhejiang Province on the Land After the contingency plan is drafted, 3 Acquisition 2020 the municipal (county, city) Procedure (for government shall disclose it on its Trial website, and in the township (town), Implementation) village and village group for at least 30 days to collect comments from the affected rural collective economic organization and its members, village committee and other interested parties. The results of the current 30 Consistency ESS No. Name Version Applicability evaluation and requirements remedies status survey shall be disclosed along with the compensation and resettlement program for land acquisition. If more than half of members of the affected rural collective economic organization think that the land compensation and resettlement program does not conform to the laws and regulations, the municipal (county, city) shall organize a public hearing. For acquired collectively owned land, the land compensation fees, resettlement subsidy, and compensation fees for rural residential houses, other ground attachments, young crops, etc. shall Measures of be paid timely and fully according to Zhejiang Province law, and social security costs for the for Land affected farmers disbursed to Acquisition providing basic living security, and 4 Compensation and 2009 protect their lawful rights and the Basic Living interests. Security of Land- Municipal or county government expropriated shall establish a social security farmers system in accordance herewith to protect the lawful rights and interests of the affected farmers practically. Municipal or county land and resources authority shall draft and implement the land acquisition compensation program. 4.1.3 Labor Management For labor management, employers should sign employment contracts with laborers on a voluntary basis to define both parties’ rights and obligations. The Labor Law of the PRC (amended in 2018) and the Labor Contract Law (2012) apply. China’s laws make provisions on wages, working hours, labor protection and labor disputes, and prohibit the use of forced labor and/or child labor, fully consistent with the requirements of ESS2. Considering the nature of the Project, China’s all-round provisions on labor protection, and the increasing labor supervision of local governments, there is almost no risk of forced and child labor for project workers. 31 In addition, China’s laws and regulations make provisions on sexual harassment and sex assault: Article 38 of the Constitution stipulates, the personal dignity of citizens of the People's Republic of China is inviolable. Insult, libel, false charge or frame-up directed against citizens by any means is prohibited. Articles 101 and 120 of the General Principles of the Civil Law stipulate, citizens and legal persons shall enjoy the right of reputation. The personality of citizens shall be protected by law, and the use of insults, libel or other means to damage the reputation of citizens or legal persons shall be prohibited. The citizen shall have the right to demand that the infringement be stopped, his reputation rehabilitated, the ill effects eliminated and an apology made; he may also demand compensation for losses. Article 236 of the Criminal Law stipulates, whoever rapes a woman by violence, coercion or any other means shall be sentenced to fixed-term imprisonment of not less than three years but not more than 10 years; Article 237 stipulates, whoever acts indecently against or insults a woman by violence, coercion or any other forcible means shall be sentenced to fixed-term imprisonment of not more than five years or criminal detention. Article 40 of the Law on the Protection of Women's Rights and Interests stipulates, sexual harassment against women is banned. The victims shall be entitled to complain to the entity or the relevant organs. Article 58 stipulates, if anyone commits sexual harassment or family violence against a woman to violate this Law, and if his act constitutes a violation of the public security administration, the victim may require the public security organ to give the violator an administrative punishment or may initiate a civil action in the people's court. Article 44 of the Public Security Administration Punishments Law stipulates, anyone who acts indecently towards any person or deliberately expose his body at a public place shall be detained for not less than 5 days but not more than 10 days if the circumstances are absolutely vile. Anyone who acts indecently towards a disabled person, mentally insane patient, or minor under the age of 14, or who commits any other severe violation shall be detained for not less than 10 days but not more than 15 days. The Special Provisions on Labor Protection of Female Employees, and the Measures for the Labor Protection of Female Workers of Zhejiang Province also stipulate, the employer shall prevent sexual harassment on female workers, and protect their privacy when handling their appeals. See Table 4-4. 32 Table 4-4 Legal Framework for Labor Management Consistency ESS No. Name Version Applicability evaluation and requirements remedies China’s labor The scope of policies do not This Law applies to enterprises, application of conduct individually-owned economic ESS2 depends on classification organizations (hereinafter referred the type of according to ESS2, to as the employer) and laborers employment and do not require who form a labor relationship with between the the preparation of Labor Law of the Amended them within the boundary of the borrower and 1 an LMP. To ensure PRC in 2018 Peoples Republic of China. State project workers. consistency, all departments, institutional The borrower workers will be organizations and social groups should develop divided into four and laborers who form a labor and implement a types, and an LMP relationship with them shall follow written LMP prepared for the this Law. applicable to the identified labor Project. risks. A labor contract should be entered into to define both parties’ rights ESS2 requires and obligations. that the When an employer hires an borrower should employee, it shall faithfully inform provide a him of the work contents, document that conditions and location, specifies the occupational harm, work safety employment state, remuneration, and other terms and information which the employee conditions to Labor Law of the Amended requires to be informed. project workers, PRC in 2018 Where an employer formulates, and pay them 2 Consistent Labor Contract Amended amends or decides rules or according to the Law of the PRC in 2012 important events which are state laws and directly related to the interests of LMP. As the employees, such rules or required by the important events shall be state laws or discussed at the meeting of LMP, project employees' representatives or the workers should general meeting of all employees, receive a and the employer shall negotiate termination slip with the labor union or the and a severance employees' representatives on an pay list timely. equal basis. Civil servants shall be managed on ESS2 requires the basis of openness, equality and that if any civil competition, and in accordance servant works in Civil Servant Law Amended with statutory authorities, support of the 3 Consistent of the PRC in 2018 conditions, standards and project (whether procedures. The government shall full-time or part- train civil servants based on their time), his/her job requirements. A civil servant’s public sector 33 Consistency ESS No. Name Version Applicability evaluation and requirements remedies salary shall include the basic employment salary, allowances, subsidies and agreement bonuses. applies, unless there is a valid Written employment contracts transfer shall be signed with civil servants certificate Provisions on the on an equal, voluntary and indicating that Administration of consensual basis to define both he/she has been Contractual Civil parties’ rights and obligations. 4 2017 employed for the Servants (for The labor contract shall specify the Project. Trial term, job requirements, labor Implementation) conditions, salaries, benefits and insurance, termination, liability for breach, etc. China has a sound labor dispute mediation system through a corporate committee under the formal trade union system. Workers may also appeal through the labor bureau directly. Labor security supervision shall be conducted over enterprises and individual industrial and Labor Law of the commercial households PRC (hereinafter referred to as the employing entities). Labor security ESS2 requires Amended supervision shall be conducted Regulations on that a GRM must in 2018 over job intermediary institutions, Labor Security be established occupational skills training Supervision for all direct and 5 institutions, and occupational skills Consistent 2004 contracted assessment and authentication workers to file Labor Protection institutions. grievances about Supervision 2005 The labor security supervision the workplace. Regulations of over an employing entity shall be Zhejiang under the jurisdiction of the labor Province security administration at the county level or at the level of a city divided into districts at the locality of employment by the employing entity. Labor security supervision shall be conducted in such forms as routine inspection, written review, special inspection, and complaint investigation. Trade Union Law Amended All physical and mental workers of ESS2 specifies of the PRC in 2009 enterprises and public institutions that if the laws 6 Consistent shall have the right to join and of the borrower organize trade unions, regardless allow workers to 34 Consistency ESS No. Name Version Applicability evaluation and requirements remedies Measures of Amended of ethnic group, race, gender, organize and Zhejiang in 2002 occupation, religion and education. bargain freely, Province for the An enterprise or public institution such laws will Implementation shall establish a trade union apply. In this of the Trade according to law within one year case, a worker Union Law of the after opening. organization will PRC The trade union shall urge be established enterprises and public institutions according to law, to cover endowment, and information unemployment, medical, injury, required for maternity and other social effective insurance for workers according to negotiation law. provided timely. The trade union shall assist enterprises and public institutions in collective welfare, salary payment, social insurance, labor safety and health, etc. ESS2 requires In China, there are over 100 that OHS technical standards on measures be occupational safety and disease designed and control, which are based on implemented to: industry best practices. (a) identify Law of the PRC potential Employers shall establish a on Prevention hazards to complete occupational health and and Control of project workers, safety system, strictly enforce Occupational especially life relevant measures and standards, Diseases threatening and offer relevant training to ones; (b) offer Amended workers. preventive and Occupational in 2018 A mechanism of employer protective Disease responsibility, authority measures; (c) Prevention and 7 2017 regulation, industry self-discipline, train project Consistent Control Plan of worker participation and public workers, and Zhejiang participation shall be established keep training Province (2017- Amended for occupational disease records; (d) 2020) in 2016 prevention and control. record and Workers shall be entitled to report Work Safety occupational health protection. occupational Regulations of accidents, The employer shall establish a Zhejiang diseases and sound responsibility system for Province incidents; (e) occupational disease prevention and control, and the trade union prevent, prepare shall supervise such work. for and respond to emergencies; The employer must cover injury and (f) take insurance according to law. remedies for adverse impacts, 35 Consistency ESS No. Name Version Applicability evaluation and requirements remedies such as occupational injuries, deaths, disabilities and diseases. Special protection shall be offered to women and children, and they shall not be hired for dangerous jobs. Law of the PRC Women shall enjoy the same labor on the Protection and social security rights as men, of Rights and and receive equal pay for equal work. ESS2 proposes Interests of appropriate Women The employer shall protect protection and women’s safety and health at work, assistance Amended and not assign unsuitable jobs to Special measures to in 2018 women. Women enjoy special Provisions on address the protection during menstruation, Labor Protection vulnerability of 8 pregnancy, lying-in and Consistent of Female 2012 certain worker breastfeeding periods. Employees groups, The employer shall prevent sexual including 2017 harassment on female workers, women, the Measures for the and protect their privacy when disabled, Labor Protection handling their appeals. migrant workers of Female In Zhejiang Province, the human and child labor. Workers of resources and social security, work Zhejiang safety management, health, and Province family planning departments of governments at or above the county level should protect and manage female workers’ labor protection properly. ESS2 requires that any child Chinese and Zhejiang policies under the prohibit any organization or minimum age individual to refer anyone under Measures of should be 16 years to any job. Governments Zhejiang employed for 9 2008 at or above the county level shall Consistent Province on Child project-related strengthen leadership in this Labor Prohibition work. Such age is respect, and establish a sound usually 14 year, coordination system and a sound unless otherwise evaluation system. stipulated in state laws. Forced labor shall be prohibited. Labor Law of the Amended ESS2 prohibits 10 Anyone who uses laborer by force, Consistent PRC in 2018 forced labor. threat or illegal restriction of 36 Consistency ESS No. Name Version Applicability evaluation and requirements remedies personal freedom shall be prosecuted criminally. ESS2 requires that a system for Zhejiang has established a risk reviewing OHS screening and early warning performance and mechanism, and conducts publicity working and training. Work Injury environment Insurance costs shall be disbursed Insurance regularly be from the work injury insurance 11 Regulations of 2017 developed, Consistent fund, subject to budgetary Zhejiang including management, and managed Province identifying risks, according to the applicable state implementing provisions. Injured workers shall and prioritizing be entitled to medical treatment measures, and and recuperation benefits. evaluating results. In Zhejiang Province, a professional technician shall receive off-job continuing Consistent education for not less than 12 days ESS2 requires per annum, relevant costs shall be Regulations on that project Professional borne by the employer, and he/she the Continuing workers be technicians in shall receive the same salary, Education of employed fairly Zhejiang not only benefits and insurance as if he/she 12 Professional 2003 and justly, receive OHS were on the job. Technicians of including training regularly, When his/her right to receive Zhejiang recruitment, but also equal continuing education is infringed, Province remuneration opportunities to he/she shall have the right to file and training. receive continuing an appeal with the competent education. authorities, which shall make a disposition and give a written reply within 30 days. China requires that novel The 2020 Annual coronavirus-infected patients, Report of the suspected patients and close Bank proposes Notice of the contacts during treatment or that measures Ministry of medical treatment, and enterprise better suited to Human workers who are unable to work the increasingly Resources and regularly shall be paid, and their diversified and Social Security on 13 2020 labor contracts shall not be changing Consistent Handling Labor terminated pursuant to Articles 40 working Relations during and 41 of the Labor Contract Law. environment be COVID-19 If an enterprise has any difficulty taken for labor Prevention and in production or management due protection and Control Properly to the pandemic, it may stabilize social security, the job of a worker by and calls on all remuneration adjustment, job governments to 37 Consistency ESS No. Name Version Applicability evaluation and requirements remedies rotation or reduction of working offer social hours, and avoid downsizing security to all where possible. If an enterprise isworkers, shut down for not more than a pay whether they are period, it shall pay workers employed in formal or according to labor contracts; if it is shut down for more than a pay informal sectors. period, and a worker works In view of the normally, the salary shall not be destructive less than the local minimum salary,impacts of the or if a worker does not work pandemic on the normally, living expenses shall be poor, especially paid. those in informal sectors, and the importance of practicing this labor protection mode is more significant than Ningbo encourages enterprises to ever. The expand recruitment by various document Notice of the means. For each additional insured “Saving Lives, Ningbo Municipal Expanding worker of an enterprise after the Human Influence and end of the pandemic, the Resources and enterprise shall receive a subsidy Getting on the Social Security Right Track” of 500 yuan per capita, but the Bureau on release by the total subsidy shall not exceed 14 Offering 2020 Bank’s Executive 300,000 yuan. Employee Board in June Enterprises shall be guided to Services to handle salary payment and leaves 2020 stresses, Enterprises “Education, properly during pandemic during COVID-19 employment and prevention and control by such Prevention and health services measures as salary adjustment, Control Properly flexible working hours and remote should be work. utilized to help people restore livelihoods, and enterprises and public institutions gain a foothold.” 4.1.4 Information Disclosure and Public Participation For information disclosure, public participation and GRM, the state, provincial and municipal laws, regulations and policies impose strict requirements on information disclosure on the approval and implementation of major construction projects, land acquisition compensation, government resource allocation, etc., and require that public participation channels be kept smooth. 38 A systematic complaint handling system has been established in Ningbo. Citizens, legal persons or other organizations shall submit suggestions, opinions or appeal requests to governments at all levels by way of letter, e-mail, telephone or visit, etc., to be handled by competent administrative authorities according to law. See Table 4-5. Table 4-5 Legal Framework for Information Disclosure and Public Participation Consistency ESS No. Name Version Applicability evaluation and requirements remedies Measures for Effective The state encourages the public ESS10 requires Partly consistent Public from participation in the assessment of that all China’s policies Participation in January environmental impacts. The stakeholders be do not require Environmental 2019 construction entity shall seek the consulted the development Impact opinions of citizens, legal persons meaningfully, and Assessment and other organizations within the timely, relevant, implementation scope of environmental impact understandable of an SEP that assessment in accordance with the and accessible describes the law. information times and Information disclosure shall be provided to the methods of conducted by Web, newspaper and stakeholders, contact with announcement. and they are not stakeholders in manipulated or the whole project Before submitting the EIA report to threatened. lifecycle. the ecology and environment authority for approval, the The SEP will be The borrower construction agency shall prepare a developed and should conduct 1 public participation note. The ecology implemented at stakeholder and environment authority shall the project level engagement in disclose information to the public to describe the the whole project through its website or otherwise for times and lifecycle, and not less than 10 working days. methods of include women contact with and low-income stakeholders in population to the whole provide timely, project lifecycle. relevant, understandable and accessible information to stakeholders. The GRM is also included in the SEP. Opinions of the 2017 Except national secrets, trade secrets, ESS10 requires Consistent General Office of personal privacy, and other content the borrower to the State Council which is not disclosed according to disclose project 2019 on Advancing the law, the information in the information, so 2 Disclosure of process of the approval and that Government 2017 implementation of major stakeholders are Information in the construction projects shall be aware of project Field of Approval disclosed to the public as much as risks, impacts 2019 and possible so as to improve the and potential 39 Consistency ESS No. Name Version Applicability evaluation and requirements remedies Implementation of 2019 transparency and efficiency of the opportunities. Major approval and implementation of Before project Construction projects, mainly including approval assessment by Projects service information, approval result the Bank, Opinions of the information, invitation for bid and project General Office of bidding information, land information the Zhejiang expropriation information, including risks, Provincial information on material modification participation Government on of design, construction-related and grievance Advancing information, quality safety redress should Disclosure of supervision information, and be disclosed to Government information relating to completion of stakeholders Information in the construction, shall be publicly during the Field of Approval disclosed in priority. period of and China is advancing the building of meaningful Implementation of province-level land acquisition consultation on Major information disclosure platforms to the project Construction ensure that land-expropriated design. Projects farmers can acquire relevant Opinions of the information efficiently and General Office of conveniently. Matters to be disclosed the State Council include 4 Level-1 matters and 10 on Advancing Level-2 ones. Disclosure of In the Project, the allocation of waste Government sorting facilities falls into public Information in the resource allocation, and the state and Field of Approval provincial regulations also make and provisions on information disclosure: Implementation of Basic, allocation (transaction), Public Resource bidding, contract signing and Allocation performance information of public Opinions of the resource projects shall be disclosed General Office of by competent authorities and the Zhejiang enterprises respectively along with Provincial law violations and discredit acts. Government on Advancing Disclosure of Government Information in the Field of Approval and Implementation of Public Resource Allocation Opinions of the 2016 China and Zhejiang advance ESS10 requires Consistent General Office of government affairs disclosure that all 3 the State Council comprehensively through the stakeholders be 2016 on Advancing statutory procedure of public consulted 40 Consistency ESS No. Name Version Applicability evaluation and requirements remedies Disclosure of participation, expert demonstration, meaningfully to Government risk assessment, legality review and provide timely, Information collective decision-making. Decisions, relevant, Opinions of the implementation, management, understandable General Office of services and results shall be and accessible the Zhejiang disclosed. information to Provincial Promote government data opening, stakeholders, Government on strengthen policy interpretation and and they be free Advancing expand public participation. from Disclosure of Government affairs disclosure shall manipulation, Government be included in the performance threat or Affairs evaluation system, and third-party discrimination. Comprehensively agencies encouraged to evaluate disclosure quality and effectiveness independently and fairly. In government service disclosure in Zhejiang, four lists (list of government powers, list of government responsibilities, list of negative enterprise investments and list of special fiscal funds), and one website (Zhejiang government service website) are practiced, with focus on work safety, ecological environment and pandemic prevention. Regulations on 2005 Transparent grievance redress ESS10 requires Consistent Complaint Letters channels have been established, and that a GRM be and Visits implementation measures for further implemented to 2016 appeals are in place. Citizens, legal accept and persons or other organizations shall promote Regulations on submit suggestions, opinions or grievance Complaint Letters appeal requests to governments at all redress for all and Visits of levels by way of letter, e-mail, project-affected Zhejiang Province telephone or visit, etc., to be handled parties, and that by competent administrative stakeholder authorities according to law. engagement 4 The department for letters and visits records be kept, of the people's government at or including a above the county level shall, upon description of receiving a letter or visit, register the stakeholders, a letter-or-visit matter presented and summary of handle it on the merits of each case feedback within 15 days. The matter presented received, and a by a letter-writer or visitor shall be brief description handled within 60 days from the date of how to it is accepted. If the matter is consider complicated, the time limit for feedback, or handling it may be extended reason for not 41 Consistency ESS No. Name Version Applicability evaluation and requirements remedies appropriately upon the approval by considering the responsible person of the feedback. administrative organ concerned, but the period extended shall not exceed 30 days, and the letter-writer or visitor shall be notified of the reasons for such extension. 4.2 Gaps from ESSs and Remedies 4.2.1 Social Risk Management In terms of social risk assessment and information disclosure for major projects, the legal framework of China, Zhejiang and Ningbo is consistent with ESS1. Since China requires the preparation of a social stability risk assessment report, while the Bank requires the preparation of an SIA report, an SIA report has been prepared as required by the Bank. 4.2.2 LAR For LAR and compensation, etc., China has established a complete legal framework and policy system, and the policy objectives are consistent with the Bank requirements. However, the Chinese provisions on persons affected by LAR are inconsistent with Article 10 of ESS5, e.g., in China, affected persons of illegal buildings are not compensated for. In China, illegal buildings are not compensated for. In addition, except large and medium water resources and hydropower projects, no RAP is to be prepared, and independent resettlement M&E is not required. In the Project, affected persons will be identified, an RAP prepared, and independent resettlement M&E conducted according to the Bank policy. 4.2.3 Labor Management China, Zhejiang and Ningbo have a sound legal framework for labor management, which is consistent with ESS2 in terms of equal pay for equal work, GBV, forced or child labor, OHS, occupational disease prevention, infectious disease (including COVID-19), labor protection, etc. However, workers in China are not classified as per ESS2, and China does not require the preparation of an LMP. To ensure consistency, all workers will be divided into four types, and an LMP prepared for the identified labor risks in accordance with ESS2. 4.2.4 Information Disclosure and Public Participation: China and Zhejiang encourage the public to participate in and supervise the preparation, construction and operation of all types of projects. There are detailed and transparent measures for information disclosure and public participation in respect of social risk assessment, public resource allocation, LA, health quarantine, etc., and smooth grievance channels are in place. To ensure consistency, the Ningbo PMO and PIUs have prepared an SEP to cover all stakeholder engagement activities. The borrower should conduct stakeholder engagement in the whole project lifecycle, and include needs and expectations of vulnerable 42 groups, women and low-income population to provide timely, relevant, understandable and accessible information to stakeholders. The GRM is also included in the SEP. 43 5 Social Risks and Impacts Screening 5.1 Methods The social team identified potential social risks by means of literature review, FGD, questionnaire survey, key informant interview and in-depth interview, including 15 FGDs and 70 men-times of key informant interviews. The Project’s potential social risks include LAR risks, NIMBY risks, labor risks, community health and safety risks, road safety risks, inadequate stakeholder engagement risks, non- inclusion risks for vulnerable groups, etc. Based on the risk factors identified and screened above, and the nature and scale of the project activities, social risks have been judged preliminarily. 5.2 Results The social risk analysis of the Project is carried out for all subprojects and in all stages (preparation, construction and operation) against the Bank’s ESF and ESSs (see Table 4-1). The overall social risk rating of the Batch 2 subprojects is “substantial”. 5.2.1 Irrelevance • Ethnic minorities - Since Ningbo is a typical city in which minority population (over 36,000, accounting for 0.59% of registered population) is scattered and introduced by marriage or employment, ESS7 does not apply. • Forced and child labor - Child labor: China has comprehensive laws and regulations on child labor, discrimination and forced labor, largely consistent with the scope and elements of ESS2. The Measures of Zhejiang Province on Child Labor Prohibition prohibit any organization or individual to refer anyone under 16 years to any job. Governments at or above the county level shall strengthen leadership in this respect, and establish a sound coordination system and a sound evaluation system. For Batch 2 subprojects, project workers include direct workers of the PIUs, contract workers responsible for civil works and equipment installation, and drives for solid waste transfer. Project workers should have relevant experience, skills and qualifications, all with age thresholds (e.g., 18 years for driving license in China). The PIUs specify in their labor management policies that no child labor (under 16) should be employed. For example, the youngest worker of the WWTP is 23 years, and contracted workers are mostly cleaners aged 40-50 years. Forced labor: According to the Labor Law, the average working hours of workers shall not exceed 44 hours per week or 8 hours per day. In case of specific circumstances, the extended working hours will not exceed 3 hours per day and 36 hours in total per 44 month. The juvenile workers (16-18 years old) should not be involved in overtime working. The PIUs’ personnel management measures and labor contracts do not contain any provision on penalty payment upon resignation. For example, workers of the WWTP may apply for resignation freely during the contract term, so there is no forced labor. Ningbo is economically developed, where a sound enterprise employment management and supervision system is in place. Based on the industry of the Project, forced and child labor risks are negligible. • Recruitment discrimination - Article 12 of the Labor Law stipulates, laborers shall not be discriminated against in employment due to their nationality, race, sex, or religious belief. Article 27 of the Employment Promotion Law stipulates, an employer shall not refuse to employ women or raise the recruitment standard for them using gender as an excuse, and shall not have such provisions as preventing female workers from getting married or bearing a child. Articles 29, 30 and 31 of the Employment Promotion Law stipulate the protection of employment rights of the disabled, infectious agent carriers and rural laborers. Article 20 of the Employment Promotion Law stipulates, any recruitment advertisement released by any employer shall not contain any discriminatory information. There is no recruitment discrimination in the Project. 5.2.2 Relevance • LAR: ESS5 Among Batch 2 subprojects, 1) The centralized plastic waste sorting and processing plant is located in Ningbo resource recycling base in Haishu District, with a floor area of about 85.8 mu, and the land used is collective land in Xuanpei and Bailiangqiao Villages of Dongqiao Town, and is to be acquired; 2) The bulky and decoration waste disposal plant is located in the Haishu District landfill, with a planned floor area of 59.2 mu. The land was acquired in 2004, and some ground attachments are to be cleared and compensated for in consultation with villagers. In addition, although this land is reserved, its use right has not been allocated or transferred to the PIU yet; 3) The WWTP of Ningbo resource recycling base is located in the wastewater treatment area of the Haishu District landfill in southern Qiaodong Town of Haishu District, and the leachate treatment station has a floor area of 67 mu and is located in the Haishu District landfill; the land of the landfill was acquired in 2004, involving no additional LA; and 4) four recyclable sorting centers. Among the 4 sorting centers, the one in Zhenhai District occupies 9 mu of land, that in Beilun District occupies 9 mu, that in Yinzhou District occupies 6.97 mu and that in Haishu District occupies 15 mu, all being state-owned land. The sites and land of the sorting centers are to be further approved by the competent authorities, especially natural resources bureaus. In sum, 85.8 mu of land 45 will be acquired for the Project, the land plan for the sorting centers needs to be adjusted, and PIUs have not obtained certificates of the land use right, and need further consultation. In addition, some attachments on the acquired land need to be cleaned up, so the Project’s LAR risks are “substantial”. • Community health and safety risks: ESS4 The communities involving community health and safety impacts and risks include those around Ningbo resource recycling base and those run through by waste transfer trucks. The Project’s community health and safety risks are highly connected to the technology and management level of the relevant facilities. The Project involves extensive construction, and may disturb nearby communities during construction, mainly including environmental impacts, traffic congestion and safety impacts. For example, the transport of plastic waste, bulky waste and decoration waste may pose noise, dust, spillage and traffic accidents to nearby communities. However, all project sites are located in Ningbo resource recycling base, workers are not allowed to enter communities during construction, and the construction sites are over 1km away from sensitive sites. Trucks will run through provincial and special highways, and avoid communities, schools, towns, hospitals and other social sensitive sites. Each sorting center has 13-15 vehicle runs, and all vehicles are enclosed vans, for which the owner has taken sound safety measures, such as GPS speed monitoring, speed limit, voice prompt and anti-fatigue. Therefore, the Project’s community health and safety risks are “moderate”. • Labor and working condition risks: ESS2 Project workers include direct workers of the PMO and PIUs, contract workers and primary suppliers’ workers. It is estimated that there will be 241 direct workers, 890 contract workers and 160 and primary suppliers’ workers. During the SIA, extensive stakeholder engagement was conducted by means of literature review, FGD, key informant interview, etc., and labor risks identified, including hazardous operations, machinery operation risks, mechanical construction noises, emergencies, safety accidents, health and infection risks, salary and benefit risks, etc. at the construction stage, and OHS risks, toxic gas risks, emergencies, infection risks, renumeration risks, etc. at the operation stage. In Ningbo, employers manage workers in accordance with the Labor Law (2018 Amendment), Labor Contract Law (2012 Amendment), and other applicable laws and regulations, which prohibit forced and/or child labor, and make provisions on salaries, working hours, labor protection and labor disputes, fully consistent with ESS2. In addition, Ningbo is economically developed, where a sound enterprise employment management and supervision system is in place. Considering the nature of the Project, the all-round provisions on labor protection, and the growing labor supervision in Ningbo, and the practice of contractor and supplier bidding under the Project, the Project’s labor and working conditions risks are “moderate”. • Stakeholder engagement risks: ESS10 At the preparation, implementation and operation stages, information disclosure and participation is an important aspect of realizing the project objectives. Project-affected 46 parties include recyclable sorters, waste truck drivers, community residents, plastic processing workers, wastewater treatment workers, bulky and decoration waste disposal workers, persons affected by LAR, residents along waste transport routes, etc. Since Batch 2 subprojects involve LA, particular attention should be paid to needs and impacts of persons affected by LAR. Other interested parties include the Ningbo PMO, PIUs (Ningbo Dabashou Eco-digital Technology Co., Ltd. (Dabashou Company), Ningbo Haijing Plastic Recycling Technology Co., Ltd. (Haijing Company), Ningbo Meijing Construction Solid Waste Recycling Technology Co., Ltd. (Meijing Company), Ningbo Qingyuan Water Environment Service Co., Ltd. (Qingyuan Company), and the Ningbo Domestic Waste Sorting Guidance Center (NDWSGC)); WWTP-related enterprises (Shouchuang Kitchen Waste Plant, Kaicheng Kitchen Waste Plant and the Yemao’ao landfill), government departments concerned (e.g., ecology and environment bureaus, natural resources and planning bureaus, forestry bureaus), sub-districts, communities, property management companies, media (Ningbo Daily, www.whningbo.cn, etc.), design and consulting agencies, and contractors. Other key interested parties are the municipal ecology and environment bureau, and natural resources and planning bureau. Inadequate information disclosure or negotiation may affect the realization of the project objectives. In particular, the NIMBY effect should be addressed through adequate consultation. Since an extensive public participation mechanism has been established under Phase 1, such risks are moderate. Among project-affected parties, vulnerable groups, and their main interests and needs have been further identified, mainly including low income residents, old people, women, contracted workers (e.g., drivers of recyclable sorting centers). Due to physical factors, old people and women will be affected more seriously by waste transport and disposal. In addition, female workers may be exposed to high OHS risks during construction, and LAR may affect livelihoods of low income residents. Therefore, risks for vulnerable groups are “moderate”. Based on screening, Batch 2 subprojects have no major social risks and impacts. Table 5-1 outlines the potential E&S risks and impacts, applicable ESSs and documents required. • NIMBY risks: ESS1 NIMBY is a cross-cutting issue, where nearby residents have concerns about impacts of waste collection, transfer and treatment facilities on their health, environment and local development, and may file complaint or even resist construction, thereby leading to community conflicts. It can be seen from an analysis of the above risks that subsequent LAR and construction activities of the centralized plastic waste sorting and processing plant, truck operations, and the persistent negative attitude of local residents to waste disposal facilities may lead to NIMBY risks. Ningbo resource recycling base is an important output of the World Bank-financed Ningbo Municipal Solid Waste Minimization and Recycling Project (P123323) which was closed in 2020. Ningbo Municipal Government has gained rich experience in improving the local living environment, and strengthening pollution supervision and control in conjunction with new countryside building. The base has won the China Circular Economy Best Practice Award, and is selected as a provincial demonstration 47 base for industrial tourism and a municipal popular science education base. The Project’s NIMBY risk mitigation experience has been extended throughout the province. For example, the smoke emission standard of the smoke purification system is stricter than the 2010 EU standard. Ningbo PMO has established a GRM for nearby residents. For grievances about noise, odor, etc., the competent municipal authorities, including the office for letters and visits, ecology and environment bureau, and urban administration bureau, offer hotlines, office reception and other grievance redress channels, and the relevant sub-district offices have set up a special division to receive grievances. Therefore, NIMBY risks are “moderate”. Table 5-1 Social Impact Screening Results Subproject Potential social risks/impacts ESSs and instruments ESS1: An SIA and an SEP have been prepared - 4 Recyclables sorting centers (two new according to ESS1; construction and two reconstructed) ESS2: Direct, contracted and - Labor management risks of workers primary suppliers’ workers involved in sorting center construction are involved. Labor rights and equipment installation, recyclable protection is included in the sorters, waste truck drivers, and primary SIA and LMP; (The PIU of suppliers’ workers of recyclable trucks, this subproject is Dabashou 4 Recyclable such as labor rights protection and OHS Company, so its LMP was sorting - Communities around project sites and run prepared in Batch 1); centers through by trucks may be exposed to and ESS4: Community health community health and safety risks, such and safety measures should as traffic safety, noise, odor and spillage. be developed; - Inadequate stakeholder engagement risks, ESS5: LA has been especially non-inclusion risks for completed, and due vulnerable groups, where female workers diligence is necessary; may be exposed to high OHS risks ESS10: The relevant requirements are included in the SEP. Centralized - Potential LAR risks (85.8 mu) ESS1: An SIA and an SEP plastic waste - NIMBY risks for nearby residents, such as have been prepared sorting and noise and odor according to ESS1; processing - Labor management risks of workers ESS2: Direct, contracted and plant involved in base construction and primary suppliers’ workers 48 Subproject Potential social risks/impacts ESSs and instruments equipment installation, plastic waste are involved. Labor rights disposal workers, and primary suppliers’ protection is included in the workers, such as labor rights protection SIA and LMP; an LMP and a and OHS worker GRM have been - Communities around project sites and run prepared; through by trucks may be exposed to and ESS5: If LAR is involved, an community health and safety risks, such RAP should be prepared; as traffic safety, noise, odor and spillage. ESS4: Community health - Inadequate stakeholder engagement risks, and safety measures should especially non-inclusion risks for be developed; vulnerable groups, where female workers ESS10: The relevant may be exposed to high OHS risks, and requirements are included LAR may affect livelihoods of low income in the SEP. residents ESS1: An SIA and an SEP - Outstanding LAR issues though LAR have been prepared completed according to ESS1; - NIMBY risks for nearby residents, such as ESS2: Direct, contract and noise and odor primary suppliers’ workers - Labor management risks of workers are involved. Labor rights involved in base construction and protection is included in the equipment installation, bulky and SIA and LMP; an LMP and a Bulky and decoration waste disposal workers, and worker GRM have been decoration primary supplier’s workers, such as labor prepared; waste disposal rights protection and OHS ESS5: LA has been plant - Communities around project sites and run completed, resettlement through by trucks may be exposed to and due diligence is required; community health and safety risks, such ESS4: Community health as traffic safety, noise, odor and spillage. and safety measures should - Inadequate stakeholder engagement risks, be developed; especially non-inclusion risks for ESS10: The relevant vulnerable groups, where female workers requirements are included may be exposed to high OHS risks in the SEP. 49 Subproject Potential social risks/impacts ESSs and instruments ESS1: An SIA and an SEP - No LAR risks because the WWTP is within have been prepared the existing plant area according to ESS1; - NIMBY risks for nearby residents, such as ESS2: Direct, contract and noise and odor primary suppliers’ workers - Labor management risks of workers are involved. Labor rights involved in WWTP construction and protection is included in the equipment installation, wastewater SIA and LMP; an LMP and a WWTP of treatment workers, and primary worker GRM have been Ningbo suppliers’ workers, such as labor rights prepared; resource protection and OHS ESS5: LA has been recycling base - Communities around project sites and run completed, resettlement through by trucks may be exposed to and due diligence is required; community health and safety risks, such ESS4: Community health as traffic safety, noise, odor and spillage. and safety measures should - Inadequate stakeholder engagement risks, be developed; especially non-inclusion risks for ESS10: The relevant vulnerable groups, where female workers requirements are included may be exposed to high OHS risks in the SEP. 50 6 Stakeholder Engagement 6.1 Stakeholder Identification According to ESS10 and the Project’s characteristics, the Project’s stakeholders include project-affected parties, other stakeholder, and vulnerable groups: Project-affected parties: individuals or groups affected or potentially affected by the Project, including those affected directly and indirectly Other interested parties: individuals or groups potentially interested in the Project Vulnerable groups: persons more likely to be affected aversely at the preparation, construction and operation stages due to own vulnerabilities, including gender, age and environmental impacts. 1) Project-affected parties Project-affected parties include community residents, persons affected by LAR, workers dealing with plastic processing, wastewater treatment, and bulky and decoration waste disposal, etc. See Table 6-1. Table 6-1 Identification and Analysis of Project-affected Parties Type Stakeholder Impact by the Project Influence on the Project Subproject 2: centralized plastic waste sorting and processing plant Bearing community health and safety Moderate influence on the Nearby risks, and environmental impacts and Project; their support is the residents risks at the construction and foundation of successful project operation stages implementation Receiving training on wastewater Wastewater treatment, being exposed to OHS Weak influence, playing a critical treatment risks; responsible for management, role in successful project Project workers technical support, equipment implementation affected operation, etc. parties Discharging wastewater to the Related WWTP, experiencing changes in the Weak influence enterprises wastewater discharge standard and charging mechanism Bearing labor risks of supply Primary workers, responsible for their Weak influence suppliers benefits, OHS, etc. Subproject 2: centralized plastic waste sorting and processing plant 51 Type Stakeholder Impact by the Project Influence on the Project Bearing community health and safety Moderate influence on the Nearby risks, and environmental impacts and Project; their support is the residents risks at the construction and foundation of successful project operation stages implementation Receiving training on plastic Plastic disposal; being exposed to OHS risks; processing responsible for management, Weak influence workers technical support, equipment operation, etc. Responsible for waste collection Receiving training on driving skills Truck and transfer, vehicle repair and and traffic safety; being exposed to drivers operation; weak influence on the OHS risks Project Bearing labor risks of suppliers’ Primary workers, responsible for their Weak influence suppliers benefits, OHS, etc. Affected by HD and relocated, and requiring full compensation and High influence on the Project; Persons proper resettlement their satisfaction their support is the key to affected by with compensation, resettlement, successful project LAR and production and livelihood implementation restoration concerns project implementation. Subproject 3: bulky and decoration waste disposal plant Bearing community health and safety Moderate influence on the Nearby risks, and environmental impacts and Project; their support is the residents risks at the construction and foundation of successful project operation stages implementation Bulky and decoration Receiving operation training; being waste Weak influence exposed to OHS risks disposal workers 52 Type Stakeholder Impact by the Project Influence on the Project Responsible for waste collection Receiving training on driving skills Truck and transfer, vehicle repair and and traffic safety; being exposed to drivers operation; weak influence on the OHS risks Project Subproject 4: 4 recyclables sorting centers Nearby Bearing community health and safety Moderate influence on the residents of risks, and environmental impacts and Project; their support is the sorting risks at the construction and foundation of successful project centers operation stages implementation Residents Bearing community health and safety along risks, and environmental impacts and Weak influence transfer risks at the construction and routes operation stages Recyclable Receiving training on recyclables Weak influence sorters sorting, being exposed to OHS risks Responsible for waste collection Receiving training on driving skills Truck and transfer, vehicle repair and and traffic safety, being exposed to drivers operation; weak influence on the OHS risks Project Source: E&S survey, interviews and consultation with departments concerned 2) Other Interested parties Other interested parties include the PMO, PIUs, municipal and district government, government departments, sub-districts, communities, media (Ningbo Daily, www.whningbo.cn, etc.), design and consulting agencies, contractors, etc. See Table 6-2. Table 6-2 Identification and Analysis of Other Interested Parties Impact by the Type Stakeholder Influence on the Project Project Being responsible for the Project on behalf of Ningbo Municipal Government, Other No significant communicating with the Bank, ensuring interested Ningbo PMO negative impact project implementation and operation, parties and conducting overall project coordination and management; high 53 Impact by the Type Stakeholder Influence on the Project Project influence on successful project implementation PIU, responsible for the implementation Dabashou Benefiting from the and management of the recyclable sorting Company Project centers, high influence on the Project PIU, responsible for the implementation Haijing Benefiting from the and management of the centralized plastic Company Project waste sorting and processing plant, high influence on the Project PIU, responsible for the implementation Meijing Benefiting from the and management of the bulky and Company Project decoration waste disposal plant, high influence on the Project PIU, responsible for the implementation Qingyuan Benefiting from the and management of the WWTP, high Company Project influence on the Project Approving EIA documents and solid waste Ecology and No significant operation, transfer, disposal and environment negative impact utilization activities; high influence on the bureaus Project Coordinating all departments concerned, District No significant supervising project implementation, government negative impact performing routine functions, and accepting and handling grievances Development Initiating the Project, approving the FS No significant and reform report, and developing relevant plans and negative impact commissions standards; high influence on the Project Finance No significant Managing the project financial plan and bureaus negative impact the Bank loan Responsible for land approval, including Natural No significant regulatory sanitation facility land plan, resources and negative impact preliminary construction land examination, site selection opinion and 54 Impact by the Type Stakeholder Influence on the Project Project planning construction land planning permit; high bureaus influence on the Project Forestry No significant Handling woodland acquisition / bureaus negative impact occupation approval, etc. Housing and Responsible for design approval, civil urban-rural No significant work bidding, construction licensing, development negative impact quality inspection, safety management, bureaus final registration, etc. Comprehensive No significant Handling waste sorting tasks, and handling enforcement negative impact grievances bureaus Transport No significant Reviewing routes and timing of waste bureaus negative impact trucks Emergency No significant Handling safety breaches, investigating management negative impact safety accidents, and handling grievances bureaus Being responsible for disease prevention Health No significant and control, and health emergency commissions negative impact education and response Human Protecting labor rights, managing and resources and No significant training laborers, protecting rights of the social security negative impact poor, and managing the poor bureaus Disabled people No significant Protecting rights of the disabled federations negative impact Women’s No significant Protecting rights of women and children federations negative impact Design and consulting No significant Learning stakeholder needs and agencies (e.g., negative impact optimizing the design FS / EIA) 55 Impact by the Type Stakeholder Influence on the Project Project Notifying issues related to stakeholder engagement to owners, handling Benefiting from the Contractors construction grievances under the Project direction of owners, and preparing, disclosing and implementing various plans No significant Giving publicity and education on waste Media negative impact sorting and plastic waste Source: E&S survey, interviews and consultation with departments concerned 3) Vulnerable groups Vulnerable groups include old people, women and children in nearby residents. Due to physical factors, old people will be affected more seriously by waste transport and disposal. In addition, LAR may affect livelihoods of low-income residents. See Table 6-3. Table 6-3 Identification and Analysis of Vulnerable Groups Type Stakeholder Impact by the Project Influence on the Project Protecting them from harmful Their participation is the substances during wastewater Old people foundation for realizing treatment and waste disposal due to the project objectives. low immunity Protecting them from harmful Vulnera Their participation is the Low-income substances, ensuring that they receive ble foundation for realizing residents equal pay for equal work, and ensuring Group the project objectives. their OHS Protecting them from harmful Their participation is the substances, ensuring that they receive Women foundation for realizing equal pay for equal work, ensuring the project objectives. equal pay for equal work and OHS Source: E&S survey, interviews and consultation with departments concerned 6.2 Previous Stakeholder Engagement Activities The main participants in the SIA include Ningbo PMO, PIUs, government agencies concerned, village committees, villagers, and other related enterprises, and the main modes of participation are FGD and interview, including: - 8 persons affected by LAR; - 24 residents from nearby sensitive communities; 56 - 33 workers of existing facilities, including 13 direct workers, 20 contract workers and 5 primary suppliers’ workers; - 12 staff members of competent authorities, including 6 at the district level, 4 at the township / sub-district level, and two at the village / community level; - 12 staff workers of the PIUs, including 5 from Dabashou Company, two from Haijing Company, two from Meijing Company and 3 from Qingyuan Company; - 4 representatives from associated enterprises of the WWTP. 6.3 Key Findings Stakeholder engagement has provided an adequate basis for assessing social risks and proposing mitigation measures. The key findings are as follows: • It is made clear that wastewater from all enterprises in Ningbo resource recycling base will be connected to the reconstructed and expanded WWTP for centralized treatment, and specific water quality indicators will be determined after consultation. • Residents in nearby sensitive sites have reflected odor from some enterprises in the park, and spillage from waste transfer vehicles. Although LAR for the park has been completed, it may still affect nearby low-lying areas due to its high altitude. Residents expect to strengthen supervision to reduce pollution, and disclose monitoring data regularly. • The sorting centers are mostly located in suburbs, surrounded by wasteland or other parks, far away from communities, so they have almost no impact on the living environment. No grievance from residents has been received to date. • The land for the WWTP in Batch 2 subprojects was acquired in 2004, and the APs are well resettled through monetary compensation or property swap. The APs are satisfied with compensation, and support the government’s work actively. • The recyclable sorting centers in operation are located on land reserved by the government, but the land use needs to be adjusted to sanitation facility land, and the PIU has not received the land use right. Each recyclable sorting center has 7-10 workers, mostly women, and men mostly do skilled jobs. About 7 tons of recyclables are sorted per day. The sorters’ health and safety are ensured according to the applicable policies and standards. • The GRMs are effective. Residents can report issues to the PMO directly via the WeChat group or to the district government through deputies to the People’s Congress. 6.4 Future SEP The future SEP is based on the stakeholder analysis in the previous section, and consists mainly of the proposed strategy for information disclosure, proposed strategy for consultation, proposed strategy to incorporate views of vulnerable groups and GRM. 1) Proposed strategy for information disclosure: For each proposed subproject, the owner should disclose the scope and schedule of construction, GRM and contact information to nearby communities one month before construction. During 57 implementation, environmental monitoring data will be disclosed to nearby communities regularly. In addition, the owners will disclose other project information to stakeholders, including major changes and updated E&S documents; the Ningbo PMO will also prepare an E&S performance report semiannually, and disclose it to the public by various means. 2) Proposed strategy for consultation: Stakeholder engagement will run through the whole project lifecycle. Ningbo PMO and PIUS will consult with the competent authorities to complete permission, land use and planning procedures, and establish close ties with communities and project workers. 3) Proposed strategy to incorporate views of vulnerable groups: Since vulnerable groups are more likely to suffer disproportionate losses and be excluded from consultation, appropriate measures should be taken to ensure that they fully participate in project activities, constant attention should be paid to their needs, and a transparent GRM provided to them. 4) GRM: To respond to concerns and grievances about E&S performance, a special GRM has been established for the Project, and includes two types – for the Project and for workers. For project-level grievances, all grievances from residents will be collected and handled. For worker grievances, all grievances from workers will be collected and handled. This report already contains an abstract of the future SEP, proposed strategies for information disclosure, consultation, and incorporating views of vulnerable groups, and a GRM. See the SEP for details. Ningbo PMO disclosed the above documents on 11 April, 2022 at the website of Ningbo Urban Management Bureau 1 to collection opinions and suggestions from stakeholders. See Figure 6-1. 1 Refer to http://zhzfj.ningbo.gov.cn/art/2022/4/11/art_1229101803_58927515.html for more information. 58 Figure 6-1 Disclosure of Draft E&S Documents In terms of WB’s comments on the E&S documents and feedbacks from the public, the Ningbo PMO and PIUs finalized relevant documents including SIA, social audit, RAP and SEP, among others , and re-disclosed them on the website of Ningbo Comprehensive Enforcement Bureau (http://zhzfj.ningbo.gov.cn/art/2022/7/19/art_1229101803_58928745.html ） on 19 July 2022. Figure 6-2 Disclosure of Final E&S Documents 59 7 Social Impact Analysis The potential impacts and risks of Batch 2 subprojects are analyzed based on the baseline social information and public participation results. 7.1 Social Benefits Batch 2 subprojects can reduce environmental pollution caused by plastic waste leakage from municipal solid waste streams including bulky waste, decoration waste, wastewater and hazardous waste, and avoid resource waste arising from incineration and land filling. They will establish a more complete waste recycling system in Ningbo, ensure the successful operation of front-end equipment at communities, expand the coverage of waste sorting, thereby improving the living standard, environmental quality, and waste sorting awareness of all local residents. In addition, the Project will generate about 200 jobs at the construction and operation stages, in which over 80% are unskilled jobs. These jobs will be first made available to local residents to increase their income. For example, nearby residents will be recruited for simple waste sorting. 7.2 Social Impacts 7.2.1 LAR risks 1) Analysis The LAR risks mainly include LA impacts, impacts on existing building occupants, potential risks in facility land acquisition, etc. a) LAR impacts Among Batch 2 subprojects, only the centralized plastic waste sorting and processing plant involves LAR. It is located in Ningbo resource recycling base in Haishu District, with a floor area of about 85.8 mu, which will be acquired. The existing land is mostly collective woodland11, involving Xuanpei and Bailiangqiao Villages, Dongqiao Town, affecting no one. 11 Article 2 of China’s Land Management Law (amended in 2019 and effective as of January 1, 2020) defines that China implements socialist public ownership, namely, ownership by the whole people (state-owned) and collective ownership by the farmer collectives (collective-owned), of land. Land in urban area shall be owned by the State, and land in the rural areas and suburban areas, except otherwise provided for by the State, shall be collectively owned. Therefore, collective land means that the ownership of the land is owned by village collective economic organizations (village committees). The collective land (especially farmland) is usually allocated and contracted to individual villagers for operation. For the project, the land to be acquired is managed collectively by village committee but has not been not contracted to individual villager(s). 60 Figure 7-1 Site of the Centralized Plastic Waste Sorting and Processing Plant b) Impacts on users of existing buildings The bulky and decoration waste disposal plant is located in the Haishu District landfill, with a planned floor area of 59.2 mu, and the land was acquired in 2004. LA and compensation have been completed, but there are still some structures and equipment on the site to be relocated. 1) Collective building in Xuanpei Village: There is a 950 m2 collective office building of Xuanpei Village on the site, being a two-storied masonry concrete building. 8 staff of the village committee are still working here. 2) Worker dormitory: A worker dormitory on the site is still in use, with a building area of 366 m2. This building is owned by the Haishu District landfill, and about 10 landfill O&M workers, who are not residents of Ningbo, live here temporarily. The O&M company, the Ningbo Mingzhou Environment & Energy Co., Ltd. (Mingzhou Company) committed to providing accommodation to non-local workers through renting residential houses/apartments from the local community. Since the building is vacant and not used, the owner, Haishu District landfill, allows the Mingzhou Company use the building temporarily for free. Before the building is demolished to clear the land for the site sitting of this subproject, the Mingzhou Company will rent residential houses/ apartments from the local community for their workers. 3) Abandoned workshops and equipment: There are some abandoned workshops (totaling 300 m2) and equipment on the site. The abandoned workshops belong to the landfill, and the abandoned equipment belongs to New CWI (Ningbo) Environmental Technology Co., Ltd., including a biogas power generator, transformers, etc. 61 Figure 7-2 Site of the Bulky and Decoration Waste Disposal Plant c) Acquisition of facility land Although the land for the bulky and decoration waste disposal plant has been acquired, the Ningbo Municipal Government has not allocated or transferred the right to use state-owned land to the PIU. The 4 recyclables sorting centers are located on state-owned construction land, but the land use plan will be adjusted for sanitation authorities, and the PIU has not obtained the right to use state-owned land. Table 7-1 Statistics of LAR Risks of Subprojects in the Park Project Affected villages and No. Subproject involving LA / LAR Resettlement population land use WWTP of Yinzhou The land for the landfill 3 villages in LA has been fully Ningbo District landfill was acquired in 2004. Qiaodong Town, completed, LA resource in 2004 The WWTP is expanded Haishu District compensation 1 recycling base from the existing facility agreements signed, and and involves no compensation fully additional LA. paid. Bulky and Yinzhou It is within the land Collective offices of LA and compensation decoration District landfill acquired for the Haishu 950 m2 of Xuanpei have been completed, 2 waste disposal in 2004 District landfill, and Village, Dongqiao but some ground plant involves no additional Town attachments have not LA. been cleared. Centralized LA not Occupying 85.8 mu of 61 mu in Xuanpei This is collective plastic waste conducted yet land Village, and 24.8 mu woodland with no sorting and in Bailiangqiao direct affected person; 3 processing Village an RAP has been plant prepared according to ESS5. Source: PMO and social team The land used for the 4 to-be constructed or reconstructed sorting centers is state-owned construction land, in which the sorting centers constructed on leased land in Yinzhou and Haishu Districts are operating. Currently, Ningbo PMO and PIU are coordinating with the district natural resources bureaus to adjust land use and environmental sanitation land plans to ensure that the land used for the sorting centers is lawful. See Table 7-2. Table 7-2 Land Used for the Sorting Centers 62 Floor Sorting Land use No. area Location Site Remarks Land use mode center time (mu) West of the Included in the State- Long-term lease Luotuo Sub- regulatory detailed End of 1 Zhenhai 9 owned of state-owned district transfer plan of Luotuo Sub- Dec 2022 unused land land12 (30 years) station district, and approved Approved under the State- Long-term lease East of the Daxie regulatory detailed End of 2 Beilun 9 owned of state-owned No.2 Bridge plan of the Chaiqiao Dec 2022 unused land land (30 years) Dawan area Southwest of Long-term lease State- Land lease, existing End of 5 Yinzhou 6.97 Mingguang Road, of state-owned owned land facility Dec. 2023 Jiangshan Town land (30 years) Land use, existing Guangze Road, facility, requiring Long-term lease State- End of 6 Haishu 15 Guoxia Village, land type adjustment of state-owned owned land Dec. 2023 Gulin Town (land for sanitation land (30 years) facilities) Source: PMO and fieldwork summary 12The master land utilization plan and sanitation facility land plan of Ningbo City will be adjusted and approved in October 2022. After the sanitation facility land plan is approved, the district governments will allocate the land to the district sanitation authorities, and the PIU will lease such land to construct sorting centers for 30 years. 63 Current site of the Zhenhai District recyclable sorting center Current site of the Beilun District recyclable sorting center 64 Current site of the Jingshan recyclable sorting center in Yinzhou District (existing facility) Gulin recyclable sorting center in Haishu District (existing facility) Figure 7-3 Current Situation of Sorting Centers 2) Existing management measures For LAR and compensation, etc., China has established a complete legal framework and policy system, including the Land Administration Law of the PRC (3rd amendment in 2019), and the Regulations on the Expropriation of Buildings on State-owned Land and Compensation (Decree No.590 of the State Council, 2011). Within this framework, local governments have promulgated local regulations and policies. 65 The social audit reveals that: (i) The WWTP of the Ningbo resource recycling base is a reconstructed work, for which land acquisition and allocation has been completed, with no LAR risk; and (ii) LA for the bulky and decoration waste disposal plant has been completed, but some ground attachments are yet to be cleared. Ningbo PMO and PIU (Meijing Company) should strengthen communication and coordination with the competent authorities to complete site clearing within 3 months before the beginning of construction, and state-owned land allocation or transfer before the beginning of construction. 3) Rating Although Batch 2 subprojects are all civil works, they are mostly located in the suburb, and the land acquired is mostly wasteland or woodland. Since local residents’ income is mostly from nonagricultural sources, LA has little impact on their income. In addition, China, Zhejiang Province and Ningbo City have sound LA policy systems. Therefore, the Project’s LAR risks are “substantial”. Table 7-3 Ratings of Land Use Risks Construction stage Operation stage Subproject Risk Rating13 Risk Rating Compensation, resettlement and Centralized plastic Acquiring 85.8 mu of collective livelihood restoration risks waste sorting and land, almost no livelihood impact S M Preparing an RAP, and processing plant on farmers conducting M&E 59.2 mu of land was acquired in 2017, and there are some ground The land has been acquired, and Bulky and decoration attachments on it. No certificate of M such ground attachments will be M waste disposal plant the right to use state-owned land subject to M&E. has been obtained. With a floor area of 67 mu, within WWTP the land of the Haishu District L No land issue L landfill, involving no additional LA All land used is state-owned land, involving no additional LA. The Recyclables sorting sites and land of the sorting centers M Acquisition of land use right M centers are to be further approved by the competent authorities. 13 Risk ratings: H for “High”, S for “Substantial”, M for “Moderate” and L for “Low”. 66 4) Design optimization and mitigation measures Through consultation with the PIUs, the social team has proposed the following design optimization and mitigation measures based on the risks identified above. Table 7-4 Design Optimization and Mitigation Measures (LAR Risks) Subproject Design optimization Mitigation measures Implementers • Prepare an RAP, and make it approved by • Ningbo the Bank. PMO Centralized • Define the LAR compensation policies • District plastic waste • Optimize site selection to and rates, and ensure that they comply natural sorting and minimize LA and impacts with the Bank and state policies. resources processing on nearby communities. • Implement the approved RAP. bureau plant • Appoint a third party for M&E during • Haijing implementation. Company • Handle the outstanding issues as advised in the social audit report, and conduct M&E. • Optimize site selection to • Strengthen communication with Peixuan • Ningbo minimize LA and impacts Village, Dongqiao Town, and complete PMO Bulky and on nearby communities. relocation and resettlement within 3 months before construction. • Municipal decoration • Strengthen coordination natural waste with the competent • Notify the relevant agencies and staff to resources disposal authorities to complete move within 3 months before bureau plant land allocation or construction. transfer before • Meijing • Complete ownership negotiation in Company construction. coordination with the Haishu District Urban Administration Bureau, and complete equipment relocation by the end of December 2022. • A social audit is performed on the used land, all being state-owned land. • Based on the social audit report, the Ningbo Municipal Government will • Ningbo approve the sanitation facility land plan PMO • Strengthen coordination in October 2022, and the allocate the • Municipal 4 recyclables with the competent land to the district sanitation natural sorting authorities to secure land authorities. resources centers and complete land • The PIU will obtain the right to use state- bureau adjustment. owned land for the Zhenhai and Beilun • Dabashou sorting centers by the end of December Company 2022 by long-term lease, and obtain that for the Yinzhou and Haishu sorting centers by the end of December 2023 by long-term lease. 7.2.2 Labor and working condition risks 1) Analysis 67 Project workers include direct workers of the PMO and PIUs, contract workers and primary suppliers’ workers. It is estimated that there will be 241 direct workers, 890 contract workers and 160 primary suppliers’ workers. In addition, each sorting center has about 10 workers, including two managers. See Table 7-5 for the 4 PIUs of the Batch 2 subprojects. Table 7-5 Activities and PIUs of Batch 2 Subprojects No. Subproject PIU Time of establishment 1 WWTP of Ningbo resource recycling base Qingyuan Company March 2021 centralized plastic waste sorting and 2 Haijing Company May 2021 processing plant 3 bulky and decoration waste disposal plant Meijing Company May 2021 4 4 recyclables sorting centers Dabashou Company May 2021 Dabashou Company, Qingyuan Company, Meijing Company and Haijing Company are all newly established PIUs, and are establishing improving their HR and work safety systems. Except that Qingyuan Company follows the policies of its parent company, the other 3 PIUs have issued and tried out new systems. Qingyuan Company will issue its own systems based on the LMP, ESS2, and applicable PRC laws and regulations by December 2022. 1) Dabashou Company Dabashou Company is also a PIU of Batch 1 subprojects. It has established the following systems: • General Manager’s Office Meeting System (trial), October 2021; • Work Attendance Management System (trial), October 2021; • Salary Management System (trial), October 2021; • Supplier Management System (trial), October 2021; • Human Resources Management System (trial), April 2022; • Work Safety Management System (trial), April 2022; • Occupational Health Management System (trial), April 2022; • Safety Education and Management System (trial), April 2022; • Accident Reporting System (trial), April 2022; • Office Emergency Response Plan (trial), April 2022. 2) Meijing Company It has established the following systems: • Safety Management System (trial), October 2021 • Supplier Management System (trial), October 2021 • Salary Management System (trial), October 2021 • Employment Recruitment and Transfer Management System (trial), November 2021 • Reward and Punishment Management System (trial), November 2021 • Work Safety Management System (trial), March 2022 68 3) Haijing Company It has established the following systems: • Work Attendance Management System (trial), October 2021 • Contract Management System (trial), October 2021 • Safety Management System (trial), October 2021 • Supplier Management System (trial), October 2021 • Salary Management System (trial), October 2021 • Recruitment Management System (trial), December 2021 • Employment Recruitment and Transfer Management System (trial), December 2021 • Work Safety Management System (trial), March 2022 The PIUs’ existing labor management systems mainly include procedures and requirements for direct workers, and also include some provisions on contracted workers, but have some gaps from ESS2 in terms of the management of contracted, community and primary suppliers’ workers. The PIUs’ existing workers do not include child labor. Direct workers can reflect their grievances through many formal and informal channels, and receive feedback quickly and effectively. Meijing Company, Haijing Company and Dabashou Company will entrust recyclable drivers to a third-party labor service company or a specialized logistics company, so these drivers are contracted workers. COVID-19 prevention measures have been taken for the existing facilities as required by the local government. Based on the social audit, the labor and working condition risks of the Batch 2 subprojects are OHS risks mainly, as detailed below. ✓ Main labor and working condition risks of the centralized plastic waste sorting and processing plant: 1) Construction stage • Dangerous work: construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials • Safety risks in machinery operation: accidents of construction workers during construction, such as welding, cutting and operating relevant tools • Noise from mechanical construction: loud, repeated and excessive noise that may arise during construction, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks • Emergency risks: emergencies and quality safety accidents arising from unsound civilized construction and quality safety management measures, or inadequate management • Sexual harassment or gender-based violence risks: physical or mental violence against women due to gender or lifestyle differences • Safety accidents: safety accidents arising from work shed collapse due to quality problems or natural disasters • Health and infection risks: infection risks (e.g., COVID-19) arising from the improper diet and accommodation management, or health management of 69 construction workers • Salaries and benefits: workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts 2) Operation stage • Traffic: potential traffic accidents during the transport of recovered bulky and construction waste • Noise from machinery operation: such as noise generated by sorting and crushing machines, etc.; loud, repeated and excessive noise, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks • Work-related injuries: work-related injuries due to improper operations during the breakdown of bulky waste • Dust pollution: dust and volatile organic substances generated by plastic crushing and granulation during operation • Industrial vehicles: improper operation of forklifts in the working area • Emergency accidents: mistakes in the operation of smart equipment leading labor health and life risks • Infection: infection risks (e.g., COVID-19) during recyclable (waste) collection and transfer, and close contact with people ✓ Main labor and working condition risks of the bulky and decoration waste disposal plant: 1) Construction stage • Dangerous work: construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials • Safety risks in machinery operation: accidents of construction workers during construction, such as welding, cutting and operating relevant tools • Noise from mechanical construction: loud, repeated and excessive noise that may arise during construction, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks • Emergency risks: emergencies and quality safety accidents arising from unsound civilized construction and quality safety management measures, or inadequate management • Sexual harassment or gender-based violence risks: physical or mental violence against women due to gender or lifestyle differences • Safety accidents: safety accidents arising from work shed collapse due to quality problems or natural disasters • Health and infection risks: infection risks (e.g., COVID-19) arising from the improper diet and accommodation management, or health management of construction workers • Salaries and benefits: workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts 2) Operation stage • Traffic: potential traffic accidents during the transport of sorted recyclables 70 •Noise from machinery operation: such as noise generated by sorting and crushing machines, etc.; loud, repeated and excessive noise, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks • Injuries: industries arising from improper operations in bulky waste dismantling • Dust pollution: dust generated by plastic crushing and granulation during operation • Emergency accidents: mistakes in the operation of smart equipment leading labor health and life risks • Infection: infection risks (e.g., COVID-19) during recyclable (waste) collection and transfer, and close contact with people ✓ Main labor and working condition risks of the WWTP: 1) Construction stage • Noise from mechanical construction: loud, repeated and excessive noise that may arise during construction, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks • Emergency risks: emergencies and quality safety accidents arising from unsound civilized construction and quality safety management measures, or inadequate management • Sexual harassment or gender-based violence risks: physical or mental violence against women due to gender or lifestyle differences • Safety accidents: safety accidents arising from work shed collapse due to quality problems or natural disasters • Health and infection risks: infection risks (e.g., COVID-19) arising from the improper diet and accommodation management, or health management of construction workers • Salaries and benefits: workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts 2) Operation stage •OHS risks: health problems of WWTP staff due to noise and exposure to chemicals, such as ammonia, hydrogen sulfide and sodium hydroxide • Toxic gases: exposure to high-level toxic gases when repair workers work in wastewater manholes and box culverts, such as ammonia and sodium hydroxide • Emergency accidents: leakage of wastewater or harmful gases due to system failure, or mistakes in the operation of smart equipment during installation and adjustment leading labor health and life risks • Noise and vibration: noise and vibration generated by pumps and blowers in the plant • Eye injury: use of hydrochloric acid, sodium hypochlorite and other liquids • Infection: infection risks (e.g., COVID-19) during contact with water, and close contact with people • Salaries and benefits: workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts ✓ Main labor and working condition risks of the 4 sorting centers: 71 Since recyclables are from smart waste separation cabins deployed in communities, they are relatively clean, and have relatively occupational health risks for workers. According to the disposal process, occupational hazards for workers mainly include odor, dust, physical injuries (scratches), noises, high temperature (summer), etc. The PIU has established an on-site job evaluation system, including job discipline, on-site health, operating safety, etc. At the Jiangshan recyclable sorting center, sorters are hired by a third-party agency, mostly being women aged 45-55 years. They sign a labor contract usually one a year. However, temporarily hired workers may have not signed a labor contract, and some workers do not use PPE (gloves, face masks, etc.) as required at work. Workers employed by contractors include both male and female ones, where female workers may be subject to GBV risks. Table 7-6 Types and Estimated Numbers of Project Workers Contract Primary suppliers’ Subproject Stage Direct hires workers workers Civil works 8 300 5 Construction Equipment WWTP 8 30 30 installation Operation 20 5 5 Civil works 10 300 0 Construction Equipment Centralized plastic 10 40 0 waste sorting and installation processing plant Trial operation 50-60 60 0 Stable operation 100-115 60 0 Civil works 10 200 0 Bulky and decoration Construction Equipment 5 15 0 waste disposal plant installation Operation 100 0 0 Civil works 8 100 0 Sorting centers (to be Construction Equipment 8 32 5 added) installation Operation 12 48 0 Source: PIUs and social team 2) Existing management measures 72 All enterprises covered by the SIA have established a series of policies and procedures in accordance with the applicable state and local regulations to establish a labor management system. Such policies and procedures are generally consistent with ESS2. ✓ Centralized plastic waste sorting and processing plant Haijing Company was founded in May 2021, and has established some personnel and work safety management systems. Its employees are entitled to statutory social insurance (endowment, medical, unemployment, accident, maternity, etc.), and a housing provident fund. Female employees’ extra benefits are based on the applicable state and local regulations, such as the Measures for the Labor Protection of Female Workers of Zhejiang Province. China’s Labor Law and the Labor Contract Law have clear provisions on employment, labor contract management and leaves, and Haijing Company’s relevant practices comply with such provisions, and are communicated to all employees through induction training, on-the-job training and routine operations. Haijing Company is improving its labor management systems according to ESS2, especially the management requirements for contract and primary suppliers’ workers. ✓ Bulky and decoration waste disposal plant Meijing Company was founded in May 2021, and has established some HR and work safety management systems. Its employees are entitled to statutory social insurance (endowment, medical, unemployment, accident, maternity, etc.), and a housing provident fund. Female employees’ extra benefits are based on the applicable state and local regulations, such as the Measures for the Labor Protection of Female Workers of Zhejiang Province. China’s Labor Law and the Labor Contract Law have clear provisions on employment, labor contract management and leaves, and Meijing Company’s relevant practices comply with such provisions, and are communicated to all employees through induction training, on-the-job training and routine operations. Meijing Company is improving its labor management systems according to ESS2, especially the management requirements for contract and primary suppliers’ workers. ✓ WWTP Founded in March 2021, Qingyuan Company is a wholly funded subsidiary of Ningbo Municipal Public Utilities Investment Co., Ltd. Since the Company has just been established, its HR systems and policies are being formulated and improved, and follow those of its parent company (Ningbo Municipal Public Utilities Investment Co., Ltd.). Currently, all staff of the Company and project workers are from the parent company. The leachate treatment process is: conditioning tank—two-stage A/O system— external ultrafiltration system—NF system—RO system—discharge up to the standard. For the above areas and occupational hazards, the PIU has set up and operated protection facilities. For toxic gases (ammonia, hydrogen sulfide, etc.), a fully sealed design is used or facilities set up (vent pipes, blowers, fume hoods, etc.) for organized gas discharge to prevent harmful gases from escaping or reducing levels of hazardous substances. ✓ 4 sorting centers 73 For direct workers, Dabashou Company has no gap from the requirements of ESS2 in terms of employment terms and conditions, and labor protection. The PIU has established an on-site job evaluation system, including job discipline, on- site health, operating safety, etc. On-site safety risks are from forklift operation mainly. Each sorting center stipulates a fixed route and a speed limit (5km/h) for forklifts, and assigns someone to command to ensure on-site safety. According to manager and worker interviews, workplace occupational hazards are insignificant. Except paperboards, recyclables have almost no dust; there is some odor in summer, but it can be reduced by window opening and fan ventilation. In addition, the company distributes disposable face masks to workers, and would check the workplace for PPE (face masks, gloves, etc.) wearing irregularly every month. Notices of job responsibilities and safety instructions are posted conspicuously at the workplace. A labor contract between a contract worker and a third-party specifies the detailed job requirements, scope of work, workplace, working hours, rest time, remuneration, overtime pay, social insurance and benefits, labor protection and conditions, occupational hazard prevention, financial compensation, etc. The Measures for the Management of Third-Party Dispatched Workers specify labor remuneration, social insurance, overtime pay, and other labor rights. For drivers, the main risks are traffic safety risks. The third-party agency has taken the following measures: 1) implementing the applicable state, provincial and municipal traffic safety regulations, formulating safety regulations and measures, and strengthening safety education and management; 2) ensuring that drivers are licensed, and observe the traffic rules and operating regulations to ensure driving safety; 3) ensuring vehicle safety through annual review and proper management, and keep vehicle operation, repair and accident records timely, fully and accurately; and 4) ensuring that vehicles drive along fixed routes and according to the speed limit under online GPS monitoring. In China, only adults (18 years or above) can apply for a driving license. Therefore, there is no child or underage worker in Kaicheng Company’s primary suppliers’ workers. These drivers are work voluntarily, and may apply for resignation freely, so there is no forced labor. ✓ Sexual assault (SEA) and sexual harassment (SH) prevention All PIUs of Batch 2 subprojects are committed to providing a healthy and efficient working environment, because SEA/SH is against laws and social morals, and is intolerable. The HR policies of the PIUs have strict relevant provisions for direct workers, contract workers and managers to avoid sexual harassment. The PIUs offer jobs first to women, such as finance, human resources and office jobs, and have established regulations against sexual harassment. Male and female workers enjoy equal rights in training, development and promotion. The PIUs have smooth internal complaint channels. 74 The district competent authorities offer SEA/SH prevention services, as shown in Table 7-7. GBV service providers are essential to solving any emerging SEA/SH event, and preventing SEA/SH events. They are divided into: • Healthcare service providers: community hospitals, maternal and child care centers • Social service providers: district legal assistance centers, district women’s federations Table 7-7 Contact Information of Service Providers Haishu Yinzhou Jiangbei Zhenhai Beilun Fenghua Service providers District District District District District District Community 023- 0574- 0574- 0574- 0574- 0574- Healthcare hospitals 65770090 88462894 87582446 86655001 86100266 88587000 service Maternal and child 0574- 0574- 0574- 0574- 0574- 0574- providers care centers 56123838 56801905 55003395 86272184 86782091 88955000 District legal 0574- 0574- 0574- 0574- Social 88190298 86781825 assistance centers 87258148 87669148 86275994 88960148 service District women’s 0574- 0574- 0574- 0574- 0574- 0574- providers federations 87315589 87525572 87666672 86275887 86780524 88588106 3) Rating It is found that: 1) During facility operation, there may be multiple OHS hazards at the workplace; 2) Few workers have weak awareness of PPE use. In general, the Project’s labor and working condition risks are “moderate”. See Table 7-8. Table 7-8 Ratings of Labor and Working Condition Risks Construction stage Operation stage Subproject Risk Rating Risk Rating Construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials, safety risks in machinery use, Centralized and infection risks due to inadequate health plastic management (e.g., COVID-19) OHS risks, emergency risks, waste All direct workers of the PIU have signed a labor M infection risks, and salary and M sorting and contract, and its salaries, benefits, working hours, benefit risks of operation staff processing and OHS management comply with the applicable plant state and local laws and regulations. However, little attention is paid to the worker management of contractors and primary suppliers. 75 Construction stage Operation stage Subproject Risk Rating Risk Rating Construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials, safety risks in machinery use, Bulky and and infection risks due to inadequate health OHS risks, traffic safety risks, decoration management (e.g., COVID-19) emergency risks, infection waste All direct hires of the PIU have signed a labor M M risks, and salary and benefit disposal contract, and its salaries, benefits, working hours, risks of operation staff plant and OHS management comply with the applicable state and local laws and regulations. However, little attention is paid to the worker management of contractors and primary suppliers. Construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials, safety risks in machinery use, and infection risks due to inadequate health management (e.g., COVID-19) Potential OHS hazards at the WWTP All direct hires of the PIU have signed a labor M M workplace contract, and its salaries, benefits, working hours, and OHS management comply with the applicable state and local laws and regulations. However, little attention is paid to the worker management of contractors and primary suppliers. Construction workers working at height or in Potential OHS risks because Recyclables confined spaces, safety risks in machinery use, and workers fail to use PPE sorting M M infection risks due to inadequate health (gloves, face masks, etc.) as centers management (e.g., COVID-19) required during operation 4) Design optimization and mitigation measures Through consultation with Ningbo PMO and PIUs, the social team has proposed the following design optimization and mitigation measures based on the risks identified above. Table 7-9 Design Optimization and Mitigation Measures (Labor and Working Condition Risks) Subproject Design optimization Mitigation measures Implementers Centralized • For on-site and nearby • Establish an appropriate LMP, which has Ningbo PMO plastic potential traffic risks, the been improved on the basis of the existing Haijing waste owners should appoint a personnel management system, with Company 76 Subproject Design optimization Mitigation measures Implementers sorting and specialized agency for particular attention paid to the processing traffic layout, giving full management and monitoring of contracted plant. consideration of driving and primary suppliers’ workers. routes and optimization • Stress the safety rules for drivers, measures, and set up improve their driving skills, restrict appropriate traffic safety driving time, and prepare a rotation table facilities and guides to avoid fatigue driving. according to the • Avoid dangerous roads and times of a day regulations. to reduce the probability of accidents. • Select suitable waste gas • Install speed limiters on trucks, and treatment processes. monitor driving behavior remotely. • For rotating and moving • Maintain trucks regular, use equipment, eliminate manufacturer approved parts, and avoid clamping risks through accidents due to equipment or part design, and ensure that failure. any protrusion will not • Improve road signs together with local cause any personal injury communities and competent authorities during normal operation. to improve overall road safety, especially • Use an occupational for roads near schools. hazard mitigation design, • Conduct traffic safety education together optimize equipment with local communities, such as at selection, and use low- schools. noise equipment where • Detect workplace occupational hazards possible. regularly, and take measures based on results. • Strengthen OHS training and workers’ safety awareness, conduct emergency drills regularly, and guide workers to use PPE properly. • Further improve the GRM for workers (direct and contracted workers), handle opinions, feedback and concerns of workers, and record them in writing. • Monitor labor risk management regularly, and make improvement based on suggestions. 77 Subproject Design optimization Mitigation measures Implementers • Establish an appropriate LMP, which has been improved on the basis of the existing personnel management system, with particular attention paid to the management and monitoring of contracted and primary suppliers’ workers. • For on-site and nearby • Stress the safety rules for drivers, potential traffic risks, the improve their driving skills, restrict owners should appoint a driving time, and prepare a rotation table specialized agency for to avoid fatigue driving. traffic layout, giving full • Avoid dangerous roads and times of a day consideration of driving to reduce the probability of accidents. routes and optimization measures, and set up • Install speed limiters on trucks, and appropriate traffic safety monitor driving behavior remotely. facilities and guides • Maintain trucks regular, use Bulky and according to the manufacturer approved parts, and avoid decoration regulations. accidents due to equipment or part Ningbo PMO waste • For rotating and moving failure. Meijing disposal equipment, eliminate • Improve road signs together with local Company plant clamping risks through communities and competent authorities design, and ensure that to improve overall road safety, especially any protrusion will not for roads near schools. cause any personal injury • Conduct traffic safety education together during normal operation. with local communities, such as at • Use an occupational schools. hazard mitigation design, • Detect workplace occupational hazards optimize equipment regularly, and take measures based on selection, and use low- results. noise equipment where • Strengthen OHS training and workers’ possible. safety awareness, conduct emergency drills regularly, and guide workers to use PPE properly. • Conduct occupational health checkups annually. • Conduct a fire safety emergency drill annually. 78 Subproject Design optimization Mitigation measures Implementers • Further improve the GRM for workers (including direct and contracted workers), handle feedback and grievances of workers, and keep written records. • Monitor labor risk management regularly, and make improvement based on suggestions. • Establish an appropriate LMP, which has been improved on the basis of the existing personnel management system, with particular attention paid to the management and monitoring of contracted and primary suppliers’ workers. • Detect workplace occupational hazards regularly, and take measures based on • Select a suitable results. deodorization process. • Strengthen OHS training and workers’ • Use an occupational safety awareness, conduct emergency Ningbo PMO hazard mitigation design, drills regularly, and guide workers to use WWTP Qingyuan optimize equipment PPE properly. Company selection, and use low- • Conduct occupational health checkups noise equipment where annually. possible. • Conduct a fire safety emergency drill annually. • Further improve the GRM for workers (including direct and contract workers), handle feedback and grievances of workers, and keep written records. • Monitor labor risk management regularly, and make improvement based on suggestions. • Give full consideration of • Implement an appropriate LMP according 4 driving routes and to ESS2, establish a procedure to manage Ningbo PMO Recyclables optimization measures, and monitor third party performance, and Dabashou sorting and set up appropriate define remedies for third-party Company centers traffic safety facilities and nonconformities in the service contract. 79 Subproject Design optimization Mitigation measures Implementers guides according to the • Stress the safety rules for drivers, regulations. improve their driving skills, restrict • Use an occupational driving time, and prepare a rotation table hazard mitigation design, to avoid fatigue driving. optimize equipment • Avoid dangerous roads and times of a day selection, and use low- to reduce the probability of accidents. noise equipment where • Install speed limiters on trucks, and possible. monitor driving behavior remotely. • Maintain trucks regular, use manufacturer approved parts, and avoid accidents due to equipment or part failure. • Improve road signs together with local communities and competent authorities to improve overall road safety, especially for roads near schools. • Conduct traffic safety education together with local communities, such as at schools. • Strengthen OHS training and workers’ safety awareness, conduct emergency drills regularly, and guide workers to use PPE properly. • Conduct a fire safety emergency drill annually. • Further improve the GRM for workers (including direct and contracted workers), handle feedback and grievances of workers, and keep written records. • Monitor labor risk management regularly, and make improvement based on suggestions. 7.2.3 Community health and safety risks 1) Analysis Batch 2 subprojects (except the recyclable sorting centers) and associated facilities are all located in Ningbo resource recycling base, and involve extensive civil works, which may disturb 80 nearby communities, mainly including environmental impacts, traffic congestion and safety impacts. In addition, plastic, bulky and decoration waste may pose noise, flying dust, waste spillage, traffic accidents and other relevant risks to nearby communities during transport. However, the centralized plastic waste sorting and processing plant, bulky and decoration waste disposal plant, and WWTP are all located in Ningbo resource recycling base, and their construction sites are over 1km away from sensitive sites; vehicles run through provincial and special highways, and avoid communities, schools, villages, hospitals and other social sensitive sites where possible, with little community disturbance. Table 7-10 Information on Recyclable Transfer Trucks Subproject PIU Transfer mode and route Number of trucks Runs Bulky and • Route: from all sites in the city 50 150 Meijing decoration waste to the Dongqiao disposal site runs/day Company disposal plant • Mode: dump truck • Route: sorting center—Haijing There is no 30 Plastic Disposal Plant budget for truck runs/day • Mode: logistics truck purchase yet. Centralized plastic Haijing • Route: Haijing Plastic Disposal Transport will be waste sorting and Company Plant—external recycling undertaken by a processing plant enterprises specialized • Mode: logistics truck logistics company. • Route: urban communities Dabashou will Each within the project area— purchase 230 sorting sorting centers trucks (belonging center will • Mode: van to Dabashou have 30-50 • Recyclable plastics: sorting other than the runs/day 4 Recyclables Dabashou centers—Haijing Plastic sorting centers). after sorting centers Company Disposal Plant completion. • Mode: logistics truck • Non-plastic recyclables: sorting centers—external recycling enterprises • Mode: logistics truck Source: estimates of PIUs The Jiangshan recyclables sorting center in Yinzhou District and Gulin recyclables sorting center in Haishu District are away from communities, hospitals, schools, etc., and have minor traffic safety risks for communities. 81 For the recyclables sorting centers, a recyclable collection and transfer system consists of an integrated logistics management platform, a smart waste separation cabin, and a sorting center. Each sorting center has 30-50 vehicle runs, and all vehicles are enclosed vans, for which the owner has taken sound safety measures, such as GPS speed monitoring, speed limit, voice prompt and anti-fatigue. 2) Existing management measures ⚫ Ningbo PMO minimizes impacts on the surrounding environment by controlling sites and vehicles. Currently, waste unloading and compression is performed in closed unloading rooms, and vehicle compartments and floors are cleaned by cleaners timely. In addition, closed waste transfer vehicles are used for transfer to avoid spillage. ⚫ For recyclables transport fleets, the PIUs have established waste collection and transfer management systems, and defined the safety protection measures to be observed by drivers, including waste transfer times and routes, driving speed, repair, preparation, cleaning and safety. ⚫ The municipal urban administration bureau is also conducting a special correction campaign for domestic waste collection and transfer vehicles to ensure compliance and avoid secondary pollution. 3) Rating There is already a sound domestic waste collection and transfer system in Ningbo, and transfer routes avoid communities, schools, villages, hospitals and other social sensitive sites where possible. However, with the increase of vehicles, especially building material transport vehicles during construction, nearby communities may still be exposed to sudden road traffic safety risks. Although the associated facility operators have taken a series of measures to reduce facility operation impacts on nearby communities, nearby residents say that there is still odor in summer, and relevant environmental monitoring data is not disclosed timely. The nearest community is 200m away, and the sorting centers generate little wastewater and waste pollution. The sorting centers have no formal grievance redress channel, and have not received any grievance from nearby residents. See Table 7-11. Table 7-11 Ratings of Community Health and Safety Risks Construction stage Operation stage Subproject Risk Rating Risk Rating Impacts on communities Vehicles run through provincial and special Centralized near the facility and highways, and avoid communities, schools, plastic waste communities passed villages, hospitals and other social sensitive sorting and through by vehicles M sites where possible, with little community M processing The construction site is over disturbance. plant 1km away from sensitive sites. 82 Impacts on communities Bulky and decoration waste will be collected near the facility and in a door-to-door manner through online communities passed appointment on the smart solid waste Bulky and through by vehicles management system. decoration The construction site is over M Vehicles run through provincial and special M waste disposal 1km away from sensitive highways, and avoid communities, schools, plant sites. villages, hospitals and other social sensitive sites where possible, with little community disturbance. Impacts on communities The results of the routine monitoring of near the facility and wastewater, ambient air and groundwater communities passed quality comply with the relevant national WWTP through by vehicles M standards. Therefore, community health and L The construction site is over safety impacts are minor. 1km away from sensitive sites. Disturbances to nearby Impacts of vehicles on communities run Recyclables communities through M M sorting centers Each sorting center has 13-15 vehicle runs, and all vehicles are enclosed vans. 4) Design optimization and mitigation measures Through consultation with the PIUs, the social team has proposed the following design optimization and mitigation measures based on the risks identified above. 83 Table 7-12 Design Optimization and Mitigation Measures (Community Health and Safety Risks) Subproject Design optimization Mitigation measures Implementers • Strengthen internal supervision and management to avoid pollutant • Make a rational layout, and leakage; start remedies for keep high-noise equipment, abnormal operating conditions main discharge ports, etc. according to the EIA and SIA. away from nearby sensitive • Develop and strictly implement sites. measures for driver and vehicle • Improve the construction plan, management, such as pre-job and schedule construction Centralized training, driving experience and rationally to minimize plastic waste sign setup, to reduce traffic Ningbo PMO construction impacts on sorting and accidents. Haijing communities. processing • Establish a formal community Company • Set up safety warning signs at plant communication mechanism to key sites, and educate local respond to community concerns residents on safety. timely. • Better traffic risk control • The owner should appoint a measures should be taken for qualified social consulting agency vehicles, such as GPS speed according to the ESCP to monitor monitoring, speed limit, voice and evaluate social management prompt and anti-fatigue. measures, and make improvement as advised. • Make a rational layout, and • The PIU should strengthen keep high-noise equipment, international supervision and main discharge ports, etc. management to avoid pollutant away from nearby sensitive leakage; in case of an abnormal sites. working condition, remedies • Improve the construction should be taken according to the Bulky and plan and make rational EIA and SIA requirements. Ningbo PMO decoration construction arrangements to • Take measures to manage trucks Meijing waste minimize impacts on and drivers, and develop and Company disposal plant community. enforce management • Set up safety signs at key requirements, such as pre-job traffic points in communities, training, threshold setting and sign and give safety education to setup, to reduce traffic accidents. local residents, including • Establish a formal community women, children and old communication mechanism to 84 Subproject Design optimization Mitigation measures Implementers people. strengthen community • Better traffic risk control communication, and respond to measures should be taken for community concerns timely. vehicles, such as GPS speed • Appoint a qualified social monitoring, speed limit, voice consulting agency to monitor and prompt and anti-fatigue. evaluate social management measures, and make improvement based on suggestions. • The PIU should strengthen international supervision and management to avoid pollutant • Make a rational layout, and leakage; in case of an abnormal keep high-noise equipment, working condition, remedies main discharge ports, etc. should be taken according to the away from nearby sensitive EIA and SIA requirements. sites. • Establish a formal community Ningbo PMO • The EIA should fully analyze WWTP communication mechanism to Qingyuan and predict pollutants strengthen community Company (especially odor) in different communication, and respond to scenarios, and install community concerns timely. appropriate environmental • Appoint a qualified social facilities based on the EIA consulting agency to monitor and results. evaluate social management measures, and make improvement based on suggestions. • Make a rational layout, and • The PIU should strengthen keep high-noise equipment, international supervision and main discharge ports, etc. management to avoid pollutant away from nearby sensitive leakage; in case of an abnormal sites. working condition, remedies 4 Recyclables Ningbo PMO • Improve the construction should be taken according to the sorting Dabashou plan and make rational EIA and SIA requirements. centers Company construction arrangements to • Take measures to manage trucks minimize impacts on and drivers, and develop and community. enforce management • Set up safety signs at key requirements, such as pre-job traffic points in communities, training, threshold setting and sign 85 Subproject Design optimization Mitigation measures Implementers and give safety education to setup, to reduce traffic accidents. local residents, including • Establish a formal community women, children and old communication mechanism to people. strengthen community • Better traffic risk control communication, and respond to measures should be taken for community concerns timely. vehicles, such as GPS speed • Appoint a qualified social monitoring, speed limit, voice consulting agency to monitor and prompt and anti-fatigue. evaluate social management measures, and make improvement based on suggestions. 7.2.4 Inadequate stakeholder engagement risks 1) Analysis Information disclosure and participation at the preparation, construction and operation stages is an important aspect to realize the project objectives. Project-affected parties include recyclable sorters, waste truck drivers, community residents, plastic processing workers, wastewater treatment workers, bulky and decoration waste disposal workers, persons affected by LAR, residents along waste transport routes, etc. Since Batch 2 subprojects involve LA, particular attention should be paid to needs and impacts of persons affected by LAR. The key other interested parties are the municipal ecology and environment bureau, and natural resources and planning bureau. Inadequate stakeholder engagement may affect the realization of the project objectives, such as site selection, LAR policies, and transport routing and safety. The survey shows that adequate information disclosure and public participation were conducted during the EIA, social stability risk assessment, and LAR of the existing facilities and associated facilities. Nearby residents often communicate with the project owners through local township governments and community officials. The disclosure of environmental monitoring indicators during operation is inadequate, and the participation of vulnerable groups is inadequate, such as old people, women and low- income residents. For the recyclables sorting centers, a recyclable collection and transfer system consists of an integrated logistics management platform, a smart waste separation cabin, and a sorting center. Each sorting center has 30-50 vehicle runs. Drivers of the sorting centers are contracted workers, and may be unable to receive the same OHS protection and training measures as direct workers. 2) Existing management measures For information disclosure, public participation and GRM, the state, provincial and municipal laws, regulations and policies impose strict requirements on information disclosure on the approval and implementation of major construction projects, land acquisition compensation, government resource allocation, etc., and require that public participation channels be kept smooth. A systematic complaint handling system has been established in 86 Ningbo City. Citizens, legal persons or other organizations shall submit suggestions, opinions or appeal requests to governments at all levels by way of letter, e-mail, telephone or visit, etc., to be handled by competent administrative authorities according to law. 3) Rating Batch 2 subprojects involve many stakeholders, which requires adequate stakeholder engagement at the preparation, construction and operation stages to protect the information and participation rights of all stakeholders. An extensive community participation mechanism was established in Phase 1 of the Project, the SIA received extensive support from all stakeholders, and information disclosure and consultation activities were conducted at the preparation. However, inadequate stakeholder engagement may still exist in subsequent construction and operation. During the survey, nearby residents expected environmental monitoring data to be further disclosed. The Project’s inadequate stakeholder engagement risks are “moderate”. See Table 7-13. Table 7-13 Ratings of Inadequate Stakeholder Engagement Risks Construction stage Operation stage Subproject Risk Rating Risk Rating Inadequate disclosure and consultation No communication and Centralized on LA compensation and resettlement coordination mechanism plastic waste policies, and inadequate participation of between communities and the sorting and M L vulnerable groups, such as old people, PIU (including old people, processing women and low-income residents women and low-income plant residents) Inadequate consultation on Inadequate disclosure of Bulky and compensation for ground attachments environmental monitoring decoration Inadequate information disclosure and indicators during operation M L waste disposal consultation, including vulnerable plant groups, such as old people, women and low-income residents Inadequate information disclosure and Inadequate disclosure of consultation, including vulnerable environmental monitoring WWTP M L groups, such as old people, women and indicators during operation low-income residents Inadequate consultation on land No communication and occupation and compensation, coordination mechanism Recyclable including vulnerable groups, such as old between communities and the M L sorting centers people, women and low-income PIU (including old people, residents women and low-income residents) 87 4) Design optimization and mitigation measures Through consultation with the PIUs, the social team has proposed the following design optimization and mitigation measures based on the risks identified above. Table 7-14 Design Optimization and Mitigation Measures (Inadequate Stakeholder Engagement Risks) Subproject Design optimization Mitigation measures Implementers • The PIU should act on the SEP and GRM, disclose • Establish community them to the public, and provide sufficient assistance funds to resources to ensure their effective operation. support nearby villages Ensure that nearby communities participate in run facilities and project design, construction and operation, services, and perform where the participation rate should not be less corporate social than 70%, with particular attention paid to responsibility to win the vulnerable groups’ needs. support of nearby Take full advantage of online platforms, and set Centralized residents. up an online disclosure and discussion module • plastic waste Establish an Ningbo PMO for stakeholders to share project information. sorting and environmental education Haijing The PIU should assign someone to handle the processing base, organize diversified Company GRM for nearby residents, and disclose grievance plant publicity activities contact information to nearby communities regularly, and disclose before project implementation. emission data timely. The PIU should establish a communication • Makes jobs first available mechanism with communities during to local residents at the construction and operation to respond to construction and community requests (monthly during operation stages, construction and quarterly during operation). especially women and low-income residents. • Environmental monitoring data should be disclosed to stakeholders timely. Establish community assistance funds to The PIU should act on the SEP and GRM, disclose support relevant them to the public, and provide sufficient Bulky and facilities and services in resources to ensure their effective operation. Ningbo PMO decoration nearby communities, Ensure that nearby communities participate in Meijing waste thereby obtaining the project design, construction and operation, Company disposal plant support of nearby where the participation rate should not be less residents. than 70%, with particular attention paid to Establish an vulnerable groups’ needs. environmental education 88 Subproject Design optimization Mitigation measures Implementers platform, organize Take full advantage of online platforms, and set diversified education up an online disclosure and discussion module activities, and disclose for stakeholders to share project information. pollutant discharge data The PIU should assign someone to handle the timely. GRM for nearby residents, and disclose grievance Makes jobs first available contact information to nearby communities to local residents at the before project implementation. construction and The PIU should establish a communication operation stages, mechanism with communities during especially women and construction and operation to respond to low-income residents. community requests (monthly during construction and quarterly during operation). Environmental monitoring data should be disclosed to stakeholders timely. Establish community The PIU should act on the SEP and GRM, disclose assistance funds to them to the public, and provide sufficient support relevant resources to ensure their effective operation. facilities and services in The PIU should assign someone to handle the nearby communities, GRM for nearby residents, and disclose grievance thereby obtaining the contact information to nearby communities Ningbo PMO support of nearby before project implementation. WWTP Qingyuan residents. The PIU should establish a communication Company Makes jobs first available mechanism with communities during to local residents at the construction and operation to respond to construction and community requests (monthly during operation stages, construction and quarterly during operation). especially women and Environmental monitoring data should be low-income residents. disclosed to stakeholders timely. • The PIU should act on the SEP and GRM, disclose them to the public, and provide sufficient • Make jobs first available resources to ensure their effective operation. to nearby residents, 4 Recyclables • The PIU should assign someone to handle the Ningbo PMO especially women and sorting GRM for nearby residents, and disclose grievance Dabashou low income residents, at centers contact information to nearby communities Company the construction and before project implementation. operation stages. • Conduct environmental education by field visit, making residents (especially children) 89 Subproject Design optimization Mitigation measures Implementers understand the significance of the Project, and support the Project. 7.2.5 NIMBY risks 1) Analysis NIMBY is a cross-cutting issue, where nearby residents have concerns about impacts of waste collection, transfer and treatment facilities on their health, environment and local development, and may file complaint or even resist construction, thereby leading to community conflicts. The bulky and decoration waste disposal plant, WWTP, centralized plastic waste sorting and processing plant, and 4 recyclables sorting centers are waste processing enterprises, and may produce such negative impacts as noise, odor and flying dust during construction and operation. Nearby residents may complaint about or even impede construction in view of their own health, the surrounding environment and local development, potentially triggering social conflicts. In adequate information disclosure may aggravate grievances of nearby residents, who will not support the to-be constructed or reconstructed facilities under the Project, or even impede their operation, finally leading to NIMBY risks. • The bulky and decoration waste disposal plant, WWTP, and centralized plastic waste sorting and processing plant are located in the park, and the nearby social sensitive sites include Xuanpei, Bailiangqiao, Huijiang, Yushantou and Sanli Village, Qiaodong Town, and Yunfeng Village, Yinjiagn Town, Haishu District mainly, which are 1.0- 3.0km away from the base. • Recyclables sorting centers: The 4 recyclables sorting centers (two are existing facilities) are located in suburbs, surrounded by wasteland or other parks, far away from communities and tidy internally, so they have almost no impact on the living environment. 2) Existing management measures Ningbo resource recycling base is an important output of the World Bank-financed Ningbo Municipal Solid Waste Minimization and Recycling Project (P123323) which was closed in 2020. Ningbo Municipal Government has gained rich experience in improving the local living environment, and strengthening pollution supervision and control in conjunction with new countryside building. The base has won the China Circular Economy Best Practice Award, and is selected as a provincial demonstration base for industrial tourism and a municipal popular science education base. The Project’s NIMBY risk mitigation experience has been extended throughout the province. • For community health and safety impacts and risks, the competent municipal authorities, including the office for letters and visits, ecology and environment bureau, and urban administration bureau, offer hotlines, office reception and other grievance 90 redress channels, and the relevant sub-district offices have set up a special division to receive grievances. • Various measures have been taken to deepen the public awareness of the Project, such as township and village official meeting, expert lecture, and field visit, and consultation has been conducted on construction, LAR, environmental protection, etc. • A domestic waste museum has been built, and is also an education base. Its internal gymnasium and outdoor basketball courts are open to nearby residents for free. Ningbo PMO has established a GRM for nearby residents. For grievances about noise, odor, etc., the competent municipal authorities, including the office for letters and visits, ecology and environment bureau, and urban administration bureau, offer hotlines, office reception and other grievance redress channels, and the relevant sub-district offices have set up a special division to receive grievances. 3) Rating It should be noted that the WWTP, and centralized plastic waste sorting and processing plant are typical NIMBY facilities, which may have cumulative E&S impacts on nearby residents. Therefore, NIMBY risks will always exist, and can be mitigated effectively if well handled, otherwise new NIMBY risks are likely to occur. See Table 7-15. Table 7-15 Ratings of NIMBY and Inadequate Stakeholder Engagement Risks Construction stage Operation stage Subproject Risk Rating14 Risk Rating Villagers in the two villages Slight odor, low noise, far Centralized plastic affected by LA may claim more away from settlements, low waste sorting and M M compensation and raise more environmental impacts processing plant environmental requirements. Nearby communities may raise Slight odor, low noise, far Bulky and decoration more environmental M away from settlements, low M waste disposal plant requirements. environmental impacts Those affected by the landfill may Odor and flying ash WWTP M M file appeals. Small scale, slight odor, far away Small scale, slight odor, far Recyclables sorting from settlements, low L away from settlements L centers environmental impacts 4) Design optimization and mitigation measures 14H stands for high risk, S for substantial risk, M for medium risk, and L for low risk. 91 Through consultation with the PIUs, the social team has proposed the following design optimization and mitigation measures based on the risks identified above. Table 7-16 Design Optimization and Mitigation Measures (NIMBY Risks) Subproject Design optimization Mitigation measures Implementers The PIU should disclose project information by means of official website, on-site billboard and community bulletin board within one month before construction, assign someone to handle Make a rational layout, and keep the GRM for nearby residents, and high-noise equipment, main disclose grievance contact information discharge ports, etc. away from Centralized to nearby communities before project Ningbo PMO plastic waste nearby sensitive sites. implementation. Haijing sorting and Improve the construction plan The PIU should establish a Company processing plant and make rational construction communication mechanism with arrangements to minimize communities during construction and impacts on community. operation to respond to community requests (monthly during construction and quarterly during operation). Environmental monitoring data should be disclosed to stakeholders timely. The PIU should disclose project information by means of official website, on-site billboard and community bulletin board within one month before construction, assign someone to handle Make a rational layout, and keep the GRM for nearby residents, and high-noise equipment, main disclose grievance contact information discharge ports, etc. away from to nearby communities before project Bulky and Ningbo PMO nearby sensitive sites. decoration waste implementation. Meijing disposal plant Improve the construction plan Company The PIU should establish a and make rational construction communication mechanism with arrangements to minimize communities during construction and impacts on community. operation to respond to community requests (monthly during construction and quarterly during operation). Environmental monitoring data should be disclosed to stakeholders timely. 92 Subproject Design optimization Mitigation measures Implementers The PIU should disclose project information by means of official website, on-site billboard and community bulletin board within one month before Make a rational layout, and keep construction, assign someone to handle high-noise equipment, main the GRM for nearby residents, and discharge ports, etc. away from disclose grievance contact information nearby sensitive sites. to nearby communities before project Ningbo PMO Select a suitable deodorization WWTP implementation. Qingyuan process. The PIU should establish a Company Improve the construction plan communication mechanism with and make rational construction communities during construction and arrangements to minimize operation to respond to community impacts on community. requests (monthly during construction and quarterly during operation). Environmental monitoring data should be disclosed to stakeholders timely. The PIU should disclose project information by means of official website, on-site billboard and community bulletin board within one month before Make a rational layout, and keep construction, assign someone to handle high-noise equipment, main the GRM for nearby residents, and discharge ports, etc. away from disclose grievance contact information Ningbo PMO 4 recyclables nearby sensitive sites. to nearby communities before project Dabashou sorting centers Improve the construction plan implementation. Company and make rational construction The PIU should establish a arrangements to minimize communication mechanism with impacts on community. communities during construction and operation to respond to community requests (monthly during construction and quarterly during operation). 93 8 SMP The SIA agency first analyzes the risk management measures that have been taken by the owner in practical management and design, and assesses social performance and potential gaps based on public participation results during the social audit and SIA; then, it proposes mitigation measures based on the mitigation hierarchy according to the ESSs relevant ESSs; finally, the SIA agency and owner negotiate the mitigation measures proposed in this report, define the responsibilities of the agencies concerned, and a mitigation hierarchy. The SMP aims to improve the overall project benefits, and minimize negative impacts and social risks through appropriate measures. A detailed SEP will be developed to identify stakeholders, and propose planning, design, preparation, implementation and M&E recommendations. The mitigation measures proposed for the social impacts and form an SMP, including an implementation schedule, PIUs and monitoring arrangements. The SMP can be implemented in stages. A low management level may be maintained in the first 3-5 years, and the standard should be improved continually later. See Table 8-1 to Table 8-4 where proposed actions will be conducted by the pertinent PIU. 94 Table 8-1 SMP for WWTP of Ningbo Resource Recycling Base Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time • Evaluate LMP implementation by full- • Establish and implement an appropriate time staff, and reflect this in project LMP. progress reports. • Improve the GRM for workers (direct • Men-times of trainees of regular and contracted). induction and OHS training for workers • Strengthen the management of PPE use. (by gender and target group) Organized by • OHS facilities must be designed, • Percentage of licensed drivers Labor and 100,000 yuan PMO constructed and commissioned along • Inspection records on PPE use by 2022-2026 1 working Counterpart Involving with the main part, and their investment workers Semiannual condition risks funds and loan Qingyuan included in the project budget. • Regular health checkup reports of Company • Conduct occupational hazard workers monitoring, and biennial occupational • Frequency and records of occupational health checkups. hazard monitoring • Conduct a fire safety emergency drill • Frequency, number of participants and annually. records of emergency drills • Modes and frequency of grievances Community • Improve the construction plan and make • Regulations against different types of 100,000 yuan 2022-2026 Organized by 2 health and safety rational construction arrangements to risks during construction Counterpart Semiannual PMO risks minimize impacts on community. • Positions and numbers of safety signs funds and loan 95 Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time • Set up safety signs at key traffic points in • Frequency of public health and anti- Involving communities, and give safety education AIDS training, and number of Qingyuan to local residents, including women, participants (by gender and target Company children and old people. group) • Develop measures for driver and vehicle • Forms of publicity on AIDS, pandemic, management, such as pre-job training, SEA/SH and drug prevention threshold setting and sign setup, to • Modes and frequency of grievances reduce traffic accidents. • Establish a formal community communication mechanism to strengthen community communication, and respond to community concerns timely. • The PIU should act on the SEP and GRM, • Use of local labor, and numbers of disclose them to the public, and provide female and low-income laborers sufficient resources to ensure their • Types, frequency and participants Organized by Stakeholder effective operation. (gender, low-income) of education 100,000 yuan PMO 2022-2026 3 engagement • Establish an environmental monitoring activities Counterpart Involving Semiannual risks information disclosure system. • Types, frequency and participants funds and loan Qingyuan • Ensure that nearby communities (gender, low-income) of opinion Company participate in project design, collection activities by the PMO, PIUs, construction and operation, with and township and village organizations 96 Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time particular attention paid to vulnerable • Modes and frequency of grievances groups’ needs. • The PIU should establish a communication mechanism with communities during construction and • Types, frequency and participants operation to respond to community (gender, low-income) of joint meetings, requests (monthly during construction and number of villages covered and quarterly during operation). • Number and operation of community • Establish community assistance funds to assistance funds support nearby villages run facilities • Number and operation of new facilities Organized by and services, and perform corporate and services 100,000 yuan PMO social responsibility to win the support • Use of local labor, and numbers of 2022-2026 4 NIMBY risks Counterpart Involving of nearby residents. female and low-income laborers Semiannual funds and loan Qingyuan • Make jobs first available to nearby • Types, frequency and participants Company residents, especially women and low (gender, low-income) of education income residents, at the construction activities and operation stages. • Types, frequency and participants • Organize diversified education activities, (gender, low-income) of opinion and disclose pollutant discharge data collection activities by the PMO, PIUs, timely. Conduct stakeholder and township and village organizations engagement on any substantial change to the project scope. Disclose site 97 Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time operation and environmental indicators regularly at the operation stage. Table 8-2 SMP for Centralized Plastic Waste Sorting and Processing Plant Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time • Establish and implement an appropriate • Evaluate LMP implementation by LMP. full-time staff, and reflect this in • Improve the GRM for workers (direct and project progress reports. contracted). • Men-times of trainees of regular • Conduct regular social monitoring on induction and OHS training for 100,000 Organized by contracted worker management, and make workers (by gender and target yuan PMO Labor and working improvement based on suggestions. group) 2022-2026 1 Counterpart Involving condition risks • Strengthen the management of PPE use. • Percentage of licensed drivers Semiannual funds and Meijing • OHS facilities must be designed, constructed • Inspection records on PPE use by loan Company and commissioned along with the main part, workers and their investment included in the project • Regular health checkup reports of budget. workers • Conduct occupational hazard monitoring, • Frequency and records of and biennial occupational health checkups. occupational hazard monitoring 98 Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time • Conduct a fire safety emergency drill • Frequency, number of participants annually. and records of emergency drills • Modes and frequency of grievances • Solve outstanding issues based on the suggestions in the social audit report, and conduct M&E. • Strengthen communication with Xuanpei Village, and complete relocation and Organized by resettlement 3 months before the start of • E&S agency appointed PMO construction. 100,000 • Mode of information disclosure of Involving • Notify the occupants of the worker yuan compensation policies 2022-2026 Meijing 2 LAR risks dormitory to move 3 months before the start Counterpart • Handling of outstanding issues Semiannual Company of construction. funds and • Approvals of land allocation or Monitored by a • Complete land use right consultation in loan transfer third-party coordination with the Haishu District Urban M&E agency Administration Bureau, and complete equipment relocation by the end of December 2022. • Strengthen communication with the competent authorities, and complete land 99 Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time allocation or transfer before the start of construction. • Improve the construction plan and make rational construction arrangements to minimize impacts on community. • Regulations against different types of risks during construction • Set up safety signs at key traffic points in • Positions and numbers of safety communities, and give safety education to signs local residents, including women, children 100,000 Organized by • Frequency of public health and anti- and old people. yuan PMO Community health AIDS training, and number of 2022-2026 3 • Develop measures for driver and vehicle Counterpart Involving and safety risks participants (by gender and target Semiannual management, such as pre-job training, funds and Meijing group) threshold setting and sign setup, to reduce loan Company • Forms of publicity on AIDS, traffic accidents. pandemic, SEA/SH and drug • Establish a formal community prevention communication mechanism to strengthen • Modes and frequency of grievances community communication, and respond to community concerns timely. • Use of local labor, and numbers of • The PIU should act on the SEP and GRM, female and low-income laborers Stakeholder disclose them to the public, and provide 100,000 2022-2026 Organized by 4 • Types, frequency and participants engagement risks sufficient resources to ensure their effective yuan Semiannual PMO (gender, low-income) of education operation. activities 100 Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time • Establish an environmental monitoring • Types, frequency and participants Counterpart Involving information disclosure system. (gender, low-income) of opinion funds and Meijing • Ensure that nearby communities participate collection activities by the PMO, loan Company in project design, implementation and PIUs, and township and village operation, and pay particular attention to organizations needs of vulnerable groups. • Modes and frequency of grievances • The PIU should establish a communication • Types, frequency and participants mechanism with communities during (gender, low-income) of joint construction and operation to respond to meetings, and number of villages community requests (monthly during covered construction and quarterly during • Number and operation of operation). community assistance funds 100,000 Organized by • Establish community assistance funds to • Number and operation of new yuan PMO support nearby villages run facilities and 2022-2026 5 NIMBY risks facilities and services Counterpart Involving services, and perform corporate social Semiannual • Use of local labor, and numbers of funds and Meijing responsibility to win the support of nearby female and low-income laborers loan Company residents. • Types, frequency and participants • Make jobs first available to nearby residents, (gender, low-income) of education especially women and low-income residents, activities at the construction and operation stages. • Types, frequency and participants • Organize diversified education activities, and (gender, low-income) of opinion disclose pollutant discharge data timely. 101 Budget and Completion No. Potential risks Actions Monitoring indicators Implementers sources time Conduct stakeholder engagement on any collection activities by the PMO, substantial change to the project scope. PIUs, and township and village Disclose site operation and environmental organizations indicators regularly at the operation stage. 102 Table 8-3 SMP for the Bulky and Decoration Waste Disposal Plant Potential Budget and Completion No. Actions Monitoring indicators Implementers risks sources time • Establish and implement an appropriate LMP. • Evaluate LMP implementation by full- • Improve the GRM for workers (direct and time staff, and reflect this in project contracted). progress reports. • Conduct regular social monitoring on contracted • Men-times of trainees of regular worker management, and make improvement induction and OHS training for workers based on suggestions. (by gender and target group) 100,000 Organized by Labor and • Strengthen the management of PPE use by • Percentage of licensed drivers yuan PMO working workers. • Inspection records on PPE use by 2022-2026 1 Counterpart Involving condition • OHS facilities must be designed, constructed and workers Semiannual funds and Haijing risks commissioned along with the main part, and • Regular health checkup reports of loan Company their investment included in the project budget. workers • Conduct occupational hazard monitoring, and • Frequency and records of occupational biennial occupational health checkups. hazard monitoring • Conduct a fire safety emergency drill annually. • Frequency, number of participants and records of emergency drills • Modes and frequency of grievances • Make clear the LAR compensation policies and • RAP 100,000 2022-2026 Organized by 2 LAR risks rates, and ensure compliance with the Bank and • E&S agency appointed yuan Semiannual PMO domestic requirements. 103 Potential Budget and Completion No. Actions Monitoring indicators Implementers risks sources time • Prepare an RAP and make it approved by the • Mode of information disclosure of Counterpart Involving Bank. compensation policies funds and Haijing • Act on the approved RAP. • Livelihood restoration of affected loan Company • Appoint a third party for M&E. persons Monitored by a • Effectiveness of the GRM third-party M&E agency • Land use approvals • Improve the construction plan and make • Regulations against different types of rational construction arrangements to minimize risks during construction impacts on community.; • Positions and numbers of safety signs • Frequency of public health and anti- • Set up safety signs at key traffic points in AIDS training, and number of communities, and give safety education to local participants (by gender and target residents, including women, children and old 100,000 Organized by group) Community people. yuan PMO • Forms of publicity on AIDS, pandemic, 2022-2026 3 health and • Develop measures for driver and vehicle Counterpart Involving SEA/SH and drug prevention Semiannual safety risks management, such as pre-job training, threshold funds and Haijing • Modes and frequency of grievances setting and sign setup, to reduce traffic loan Company accidents. • Establish a formal community communication mechanism to strengthen community communication, and respond to community concerns timely. 104 Potential Budget and Completion No. Actions Monitoring indicators Implementers risks sources time • The PIU should act on the SEP and GRM, disclose • Use of local labor, and numbers of them to the public, and provide sufficient female and low-income laborers resources to ensure their effective operation. • Types, frequency and participants 100,000 Organized by (gender, low-income) of education Stakeholder • Establish an environmental monitoring yuan PMO activities 2022-2026 4 engagement information disclosure system. Counterpart Involving • Types, frequency and participants Semiannual risks • Ensure that nearby communities participate in funds and Haijing (gender, low-income) of opinion project design, implementation and operation, loan Company collection activities by the PMO, PIUs, and pay particular attention to needs of and township and village organizations vulnerable groups. • Modes and frequency of grievances • The PIU should establish a communication • Types, frequency and participants mechanism with communities during (gender, low-income) of joint meetings, construction and operation to respond to and number of villages covered community requests (monthly during • Number and operation of community construction and quarterly during operation). 100,000 Organized by assistance funds yuan PMO • Establish community assistance funds to • Number and operation of new facilities 2022-2026 5 NIMBY risks Counterpart Involving support nearby villages run facilities and and services Semiannual services, and perform corporate social funds and Haijing • Use of local labor, and numbers of responsibility to win the support of nearby loan Company female and low-income laborers residents. • Types, frequency and participants (gender, low-income) of education activities 105 Potential Budget and Completion No. Actions Monitoring indicators Implementers risks sources time • Make jobs first available to nearby residents, • Types, frequency and participants especially women and low-income residents, at (gender, low-income) of opinion the construction and operation stages. collection activities by the PMO, PIUs, • Organize diversified education activities, and and township and village organizations disclose pollutant discharge data timely. Conduct stakeholder engagement on any substantial change to the project scope. Disclose site operation and environmental indicators regularly at the operation stage. 106 Table 8-4 SMP for the 4 Recyclable Sorting Centers Potential Budget and Completion No. Actions Monitoring indicators Implementers risks sources time • Establish and implement an appropriate LMP. • Evaluate LMP implementation by full- • Improve the GRM for workers (direct and time staff, and reflect this in project contracted). progress reports. • Conduct regular social monitoring on contracted • Men-times of trainees of regular worker management, and make improvement induction and OHS training for based on suggestions. workers (by gender and target group) 100,000 Organized by Labor and • Strengthen the management of PPE use by • Percentage of licensed drivers yuan PMO working workers. • Inspection records on PPE use by 2022-2026 1 Counterpart Involving condition • OHS facilities must be designed, constructed and workers Semiannual funds and Dabashou risks commissioned along with the main part, and • Regular health checkup reports of loan Company their investment included in the project budget. workers • Conduct a fire safety emergency drill annually. • Frequency and records of occupational hazard monitoring • Frequency, number of participants and records of emergency drills • Modes and frequency of grievances • Ningbo PMO and Dabashou Company should • Effectiveness of the GRM 100,000 2022-2026 Organized by 2 LAR risks strengthen coordination with the competent • Approvals of land allocation or transfer yuan Semiannual PMO 107 Potential Budget and Completion No. Actions Monitoring indicators Implementers risks sources time authorities to obtain the land for the Project as Counterpart Involving soon as possible. funds and Dabashou • Strengthen communication with the competent loan Company authorities, and obtain relevant approvals of the Monitored by a right to use state-owned land before the start of third-party construction (or equipment installation). M&E agency • Disclose project information by means of official • Types, frequency and participants website, on-site billboard, community bulletin (gender, low-income) of joint board, etc. one month before construction. meetings, and number of villages • The PIU should assign someone to handle the covered GRM for nearby residents, and disclose • Number and operation of community grievance contact information to nearby assistance funds 100,000 Organized by communities before project implementation. • Number and operation of new facilities yuan the PMO 2022-2026 3 NIMBY risks • The PIU should establish a communication and services Counterpart Involving Semiannual mechanism with communities during • Use of local labor, and numbers of funds and Dabashou construction and operation to respond to female and low-income laborers loan Company community requests (monthly during • Types, frequency and participants construction and quarterly during operation). (gender, low-income) of education activities • Types, frequency and participants (gender, low-income) of opinion 108 Potential Budget and Completion No. Actions Monitoring indicators Implementers risks sources time collection activities by the PMO, PIUs, and township and village organizations • Improve the construction plan and make • Regulations against different types of rational construction arrangements to minimize risks during construction impacts on community. • Positions and numbers of safety signs • Set up safety signs at key traffic points in • Frequency of public health and anti- communities, and give safety education to local AIDS training, and number of residents, including women, children and old participants (by gender and target 100,000 Organized by Community people. group) yuan the PMO 2022-2026 4 health and • Develop measures for driver and vehicle • Forms of publicity on AIDS, pandemic, Counterpart Involving Semiannual safety risks management, such as pre-job training, threshold SEA/SH and drug prevention funds and Dabashou setting and sign setup, to reduce traffic loan Company • Modes and frequency of grievances accidents. • Establish a formal community communication mechanism to strengthen community communication, and respond to community concerns timely. Stakeholder • The PIU should act on the SEP and GRM, disclose • Use of local labor, and numbers of 100,000 2022-2026 Organized by 5 engagement them to the public, and provide sufficient female and low-income laborers yuan Semiannual the PMO risks resources to ensure their effective operation. 109 Potential Budget and Completion No. Actions Monitoring indicators Implementers risks sources time • Establish an environmental monitoring • Types, frequency and participants Counterpart Involving information disclosure system. (gender, low-income) of education funds and Dabashou • Ensure that nearby communities participate in activities loan Company project design, implementation and operation, • Types, frequency and participants and pay particular attention to needs of (gender, low-income) of opinion vulnerable groups. collection activities by the PMO, PIUs, and township and village organizations • Modes and frequency of grievances 110 9 Institutional Arrangements and Capacity Building 9.1 Institutional Arrangements The organizational structure for social management is shown in Figure 9-1. Project Management Office (PMO) Social management M&E agency Haijing Dabashou Meijing Qingyuan Company Company Company Company (PIU) (PIU) (PIU) (PIU) Figure 9-1 Organizational Chart The main responsibilities of all departments concerned are: 1) Ningbo Project Management Office (PMO) • Guiding and supervising the PIUs to carry out relevant E&S management work of the subprojects in accordance with the requirements of the ESMF, and E&S management documents approved by the Bank; • Assigning at least one full-time staff to coordinate the implementation of the E&S management framework, and maintaining contact with World Bank E&S experts during the implementation period; • Hiring external E&S monitoring consultants to conduct external monitoring of the Project’s E&S management and prepare external monitoring reports, and reporting to the Bank every six months. • Ensuring that relevant measures and requirements in the E&S management plans are included in the bidding documents; • Screening the E&S risk levels of subprojects with the assistance of an external expert group, reviewing E&S safeguards documents, and submitting them to the Bank for review as necessary; • Carrying out E&S management capacity building for subproject implementation units; • Supervise the implementation of applicable E&S safeguards documents (EMP, SAP, LMP, SAP, etc.); • Ensuring funds for project implementation 111 2) PIUs • Establishing internal organization and assigning staff responsible for E&S management; • Assigning a full-time E&S staff member to implement E&S documents; • Conducting relevant stakeholder consultation activities in accordance with the requirements of the SEP; • Supervising the implementation of E&S management measures; • Submitting periodic subproject progress reports to the PMO; 9.2 Capacity Building The social team has found that though Ningbo PMO has participated in the implementation of a previous Bank-financed project, it is implementing E&S management measures and requirements under the Bank’s ESF for the first time. In addition, since the 4 PIUs are newly established to implement a Bank-financed project for the first time, they lack social management experience. In order to implement the SMP more effectively, and ensure that the affected persons benefit from the Project, Ningbo PMO will take the following measures to strengthen institutional capacity: 1) Strengthen training for the PIUs through social and resettlement expert with experience in Bank-financed projects, so that the PIUs fully understand the Bank’s requirements, applicable state laws and regulations, the types and purposes of social management documents, and methods and schedule to implement the measures under the SMP. 2) Establish an internal supervision mechanism, a feedback mechanism, and a social risk early warning system from the PMO to the PIUs. The staff specializing in social management should have a holistic view, excellent policy understanding and professionalism, and experience in dealing with the public. 3) Information disclosure: All E&S documents should be disclosed to the public for supervision. 4) Establish an external M&E mechanism, and appoint an independent third party with experience in Bank-financed projects to monitor and evaluate SMP and RAP implementation. 112 Table 9-1 Social Management Capacity Building Schedule Resource / Men- Time Trainees Key points Objective Mode Frequency trainer times (day) 1) The Bank’s ESSs; Strengthening the 2) Approved ESMF, SEP, LMP and ESCP; social management capacity of the 3) SMP and M&E; Bank specialist or Ningbo PMO Lecture, At least once a 4) SEP and LMP implementation and appointed social Ningbo PMO 10 seminar and 1 year during management; and resettlement field visit implementation 5) Implementation and M&E of E&S measures; specialist 6) Ningbo PMO’s requirements for social and resettlement management 1) The Bank’s ESSs; Strengthening the 2) Approved ESMF, SEP, LMP and ESCP; E&S management knowledge and Workshop (high- 3) SMP and M&E; capacity of external level) 4) SEP and LMP implementation and Bank specialist or specialists Lecture, At least twice a External management; appointed social 20 seminar and 1 year during specialist 5) Implementation and M&E of E&S measures; and resettlement field visit implementation consulting specialist 6) Organizational setup and capacity building services for social and resettlement management 7) The Bank’s policy and requirements for social and resettlement M&E 113 Resource / Men- Time Trainees Key points Objective Mode Frequency trainer times (day) 1) The Bank’s ESSs; Strengthening the 2) Approved ESMF, SEP, LMP and ESCP; social and OHS management 3) SMP and M&E; capacity of the PIUs Bank specialist or 4) SEP and LMP implementation and Lecture, At least twice a and their social appointed social PIUs management; 20~30 seminar and 1 year during management staff and resettlement 5) Implementation and M&E of E&S measures; field visit implementation specialist 6) PIUs’ requirements for social and resettlement management 7) GRM and file management 114 10 M&E 10.1 Internal Monitoring Ningbo PMO is responsible for monitoring the E&S performance of the entire project implementation process. The dedicated E&S staff in the PMO shall be responsible for collecting and processing information related to E&S management in a timely manner, regularly tracking the implementation status of subprojects, inspecting the E&S performance of subprojects on- site, identifying problems and making suggestions for improvement. At the same time, the PMO must give full play to the coordination role, require all district PMOs and PIUs to assume the responsibility in the E&S performance of their subprojects, and ensure that relevant E&S impact mitigation measures are effectively implemented at the project level. The PIUs are responsible for the E&S performance, including designation of E&S department with dedicated staff, supervision of the implementation of mitigation measures in the E&S documents, and regular reporting to the PMO on the E&S progress. The supervising agencies will be hired for all construction activities to conduct construction supervision tasks, including the E&S measures as stipulated in the construction contracts. Supervision companies will identify on-site E&S problems in a timely manner, put forward correction requirements, and ensure that the E&S management of the project construction meets the contract requirements, and reflect the E&S performance situation in their monthly supervision reports. 10.2 External Monitoring In addition to daily management and supervision of E&S performance by the PMO and PIUs, the PMO will also engage a third-party monitoring agency to conduct independent monitoring of E&S performance. The external E&S monitoring agency will be engaged by Ningbo PMO to monitor the E&S performance of all project activities, and submit M&E opinions and reports. The responsibilities of the consultants are: a) Reviewing whether the construction organization design, environmental management plan, safety production plan, traffic management plan and other documents of the contractors meet the requirements of the approved E&S documents; b) Assisting the PMO and PIUs to carry out E&S management training for contractors and supervising agencies, covering labor management, stakeholder engagement, etc.; assisting in investigating and dealing with E&S emergencies or accidents; c) Monitoring the implementation of the social action plan and other social management documents, including consultation and investigation for the APs; d) Periodically submitting monitoring reports to the PMO and PIUs. In addition, relevant government departments will also have their regulatory monitoring over project construction and operation. 115 During project implementation, the Bank will also conduct regular field missions to monitor and support the compliance E&S performance. 10.3 Reporting System The PIUs will prepare regular progress reports (once every six months) on the progress and performance of SMP, ESCP, and other related plans (such as SEP), and submit to the PMO. Ningbo PMO will summarize the overall E&S performance and issues of all subprojects, prepare an E&S progress report every six months, and submit it to the Bank as part of the project progress report. The external E&S monitoring agency will prepare an external monitoring report every six months, and submit to the PMO. These external reports will be provided to the Bank together with the PMO’s semiannual progress reports. 116 Appendix 1 Public Consultation Records Table 1 Completed Public Consultation Activities and Key Findings Date Venue Stakeholders # Methods Topic Results The feasibility study report is complete. The Project is rational in scale, design, investment and economy. The NMII report can serve as a basis for subsequent work. Municipal urban administration bureau Internal review The general play is further optimized. Dec Meeting Municipal environmental sanitation meeting on the The operation scheme of the existing 800t/d wastewater 23, room of center 15 FGD feasibility study of treatment system at the construction stage is further 2020 NMII Central South Architectural Design the Project refined. Institute The effluent indicators for enterprises in the base are Other experts defined. The equipment investment is further rationalized. NMII Organizatio All wastewater produced by enterprises in the park Feb Meeting Consultation on Municipal urban administration bureau nal should be discharged into the WWTP under the Project. 10, room of 11 issues related to Municipal finance bureau interview The future charging logic based on the factor method is 2021 NMII the Project Ningbo PMO FGD defined. Project Long-term land should be reserved for the WWPT based NMII Mar Meeting introduction on the regulatory land plan of the Ningbo resource Municipal finance bureau 23, room 1615 20 FGD Coordination of recycling base. NDWSGC 2021 of NMII charging All wastewater produced by enterprises in the park Shouchuang Kitchen Waste Plant mechanism should be discharged into the WWTP of the Ningbo 117 Date Venue Stakeholders # Methods Topic Results Kaicheng Kitchen Waste Plant resource recycling base, and water quality indicators will NBSMC Renewable Resources be defined after consultation. Technology Co., Ltd. The wastewater discharge rate will be fixed based on the Yemao’ao landfill budget in the preliminary design and after water quality indicator calculation. Central South Architectural Design Institute Discharging enterprises should optimize their wastewater to reduce operating costs of the WWTP of the Ningbo resource recycling base; A certain overload should be allowed for the WWTP. The effluent water quality of the WWTP should reach the Class B level in the wastewater quality standard for discharge to municipal sewers (GB/T31962-2015), to be finally based on the EIA approval. Sewers of discharging enterprises should be designed, constructed and operated in step with the WWTP. Municipal comprehensive enforcement All wastewater produced by enterprises in the Ningbo FGD Project bureau resource recycling base will be discharged into the Key introduction May Meeting Municipal development and reform reconstructed/expanded WWTP for centralized informant EIA coordination 19, room 1615 commission 12 treatment. interview Definition of two 2021 of NMII Municipal finance bureau Since the Yemao’ao landfill has been closed temporarily, Questionnai tail water Municipal ecology and environment the leachate treatment capacity of the landfill under the re survey indicators bureau Project remains unchanged. 118 Date Venue Stakeholders # Methods Topic Results NDWSGC Opinions on and The EIA report will be approved by the municipal ecology District ecology and environment attitudes to the and environment bureau. bureau Project The municipal development and reform commission, NMII municipal finance bureau, and other agencies concerned will work on the Project together. Renxin Environmental Research Institute Municipal comprehensive enforcement bureau Municipal development and reform Influent water quality indicators will be determined commission rationally in full consultation with the EIA agency and in Municipal finance bureau consideration of WWTP reception. Municipal ecology and environment All design parameters are verified. Meeting Internal review Jun 8, bureau The general plan is optimized to reduce the investment room 1615 14 FGD meeting on 2021 NDWSGC and operating costs. of NMII preliminary design District ecology and environment Measures should be taken during construction in order bureau not to affect the operation of the existing system. NMII The construction agency should provide existing building Renxin Environmental Research information as soon as possible. Institute Other consulting agencies Source: E&S survey, interviews and consultation with departments concerned 119 Table 2 FGDs in Affected Villages # of Stakeholder Key points participants 1) LA compensation rates should be fixed rationally, not less than that for the landfill (Phase 2) in 2018 (80,000 yuan/mu); Xuanpei 15 2) Commercial crops and big trees should be compensated through appraisal; Village 4) A sharing mechanism should be established, where the village collective and villagers can earn money by equity participation or otherwise. 1) Villagers often complain about odor generated by the kitchen waste disposal plant Bailiangqiao and incineration plant; 12 Village 2) Compensation rates should be fixed rationally, and the highest policy rates should apply. 1) Villagers often complain about odor and black smoke, and have little trust in operation management; Huijiang 2) Monitoring data is not notified to villagers as promised, aggravating their worries 8 Village about environmental problems; 3) There is a strong wish for relocation, and the new village should not be worse than that of Xuanpei Village. 1) Vehicle odor affects villagers seriously; 2) Some vehicles have a leakage problem, and spills flow into the village with rain, Yushantou 7 affecting the village environment greatly; Village 3) Villagers are affected seriously by the nearby industrial park and waste disposal facility, and expect the new village to be constructed as soon as possible. 1) This village is located in a low-lying area, and wastewater brought down by rain affects the river greatly; 2) The new village has been completed, but its house value is affected by the existing Sanli Village 6 waste disposal facility; the housing land in the new village should be converted into state-owned construction land; 3) An environmental monitoring station should be set up, and air quality monitoring data disclosed. Source: E&S survey, interviews and consultation with departments concerned 120 Appendix 2 LMP for PIUs Appendix 2.1 LMP for Bulky and Decoration Waste Treatment Plant The bulky and decoration waste treatment plant (hereinafter, “this subproject”) is one of the Batch 2 subprojects. Its owner is Ningbo Meijing Construction Waste Recycling Technology Co., Ltd. (hereinafter, “the Company”), which was founded in May 2021. The Company is 40% funded by Ningbo Fubang Green Energy Technology Co., Ltd., 30% by Ningbo Public Utilities Investment Co., Ltd., and 30% by Ningbo Ecological & Environmental Protection Group Co., Ltd., with a registered capital of 40 million yuan. Its business scope is the disposal of bulky, decoration and construction waste, the processing, production and sale of building materials, the sale of recycled waste, the preparation and sale of regenerated building materials, and the sale of biomass briquette fuels This LMP is a living document, and the current version is based on the SIA on the Batch 2 subprojects, and the Company’s HR policies and management systems. In October 2021, the Company established a series of HR and work safety systems. With the progress of the Project, the Company will further improve its LMP in accordance with the World Bank’s ESS2, and the applicable laws and regulations of China. 1 Overview of Project Workers According to the definition of project workers in ESS2, project activities, key informant interviews and document review, this subproject involves direct workers and contracted workers. Direct Hires: People employed directly by Ningbo Municipal PMO and PIUs specifically for project management 15 , including technicians and operation and management staff, all with relevant experience. Contract Workers: Those employed including construction workers of this subproject, and workers of the third-party operation company that may be appointed at the operation stage (i.e. drivers, etc.) Based on local residents’ needs, bulky and decoration waste will be collected door -to-door with appointments made through the smart project management system constructed under the Project, so this subproject has no direct primary supplier. In this subproject, primary suppliers’ workers are workers at the recyclable sorting centers mainly. An estimate of types and numbers of workers is shown in Table 1. Table 1 Estimate of Types and Numbers of Project Workers Subproject Stage Direct hires Contract workers Primary suppliers’ workers Civil works 10 200 0 Bulky and Construction decoration Equipment installation 5 15 0 waste Operation 80 5016 0 15 Some workers may be full-time or part-time civil servants. If there is no valid transfer certificate indicating that he/she has been employed for the Project, his/her public sector employment agreement applies, and the requirements on labor protection (Clauses 17~20) and OHS (Clauses 24~30) of ESS2 should be met. 16 Mostly drivers of bulky and construction waste, to be recruited by a third-party labor service company 121 Subproject Stage Direct hires Contract workers Primary suppliers’ workers disposal plant Source: estimated by the Company All direct hires will be from the Company. Since the Company has been newly established, it has a workforce of less than 5 persons, all having undergraduate or above education. The Company is in the process of recruiting more staff. The Company will review labor management systems of bidding contractors through its bidding mechanism, and ask contractors to establish labor management procedures in accordance with ESS2. Bidding is under preparation, and it is uncertain if contracted workers include non-local workers, which will be further identified during implementation. 2 Screening of Potential Significant Labor Risks 2.1 Subproject activities This subproject is located in the Ningbo resource recycling base, with a floor area of 59.2 mu and a total new building area of 22,150 m2. After completion, it will have a total treatment capacity of 300,000 tons of bulky and decoration waste, and 60,000 tons of existing waste annually. It will build a bulky waste production line with capacity of treating 45,000 tons of bulky waste annually, a RDF (refuse derived fuel) production line with an annual capacity of 82,000 tons, and a production line with an annual capacity of 18 million reclaimed bricks. 2.2 Major labor risks At the preparation stage, a social impact survey and extensive stakeholder engagement were conducted on this subproject, and major labor risks were identified. According to the SIA of the Batch 2 subprojects, as the Project is located in the developed city of Ningbo, where the government has a well-established labor management and supervision systems for enterprises, so this subproject’s labor risks are negligible or very low, mainly including: • Forced labor and child labor • Discrimination in recruitment According to the scope, scale and nature of this subproject, major labor risks related that may be encountered by workers include: A. Construction stage • Dangerous work: Construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials; • Safety risks in machinery operation: Accidents of construction workers during construction, such as welding, cutting or operating relevant tools; • Noise from mechanical construction: Loud, repeated and excessive noises that may arise during construction, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks; • Emergency risks: Emergencies and quality safety accidents arising from unsound civilized construction and quality safety management measures, or inadequate management; • Sexual harassment or gender-based violence risks: Physical or mental violence against women due to gender or lifestyle differences; • Workplace accidents: Accidents arising from work shed collapse due to quality 122 problems or natural disasters; • Health and infection risks: Disease infection risks (e.g., COVID-19) arising from the improper diet and accommodation management, or health management of construction workers; • Salaries and benefits: Workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts; B. Operation stage • Traffic: Potential traffic accidents during the transport of collected bulky and construction waste; • Noise from machinery operation: Noises generated by sorting and crushing machines, etc.; loud, repeated and excessive noise, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks; • Work-related injuries: Work-related injuries due to improper operations during the breakdown of bulky waste; • Dust pollution: Dust generated from the breaking down of bulky waste • Emergency accidents: Mistakes in the operation of smart equipment leading labor health and life risks; • Infection: Disease infection risks (e.g., COVID-19) during recyclable (waste) collection and transfer, and close contact with people. 3 Brief Overview of Labor Legislation: Terms and Conditions China has established a sound system of laws and regulations on labor management. As a member of the International Labor Organization (ILO), China has approved 26 conventions (including 20 that have taken effect), including equal remuneration, discrimination, minimum age, child labor, OHS, employment policy, consulting, risk of association, etc. In general, the Chinese and Ningbo policies make provisions on salary, working hours, labor protection and labor disputes, and prohibit forced labor and child labor, which is completely consistent with the requirements of ESS2. Table 2 Applicable PRC Laws relating to Labor and Working Conditions No. Title Effective year 1 China’s Labor Law 1995, amended in 2018 2 Provisions of the State Council on Working Hours of Workers and Staff 1995 3 China’s Emergency Incident Response Law 2007 4 Regulations on the Implementation of China’s Labor Contract Law 2008 5 China’s Labor Contract Law 2008, amended in 2012 6 Special Rules on Labor Protection of Female Employees 2012 7 China’s Law on the Prevention and Control of Occupational Diseases 2017 Table 3 List of ILO Conventions Approved by China Convention Date Basic conventions (4) C100 - Equal Remuneration Convention, 1951 (No.100) 1990.12.02 C111 - Discrimination (Employment and Occupation) Convention, 1958 2006.01.12 123 Convention Date (No.111) C138 - Minimum Age Convention, 1973 (No.138), specifying the minimum wage 1999.04.28 of 16 years C182 - Worst Forms of Child Labor Convention, 1999 (No.182) 2002.08.08 Governance (priority) conventions (2) C122 - Employment Policy Convention, 1964 (No.122) 1997.12.17 C144 - Tripartite Consultation (International Labor Standards) Convention, 1990.11.02 1976 (No.144) Technical conventions (14) C011 - Right of Association (Agriculture) Convention, 1921 (No.11) 1934.04.27 C014 - Weekly Rest (Industry) Convention, 1921 (No. 14) 1934.05.17 C019 - Equality of Treatment (Accident Compensation) Convention, 1925 (No. 1934.04.27 19) C026 - Minimum Wage-Fixing Machinery Convention, 1928 (No. 26) 1930.05.05 C027 - Marking of Weight (Packages Transported by Vessels) Convention, 1929 1931.06.24 (No. 27) C032 - Protection against Accidents (Dockers) Convention (Revised), 1932 (No. 1935.11.30 32) C045 - Underground Work (Women) Convention, 1935 (No. 45) 1936.12.02 C080 - Final Articles Revision Convention, 1946 (No. 80) 1947.08.04 C150 - Labor Administration Convention, 1978 (No. 150) 2002.03.07 C155 - Occupational Safety and Health Convention, 1981 (No. 155) 2007.01.25 C159 - Vocational Rehabilitation and Employment (Disabled Persons) 1988.02.02 Convention, 1983 (No. 159) C167 - Safety and Health in Construction Convention, 1988 (No. 167) 2002.03.07 C170 - Chemicals Convention, 1990 (No. 170) 1995.01.11 Maritime Labor Convention, 2006 (MLC) 2015.12.12, According to A4.5 (2) and (10), the government designates the following social amended in security sectors: medical, unemployment benefit, pension, employment injury 2016 and benefit, and maternity benefit. 2018 Source: official website of ILO, December 29, 2020 On this basis, the Company is establishing detailed HR and safety management systems. As of March 2022, the Company had established and tried out the following systems: • Safety Management System (trial), October 2021 • Supplier Management System (trial), October 2021 • Renumeration Management System (trial), October 2021 • Employee Recruitment and Transfer Management System (trial), November 2021 • Reward and Punishment Management System (trial), November 2021 124 • Work Safety Management System (trial), March 2022 When the Company signs a labor contract with a worker, its basic terms and conditions include detailed job requirements, scope and place of work, working and rest hours, remuneration, bonus, social insurance, labor protection, labor conditions, occupational hazard protection, and economic compensation. During the contract term, an employee may consult the HR staff at any time. Both parties may alter the contract when reaching an agreement. The working hours at the Company will comply with China’s policies. In case of overtime work, an overtime pay will be paid according to policies17. Employees are entitled to paid leaves. For example, if an employee has a service length of less than 10 years, he/she is entitled to a paid annual leave of 5 days; if an employee has a service length of 10 years or more, he/she is entitled to a paid annual leave of 10 days. The Company’s employees are entitled to statutory social insurance (endowment, medical, unemployment, accident, maternity, etc.), and a housing provident fund. Female employees’ extra benefits are based on the applicable state and local regulations, such as the Measures for the Labor Protection of Female Workers of Zhejiang Province. China’s Labor Law and the Labor Contract Law have clear provisions on employment, labor contract management and leaves, and the Company’s relevant practices comply with such provisions, and are communicated to all employees through induction training, on-the-job training and routine operations. In terms of contract terms and working conditions for direct hires, there is no gap between the Company’s practices and ESS2. However, the policies used by the PIU in managing labor risks of contracted and primary supply workers have gaps from ESS2. The Company have taken measures in this LMP to align them with ESS2. 4 Brief Overview of Labor Legislation: Occupational Health and Safety In China, there are over one hundred technical specifications and standards for the control of occupational safety and prevention of diseases under the Labor Law system. These technical specifications and standards are developed based on the industry best practices or updated toward the industry best practice, i.e. WHO, and relevant technical codes/norms of EU or USA, and the requirements of the International Labor Conventions 18 . These technical specifications and standards become compulsory to apply in the design and operation of the facilities. According to the Labor Law and the Law on the Prevention and Control of Occupational Diseases , the main OHS requirements are as follows: 1) Employers shall establish a complete occupational health and safety system, strictly enforce relevant measures and standards, and offer relevant training to workers to prevent accidents at work, and reduce occupational hazards. 17 In China, enterprises are required: 1) to pay no less than 150 percent of the normal wages if the extension of working hours is arranged; 2) to pay no less than 200 percent of the normal wages if the extended hours are arranged on days of rest and no deferred rest can be taken; and 3) to pay no less than 300 percent of the normal wages if the extended hours are arranged on statutory holidays. 18 Historical So far, China has signed 25 of the International Labor Conventions, including Convention on Equal Pay for Equal Work (100th convention), Minimum Employment Age Convention (138 th convention), The Worst Forms of Child Labor Convention (182th convention), and Employment and Occupation Discrimination Convention (111 th convention), etc. 125 2) Labor safety and health facilities must comply with the applicable national standards. Newly constructed, reconstructed or expanded labor safety and health facilities must be designed, constructed and put into operation together with the main part of the project. 3) Employers shall provide labor safety and health conditions, and necessary labor protection articles complying with the state provisions to workers, and conduct regular health checkups for workers doing hazardous jobs. 4) Workers doing special jobs must receive special training and be qualified for such jobs. 5) Workers must comply strictly with safety operation regulations at work, and shall have the right to reject employer management staff’s nonconforming or risky instructions, and criticize or prosecute activities endangering life safety and physical health. 6) The state shall establish a counting, reporting and handling system for casualty accidents and occupational diseases. Labor authorities of governments at or above the county level and employers shall count, report and handle casualty accidents and occupational diseases of workers at work. The HR procedures and policies drafted by the Company cover OHS requirements for workers, and special equipment operations. For the construction and operation of this subproject, the rules and regulations drafted by the Company provide labor safety and health conditions, and necessary labor protection articles complying with the state provisions to workers, and conduct regular health checkups for workers. The Company has developed and implemented requirements for special equipment operations. Therefore, no gap is found between the Company’s practices and ESS2. Employees have the right to report any act endangering their health and safety. In addition, employees may file an OHS complaint to the municipal Human Resources and Social Security Bureau. Therefore, the employee GRM complies with ESS2. 5 Responsible Staff The agencies responsible for this subproject are the Ningbo PMO (civil servants) and the Company. ⚫ Ningbo PMO: Ningbo PMO will be responsible for overall project organization, coordination, supervision and guidance, and communicate with the World Bank. The Ningbo PMO has promised to appoint an environmental officer and a social officer, responsible for E&S policy training, document preparation, and implementation and performance evaluation, including labor management. ⚫ PIU (the Company): According to the Company’s organization structure, the Company will comprise the Financial Center, Human Resources and Administration Dept., Procurement Center, Storage Center, Logistics Center, Information Management Dept., Technology Center, Production Center, etc., in which the Human Resources and Administration Dept. is responsible for the Company’s personnel affairs, including recruitment, training, payroll, social insurance and performance evaluation, as well as training on OHS and job skills and duties. As discussed in Sections 3 and 4, the HR management procedures and policies drafted by the Company cover working conditions and OHS for workers. The Company will appoint a full-time staff to be responsible for tracking the preparation and implementation of the E&S documents, including labor conditions, OHS, employee grievance redress, direct workers’ performance, and contractor labor management, etc. 126 The Company will establish a sound GRM for employees, including internal and external channels. The Company will offer multiple channels for workers to raise workplace issues. A worker may first report to the person responsible for the workplace or his/her direct supervisor; if he/she is dissatisfied with the reply, he/she may report to the department manager, or finally report to the General Manager. All grievance redress channels run in parallel, and workers may use any channel at their discretion. In sum, the Company has established sound management procedures for direct workers (especially child labor, forced labor and OHS), meeting the requirements of ESS2. However, as confirmed by the Company, the Company does not currently have policies or procedures for managing risks to workers employed by contractors or primary supplier or community workers that are anticipated under ESS2, and this LMP includes measures to address such gap In addition, when employing a contractor, the Company will include labor management requirements in the tendering documents. The contractor should comply with ESS2 and this LMP (including the prohibition of child and forced labor, labor terms and conditions, OHS, etc.), include this in its contract, and cause any subcontractor to do the same. See Section 6 for detailed requirements. 6 Policies and Procedures China has a relatively sound legal framework on labor and working conditions, especially child labor, forced labor and OHS. Contractors would usually develop a series of management plans and procedures, covering quality, environment, safety management, site management, and worker management, etc. The Chinese laws stipulate that when an employer employs an employee, it should sign an employment contract with the employee equally and voluntarily to define their rights and obligations. Both China’s Labor Law (2018) and Labor Contract Law (2012) apply. The national and municipal policies make provisions on salary, working hours, labor protection and labor disputes, and prohibit forced labor and child labor, which are completely consistent with the requirements of ESS2. According to Sections 3, 4 and 5, the labor risks identified in Section 2 have been managed effectively under the prevailing LMP. For the gaps from the ESS2 requirements (e.g., contracted worker management), the Ningbo PMO and the Company will take measures to strengthen the LMP for this subproject to comply with ESS2. ⚫ Ningbo PMO: Ningbo PMO will appoint a full-time staff for routine labor risk communication, and provide support to the PIU. The PIU is also required to appoint a full- time staff member to supervise labor and safety performance accordingly. The Ningbo PMO will document the above arrangement in the ESCP. ⚫ PIU (the Company): The Company will take the following measures to strengthen contracted worker management - o Appointing qualified employees to manage the performance of direct workers and contractors; o Implementing this LMP; 127 o Ensuring that each contractor develops its own LMP according to this LMP; o Ensuring that the waste collection and transfer contractor develops its own LMP according to this LMP; o Including detailed COVID-19 prevention and control measures in the contract; o Monitoring, supervising and reporting health and safety concerns related to COVID- 19, including main responsibilities and reporting arrangements related to contractors; o Strengthening workers’ awareness and training to prevent COVID-19 dissemination; o Strengthening workers’ awareness and training to prevent and reduce gender-based violence and sexual harassment; o Supervising contractors to perform the labor obligations in the General Contract Terms in the tendering documents, and meet the requirements of ESS2 and China’s Labor Law; o Supervising contractors to implement this LMP; o Ensuring the workplace OHS standard complies with the state OHS laws and OHS plan; o Supervising the waste collection and transfer contractor to ensure the safety of waste collection and transfer, stressing the safety rules for drivers, improving their driving skills, and preparing a rational work schedule to avoid fatigue driving; o Supervising project workers training; o Ensuring that a GRM available to all types of project workers is established, and supervising its implementation; o Supervising primary suppliers to take measures to correct potential risks related to child labor forced labor and OHS; o Reporting the performance of project workers to the Ningbo PMO semiannually. ⚫ Contractors: The contract shall include provisions on compliance with ESS2. Contractors and subcontractors shall assume the following duties - o Developing an LMP and an OHS plan, which will be submitted to the PIU for approval; o Keeping recruitment and employment records of contracted workers; o Notifying job descriptions and labor conditions to contracted workers; o Developing and implementing a labor GRM; o Implementing prevention and control measures for COVID-19 and other infectious diseases; o Monitoring, supervising and reporting health and safety concerns related to COVID- 19; o Strengthening workers’ awareness and training to prevent and reduce COVID-19 dissemination risks; o Strengthening workers’ awareness and training to prevent and reduce gender -based violence and sexual harassment; o Establishing a regular review and reporting system on worker OHS performance; o Offering induction, and health and safety training to workers regularly; o Ensuring that all workers confirm that they understand the working requirements in writing; o Updating its LMP if necessary; o Reporting the labor performance of contracted workers to the PIU monthly 128 ⚫ Third-party monitor: Ningbo PMO will appoint a third-party monitor to evaluate the performance of all types of workers, and the TORs should meet the Bank requirements. 7 Age of Employment China’s Labor Law (2018) defines minimum working age at 16, which is more stringent than the requirements of ESS 2 (14 years old). Both China’s Labor Law (2018) and Regulation on Special Protection for Juvenile Workers (1994) sets out specific protection for juvenile workers (aged from 16 to 18). Juvenile workers should be prohibited in working in a few hazardous positions such in unhealthy, hazardous or toxic circumstance, during the night, with dangerous machinery, equipment or tools, or involving handling or transport of heavy loads. The Company complies strictly with China’s policy on the prohibition of child and forced labor. Qualified candidates should have received undergraduate or above education, with a minimum age of 21-22 years. As of August 2021, the youngest employee of the Company was 21 years old. Before employment, the Company asks every candidate to provide basic information (e.g., a copy of the ID card) for further verification by the HR Dept. During the construction and operation of this subproject, the Company will ask its contractors and primary suppliers to verify the age of all workers to assure no child labor will be employed or engaged with this subproject. This will require workers to provide official documentation, which could include a birth certificate, national identification card, or medical or school record. If a child under the minimum age is identified working on this subproject, measures will be taken to immediately terminate the employment or engagement of the child in a responsible manner, considering the best interest of the child. 8 Terms and Conditions As shown in legal review (Section 3 in this LMP), China has established very comprehensive regulations regarding terms and conditions for a labor contract, which are deemed in alignment with relevant requirements of ESS2. The Company can sign a labor contract in writing with an employee. The labor contract should cover the basic terms and conditions, including the term of specific job positions, work content and place of work, work time and rest time, labor remuneration, bonus and social insurances, labor protection, labor conditions and protection against occupational hazards, and specified economic compensation. The content of a labor contract should be reached through prior consensus between the employer and an employee, without any violation against China’s labor related regulations and the requirements of ESS2. Contractors’ labor management procedures will set out terms and conditions for the contract ed workers. These terms and conditions will meet the requirements of ESS2 and the ESCP, and be aligned with this LMP. 9 GRM Ningbo PMO and the Company will establish and implement a GRM for workers, including direct workers. Ningbo PMO and the Company have established grievance redress hotlines (0574- 87191097 and 0574-56177703). In addition, the Company will ask contractors to develop and implement a GRM for workers. 129 The construction contractors will prepare their labor management procedure before subproject construction, which will also include detailed description of the GRM for workers, which includes: • A procedure to receive grievances such as comment/complaint form, suggestion boxes, email, a telephone hotline; • Stipulated timeframes to respond to grievances; • A registration system to record and track the timely resolution of grievances; • A responsible unit to receive, record and track resolution of grievances. The Company will assign dedicated staff to supervise grievance redress by contractors, and report to the PMO in monthly progress reports. The GRM for workers will be described in staff induction training, which will be provided to all project workers. The mechanism will be based on the following principles: • The process will be transparent and allow workers to express their concerns and file grievances. • There will be no discrimination against those who express grievances and any grievances will be treated confidentially. • Anonymous grievances will be treated equally as other grievances, whose origin is known. • Grievances will be seriously treated and timely and appropriate action in response will be taken. Information about the existence of the GRM will be readily available to all project workers (direct and contracted) through the PIU’s website, staff meetings, and other means as needed. In addition, Ningbo Municipal Human Resources and Social Security Bureau has disclosed the appeal hotlines of all municipal and district labor protection supervision agencies on its official website (http://rsj.ningbo.gov.cn/art/2018/10/9/art_1229130162_49605564.html), so that all workers can file grievances about labor contracts, remuneration, working conditions, etc. The GRM for workers will not prevent workers to use the mediation procedure provided in the China’s Labor Law. The basic procedure is as follows: Stage 1: The party that seeks arbitration shall file a written application to the labor dispute arbitration committee within 60 days starting from the date of the occurrence of labor dispute. In general, the arbitration committee shall produce a ruling within 60 days after receiving the application. The parties involved shall implement arbitration rulings if they do not have any objections to these rulings. Labor dispute arbitration committees shall comprise the representatives of labor administrative departments, representatives from trade unions at the same level, and the employer representatives. The chairmanship of such a committee shall be held by the representative of a labor administrative department. Stage 2: If any of the parties involved in a labor dispute has objections to an arbitration ruling, it can raise a lawsuit with the People’s Court within 15 days after receiving the ruling. 10 Contractor Management The PIU will ask all contractors participating in the Project to operate in a manner that complies with the ESS (including the requirements in the ESCP). Contractor management is conducted through the tendering process. The tendering documents shall meet the Bank’s requirements, including labor, OHS, and COVID-19 prevention and control. 130 As part of the process to select construction contractors who will engage contracted workers, the Company will review the following information: • Information in public records, for example, corporate registers and public documents relating to violations of applicable labor law, including reports from labor inspectorates and other enforcement bodies; • Business licenses, registrations, permits, and approvals; • Documents relating to a labor management system, including OHS issues, for example, labor management procedures; • Identification of labor management, safety, and health personnel, their qualifications, and certifications; • Workers’ certifications/permits/training to perform required work; • Records of safety and health violations, and responses; • Accident and fatality records and notifications to authorities; • Records of legally required worker benefits and proof of workers’ enrollment in the related programs; • Worker payroll records, including hours worked and pay received; and • Copies of previous contracts with contractors and suppliers, showing inclusion of provisions and terms reflecting ESS2. The bidding document will screen out any bidder that uses child labor or involve historic child labor use. Per China’s Labor Law, the minimum working age is 16 years old. The contracts with selected contractors will include provisions related to labor and occupational health and safety, as set out in ESS2 and China’s regulations. The Company will manage and supervise the performance of contractors, with focus on their contract compliance, possibly including regular auditing, on-site inspection and/or record review. Contractors’ labor management records and reports may include: • A representative sample of employment contracts or arrangements between third parties and contracted workers; • Records relating to grievances received and their resolution; • Reports relating to safety inspections, including fatalities and incidents and implementation of corrective actions; • Records relating to incidents of non-compliance with national law; and • Records of training provided for contracted workers to explain labor and working conditions and OHS for the subproject. Contractor labor performance should be part of project implementation progress reports submitted to Ningbo PMO. 11 Primary Supply Workers The Company will review primary suppliers to identify their labor force, and screen major risks and impacts, especially forced labor, child labor, and serious workplace safety problems. If a primary supplier has any major child labor or forced labor risk, or any serious safety problem, the Company should take the following measures: • Assess the level of major risks related to primary suppliers’ workers, and designing appropriate mitigation measures in the SMP; 131 • Following up with primary suppliers on quarterly basis forthe implementation status of environmental measures (if any), thereby ensuring that labor management is well implemented, and reporting their labor performance to the Ningbo PMO regularly as part of progress reports; • If it is impossible to take any remedy for any identified labor risk, the PIU will transfer primary suppliers to suppliers that can prove their compliance with ESS2 within a reasonable period. 132 Appendix 2.2 LMP for Centralized Plastic Waste Sorting and Processing Plant, and Recyclables Sorting Centers The centralized plastic waste sorting and processing plant, and the 4 recyclables sorting centers are among the Batch 2 subprojects. Its owner is Ningbo Haijing Resource Recycling Technology Co., Ltd. (hereinafter, the “Company”), which was founded in May 2021. The Company is 70% funded by Ningbo Fubang Green Energy Technology Co., Ltd., with a registered capital of 30 million yuan. Its business scope is the import of waste plastics usable as raw materials, recycling of waste plastics, cleaning, processing, production and sale of recycled plastic particles and products, sale of synthetic rubbers, and import and export of various commodities and technologies either directly or as an agent (except those restricted or prohibited by the state). This LMP is a living document, and is based on the SIA on the Batch 2 subprojects, and the Company’s personnel policies and management systems. In October 2021, the Company established a series of HR management and work safety systems. With the progress of the Project, the Company will further improve its LMP in accordance with the Bank’s ESS2, and the applicable laws and regulations of China. 1 Overview of Project Workers According to the definition of project workers in ESS2, the centralized plastic waste sorting and processing plant involves direct hires, contract workers and primary suppliers’ workers. Direct hires: People employed directly by Ningbo PMO and PIUs specifically for project management19, including technicians, and operation and management staff, all with relevant experience; Contract workers: Construction workers contract including those for the construction of the centralized plastic waste sorting and processing plant. At the operation stage, semi-finished products from the recyclables sorting centers may be transferred by drivers hired by a third party. Primary suppliers’’ workers: Mainly to the workers of key suppliers providing necessary goods or raw materials directly for a project’s core functions. Primary suppliers’ workers are workers at the recyclables sorting centers20 mainly. An estimate of types and numbers of workers of the centralized plastic waste sorting and processing plant is shown in Table 1. Table 1 Estimate of Types and Numbers of Project Workers Subproject Stage Direct hires Contract workers Primary suppliers’ workers Centralized Construction Civil works 10 300 0 plastic Equipment installation 10 40 0 19 Some workers may be full-time or part-time civil servants. If there is no valid transfer certificate indicating that he/she has been employed for the Project, his/her public sector employment agreement applies, and the requirements on labor protection (Clauses 17~20) and OHS (Clauses 24~30) of ESS2 should be met. 20 The recyclables sorting centers are also one of the Batch 2 subprojects, implemented by Ningbo Dabashou Eco- digital Technology Co., Ltd., which has prepared an LMP according to ESS2. 133 Subproject Stage Direct hires Contract workers Primary suppliers’ workers waste Trial operation 50-60 60 0 sorting and processing Stable operation 100-115 6021 0 plant Source: estimated by the Company All direct hires will be from the Company. Since the Company has been newly established, it has a workforce of less than 10, all having received undergraduate or above education. The Company is in the process of recruitment. The Company will review labor management systems of bidding contractors through its bidding mechanism, and ask contractors to establish labor management procedures in accordance with ESS2. Bidding is under preparation, so it is uncertain if contracted workers include non-local workers, which will be further identified during implementation. Primary suppliers’ workers of the centralized plastic waste sorting and processing plant are workers (about 10 each) and drivers at the recyclables sorting centers. According to the SIA, since sorting is unskilled, sorters will be from nearby villages, mostly women. 2 Screening of Potential Significant Labor Risks 2.1 Subproject activities The centralized plastic waste sorting and processing plant is located in the Ningbo resource recycling base, with a floor area of 85.7 mu and a total new building area of 60,000 m2. After completion, it will have treatment capacity of 40,000 tons of plastics annually. 2.2 Major labor risks At the preparation stage, a social impact survey and extensive stakeholder engagement were conducted, and major labor risks were identified. According to the SIA, the Project is located in the developed city of Ningbo, where the government has well-established labor management and supervision systems for enterprises, so the labor risks are negligible or very low, mainly including: • Forced labor and child labor • Discrimination in recruitment According to the scope, scale and nature of the centralized plastic waste sorting and processing plant, major labor risks related that may be encountered by workers include: A. Construction stage • Dangerous work: Construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials; • Safety risks in machinery operation: Accidents of construction workers during construction, such as welding, cutting and operating relevant tools; • Noise from mechanical construction: Loud, repeated and excessive noises that may arise during construction, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks; 21 Mostly drivers of plastic waste, to be recruited by a third-party labor service company 134 • Emergency risks: Emergencies and quality safety accidents arising from unsound civilized construction and quality safety management measures, or inadequate management; • Sexual harassment or gender-based violence risks: Physical or mental violence against women due to gender or lifestyle differences; • Workplace accidents: Safety accidents arising from work shed collapse due to quality problems or natural disasters; • Health and infection risks: Disease infection risks (e.g., COVID-19) arising from the improper diet and accommodation management, or health management of construction workers; • Renumeration: Workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts. B. Operation stage • Traffic: Potential traffic accidents during the transport of sorted recyclables; • Noise from machinery operation: Such as noises generated by sorting and crushing machines, etc.; loud, repeated and excessive noises, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks; • Dust pollution: Dust and volatile organic substances generated by plastic crushing and granulation during operation; • Industrial vehicles: Improper operation of forklifts in the working area; • Emergency accidents: Mis-operation of smart equipment leading labor health and life risks; • Infection: Disease infection risks (e.g., COVID-19) during recyclables (waste) collection and transfer, and close contact with people. During preparation, Ningbo PMO investigated the Company’s labor management according to ESS2 to analyze and summarize the gaps between the Company’s labor management and ESS2, and propose enhancement measures. 3 Brief Overview of Labor Legislation: Terms and Conditions China has established a sound system of laws and regulations on labor management. As a member of the International Labor Organization (ILO), China has approved 26 conventions (including 20 that have taken effect), including equal remuneration, discrimination, minimum age, child labor, OHS, employment policy, consulting, risk of association, etc. In general, the Chinese and Ningbo policies make provisions on salary, working hours, labor protection and labor disputes, and prohibit forced labor and child labor, which is completely consistent with the requirements of ESS2. Table 2 Applicable PRC Laws relating to Labor and Working Conditions No. Title Effective year 1 China’s Labor Law 1995, amended in 2018 2 Provisions of the State Council on Working Hours of Workers and Staff 1995 135 No. Title Effective year 3 China’s Emergency Incident Response Law 2007 4 Regulations on the Implementation of China’s Labor Contract Law 2008 5 China’s Labor Contract Law 2008, amended in 2012 6 Special Rules on Labor Protection of Female Employees 2012 7 China’s Law on the Prevention and Control of Occupational Diseases 2017 Table 3 List of ILO Conventions Approved by China Convention Date Basic conventions (4) C100 - Equal Remuneration Convention, 1951 (No.100) 1990.12.02 C111 - Discrimination (Employment and Occupation) Convention, 1958 2006.01.12 (No.111) C138 - Minimum Age Convention, 1973 (No.138), specifying the 1999.04.28 minimum wage of 16 years C182 - Worst Forms of Child Labor Convention, 1999 (No.182) 2002.08.08 Governance (priority) conventions (2) C122 - Employment Policy Convention, 1964 (No.122) 1997.12.17 C144 - Tripartite Consultation (International Labor Standards) 1990.11.02 Convention, 1976 (No.144) Technical conventions (14) C011 - Right of Association (Agriculture) Convention, 1921 (No.11) 1934.04.27 C014 - Weekly Rest (Industry) Convention, 1921 (No. 14) 1934.05.17 C019 - Equality of Treatment (Accident Compensation) Convention, 1934.04.27 1925 (No. 19) C026 - Minimum Wage-Fixing Machinery Convention, 1928 (No. 26) 1930.05.05 C027 - Marking of Weight (Packages Transported by Vessels) 1931.06.24 Convention, 1929 (No. 27) C032 - Protection against Accidents (Dockers) Convention (Revised), 1935.11.30 1932 (No. 32) C045 - Underground Work (Women) Convention, 1935 (No. 45) 1936.12.02 C080 - Final Articles Revision Convention, 1946 (No. 80) 1947.08.04 C150 - Labor Administration Convention, 1978 (No. 150) 2002.03.07 C155 - Occupational Safety and Health Convention, 1981 (No. 155) 2007.01.25 C159 - Vocational Rehabilitation and Employment (Disabled Persons) 1988.02.02 Convention, 1983 (No. 159) C167 - Safety and Health in Construction Convention, 1988 (No. 167) 2002.03.07 C170 - Chemicals Convention, 1990 (No. 170) 1995.01.11 Maritime Labor Convention, 2006 (MLC) According to A4.5 (2) and (10), the government designates the 2015.12.12, amended following social security sectors: medical, unemployment benefit, in 2016 and 2018 pension, employment injury benefit, and maternity benefit. 136 Source: official website of ILO, December 29, 2020 On this basis, the Company is establishing detailed personnel and safety management systems. As of March 2022, the Company had established and tried out the following systems: • Workplace Attendance Management System (trial), October 2021 • Contract Management System (trial), October 2021 • Safety Management System (trial), October 2021 • Supplier Management System (trial), October 2021 • Renumeration Management System (trial), October 2021 • Recruitment Management System (trial), December 2021 • Employee Recruitment and Transfer Management System (trial), December 2021 • Work Safety Management System (trial), March 2022 When the Company signs a labor contract, its basic terms and conditions include detailed job requirements, scope and place of work, working and rest hours, remuneration, bonus, social insurance, labor protection, labor conditions, occupational hazard protection, and economic compensation. During contract performance, an employee may consult the HR staff at any time. Both parties may alter the contract when reaching an agreement. The working hours of the company comply with China’s policies. In case of overtime work, an overtime pay will be paid according to policies22. Employees are entitled to paid leaves. For example, if an employee has a service length of less than 10 years, he or she is entitled to a paid annual leave of 5 days; if an employee has a service length of 10 years or more, he or she is entitled to a paid annual leave of 10 days. The Company’s employees are entitled to statutory social insurance (endowment, medical, unemployment, accident, maternity, etc.), and a housing provident fund. Female employees’ extra benefits are based on the applicable state and local regulations, such as the Measures for the Labor Protection of Female Workers of Zhejiang Province. China’s Labor Law and the Labor Contract Law have clear provisions on employment, labor contract management and leaves, and the Company’s relevant practices comply with such provisions, and are communicated to all employees through induction training, on-the-job training and routine operations. In terms of contract terms and working conditions for direct hires, there is no gap between the Company’s practices and ESS2. However, the policies used by the PIU in managing labor risks of contracted and primary supply workers have significant gaps from ESS2. The Ningbo PMO and the Company have taken measures in this LMP to align them with the ESS2. 4 Brief Overview of Labor Legislation: Occupational Health and Safety In China, there are over one hundred technical specifications and standards for the control of occupational safety and prevention of diseases under the Labor Law system. These technical specifications and standards are developed based on the industry best practices or updated toward the industry best practice, i.e. WHO, and relevant technical codes/norms of EU or USA, and the 22 In China, enterprises are required: 1) to pay no less than 150 percent of the normal wages if the extension of working hours is arranged; 2) to pay no less than 200 percent of the normal wages if the extended hours are arranged on days of rest and no deferred rest can be taken; and 3) to pay no less than 300 percent of the normal wages if the extended hours are arranged on statutory holidays. 137 requirements of the International Labor Conventions 23 . These technical specifications and standards become compulsory to apply in the design and operation of the facilities. According to the Labor Law and the Law on the Prevention and Control of Occupational Diseases, the main OHS requirements are as follows: 1) Employers shall establish a complete occupational health and safety system, strictly enforce relevant measures and standards, and offer relevant training to workers to prevent accidents at work, and reduce occupational hazards. 2) Labor safety and health facilities must comply with the applicable national standards. Newly constructed, reconstructed or expanded labor safety and health facilities must be designed, constructed and put into operation together with the main part of the project. 3) Employers shall provide labor safety and health conditions, and necessary labor protection articles complying with the state provisions to workers, and conduct regular health checkups for workers doing hazardous jobs. 4) Workers doing special jobs must receive special training and be qualified for such jobs. 5) Workers must comply strictly with safety operation regulations at work, and shall have the right to reject employer management staff’s nonconforming or risky instructions, and criticize or prosecute activities endangering life safety and physical health. 6) The state shall establish a counting, reporting and handling system for casualty accidents and occupational diseases. Labor authorities of governments at or above the county level and employers shall count, report and handle casualty accidents and occupational diseases of workers at work. The HR procedures and policies drafted by the Company cover OHS requirements for workers, and special equipment operations. For the construction and operation of the centralized plastic waste sorting and processing plant, the rules and regulations drafted by the Company provide labor safety and health conditions, and necessary labor protection articles complying with the state provisions to workers, and conduct regular health checkups for workers. The Company has developed and implemented requirements for special equipment operations. Therefore, there is no gap found betwe en the Company’s practices and the ESS2. Employees have the right to report any act endangering their health and safety. In addition, employees may file an OHS complaint to the municipal human resources and social security bureau. Therefore, the employee GRM complies with the ESS2. 5 Responsible Staff The agencies responsible for the centralized plastic waste sorting and processing plant are Ningbo PMO (civil servants) and the Company. • Ningbo PMO: Ningbo PMO will be responsible for the overall project organization, coordination, supervision and guidance, and communicate with the Bank. Ningbo PMO has promised to appoint an environmental officer and a social staff to be responsible for 23 Historical So far, China has signed 25 of the International Labor Conventions, including Convention on Equal Pay for Equal Work (100th convention), Minimum Employment Age Convention (138 th convention), The Worst Forms of Child Labor Convention (182th convention), and Employment and Occupation Discrimination Convention (111th convention), etc. 138 E&S policy training, document preparation, and implementation and performance evaluation, including labor management. • PIU (the Company): According to the Company’s organization structure, the Company will consist of the Financial Center, General Affairs Office (including the Human Resources Dept., Administration Dept., Public Relations Dept.), Procurement Center, Operations Center, Project Information Management Center, Production Technology Center, etc., in which the Human Resources Dept. of the General Affairs Office is responsible for the Company’s HR affairs, including employee recruitment, training, payroll, social insurance and performance evaluation, as well as training on OHS and job skills and duties. As discussed in Sections 3 and 4, the personnel management procedures and policies drafted by the Company cover working conditions and OHS for workers. The Company will appoint a full-time staff to be responsible for E&S document management, including labor conditions, OHS, employee grievance redress, direct workers’ performance, management of contracted workers and primary supply workers, etc. The Company will establish a sound GRM for employees, including internal and external channels. The Company will offer multiple channels for workers to raise workplace issues. A worker may first report to the person responsible for the workplace or his/her direct supervisor; if he/she is dissatisfied with the reply, he/she may report to the department manager, or finally report to the General Manager. All grievance redress channels run in parallel, and workers may use any channel at their discretion. In sum, the Company has established a sound management procedure for direct workers (especially child labor, forced labor and OHS), meeting the requirements of ESS2. However, as confirmed by the Company, the Company does not currently have policies or procedures for managing risks to workers employed by contractors or primary supplier or community workers that are anticipated under ESS2, and this LMP includes measures to address such gap. In addition, when employing a contractor, the Company will include labor management requirements in the tendering documents. The contractor should comply with the ESS2 and this LMP (including the prohibition of child and forced labor, labor terms and conditions, OHS, etc.), include this in its contract, and cause any subcontractor to do the same. See Section 6 for detailed requirements. 6 Policies and Procedures China has a relatively sound legal framework on labor and working conditions, especially child labor, forced labor and OHS. Contractors would usually develop a series of management plans and procedures, covering quality, environment, safety management, site management, worker management, etc. The Chinese laws stipulate that when an employer employs an employee, it should sign an employment contract with the employee equally and voluntarily to define their rights and obligations. Both China’s Labor Law (2018) and Labor Contract Law (2012) apply. The national and municipal policies make provisions on salary, working hours, labor protection and labor 139 disputes, and prohibit forced labor and child labor, which is completely consistent with the requirements of ESS2. According to Sections 3, 4 and 5, the labor risks identified in Section 2 have been managed effectively under the prevailing LMP. For the gaps from the ESS2 requirements (e.g., management of contracted workers and primary supply workers), Ningbo PMO and the Company will take measures to strengthen the LMP to comply with ESS2. • Ningbo PMO: Ningbo PMO will appoint a full-time staff member for routine labor risk communication, and provide support to the PIU. The PIU is also required to appoint a full- time staff member to supervise labor and safety performance. Ningbo PMO will document the above arrangements in the ESCP. • PIU (the Company): The Company will take the following measures to strengthen contracted worker management – o Appointing qualified employees to manage the performance of direct workers and contractors; o Implementing this LMP; o Ensuring that each contractor develops its own LMP according to this LMP; o Ensuring that the waste collection and transfer contractor develops its own LMP according to this LMP; o Including detailed COVID-19 prevention and control measures in the contract; o Monitoring, supervising and reporting health and safety concerns related to COVID- 19, including main responsibilities and reporting arrangements related to contractors; o Strengthening workers’ awareness and training to prevent COVID-19 dissemination; o Supervising contractors to perform the labor obligations in the General Contract Terms in the tendering documents, and meet the requirements of ESS2 and China’s Labor Law; o Supervising contractors to implement this LMP; o Ensuring that the workplace OHS standard complies with the state OHS laws and OHS plan; o Supervising the waste collection and transfer contractor to ensure the safety of waste collection and transfer, stressing the safety rules for drivers, improving their driving skills, and preparing a rational work schedule to avoid fatigue driving; o Supervising project worker training; o Ensuring that a GRM available to all types of project workers is established, and supervising its implementation; o Supervising primary suppliers to take measures to correct potential risks related to child labor forced labor and OHS; o Reporting the performance of project workers to the Ningbo PMO semiannually • Contractors: The contract shall include provisions on compliance with ESS2. Contractors and subcontractors shall assume the following duties – 140 o Developing an LMP and an OHS plan, which will be submitted to the PIU for approval; o Keeping recruitment and employment records of contracted workers; o Notifying job descriptions and labor conditions to contracted workers; o Developing and implementing a labor GRM; o Implementing prevention and control measures for COVID-19 and other infectious diseases; o Monitoring, supervising and reporting health and safety concerns related to COVID- 19, o Strengthening workers’ awareness and training to prevent and reduce COVID-19 dissemination risks; o Strengthening workers’ awareness and training to prevent and reduce gender-based violence and sexual harassment; o Establishing a regular review and reporting system on worker OHS performance; o Offering induction, and health and safety training to workers regularly; o Ensuring that all workers confirm that they understand the working requirements in writing; o Updating its LMP if necessary; o Reporting the labor performance of contracted workers to the PIU monthly • Third-party monitor: The Ningbo PMO will appoint a third-party monitor to evaluate the performance of all types of workers, and the TORs should meet the Bank requirements. 7 Age of Employment China’s Labor Law (2018) defines minimum working age at 16, which is more stringent than the requirements of ESS 2 (14 years old). Both China’s Labor Law (2018) and Regulation on Special Protection for Juvenile Workers (1994) sets out specific protection for juvenile workers (aged from 16 to 18). Juvenile workers should be prohibited in working in a few hazardous positions such in unhealthy, hazardous or toxic circumstance, during the night, with dangerous machinery, equipment or tools, or involving handling or transport of heavy loads. The Company complies strictly with China’s policy on the prohibition of child and forced labor. Qualified candidates should have received undergraduate or above education, with a minimum age of 21-22 years. As of August 2021, the youngest employee of the Company was 21 years old. Before employment, the Company asks every candidate to provide basic information (e.g., a copy of the ID card) for further verification by the HR Dept. During the construction and operation of the centralized plastic waste sorting and processing plant, the Company will ask its contractors and primary suppliers to verify the ages of all workers to assure no child labor will be employed. This will require workers to provide official documentation, which could include a birth certificate, national identification card, or medical or school record. If a child under the minimum age is identified working on the centralized plastic waste sorting and processing plant, measures will be taken to immediately terminate the employment or engagement of the child in a responsible manner, considering the best interest of the child. 8 Terms and Conditions 141 As shown in legal review (Section 3 in this LMP), China has established very comprehensive regulations regarding terms and conditions for a labor contract, which are deemed in alignment with relevant requirements of the ESS2. The Company can sign a labor contract in writing with an employee. The labor contract should cover the basic terms and conditions, including the term of specific job positions, work content and place of work, work time and rest time, labor remuneration, bonus and social insurances, labor protection, labor conditions and protection against occupational hazards, and specified economic compensation. The content of a labor contract should be reached through prior consensus between the employer and an employee, without any violation against China’s labor related regulations and the requirements of the ESS2. The contractors’ labor management procedures will set out terms and conditions for the contracted workers. These terms and conditions will meet the requirements of the ESS2 and the ESCP, and be aligned with this LMP. 9 GRM Ningbo PMO and the Company will establish and implement a GRM for workers, including direct hires. Ningbo PMO and the Company have established grievance redress hotlines (0574-8719 1097 and 0574-5617 7690). In addition, the PIU will ask contractors to develop and implement a GRM for workers. The construction contractors will prepare their labor management procedure before subproject construction, which will also include detailed description of the GRM for workers, which includes: • A procedure to receive grievances such as comment/complaint form, suggestion boxes, email, a telephone hotline; • Stipulated timeframes to respond to grievances; • A registration system to record and track the timely resolution of grievances; • A responsible unit to receive, record and track resolution of grievances. The Company will assign dedicated staff to supervise grievance redress by contractors, and report to the PMO in monthly progress reports. The GRM for workers will be described in staff induction training, which will be provided to all project workers. The mechanism will be based on the following principles: • The process will be transparent and allow workers to express their concerns and file grievances. • There will be no discrimination against those who express grievances and any grievances will be treated confidentially. • Anonymous grievances will be treated equally as other grievances, whose origin is known. • Grievances will be seriously treated and timely and appropriate action in response will be taken. Information about the existence of the GRM will be readily available to all project workers (direct and contracted) through the PIU’s website, staff meetings, and other means as needed. In addition, the Ningbo Municipal Human Resources and Social Security Bureau has disclosed the appeal hotlines of all municipal and district labor protection supervision agencies on its official 142 website (http://rsj.ningbo.gov.cn/art/2018/10/9/art_1229130162_49605564.html), so that all workers can file grievances about labor contracts, remuneration, working conditions, etc. The GRM for workers will not prevent workers to use the mediation procedure provided in the China’s Labor Law. The basic procedures are as follows: Stage 1: The party that asks for arbitration shall file a written application to the labor dispute arbitration committee within 60 days starting from the date of the occurrence of labor dispute. In general, the arbitration committee shall produce a ruling within 60 days after receiving the application. The parties involved shall implement arbitration rulings if they do not have any objections to these rulings. Labor dispute arbitration committees shall be composed of the representatives of labor administrative departments, representatives from trade unions at the same level, and the employer representatives. The chairmanship of such a committee shall be held by the representative of a labor administrative department. Stage 2: If any of the parties involved in a labor dispute has objections to an arbitration ruling, it can raise a lawsuit with the People’s Court within 15 days after receiving the ruling. 10 Contractor Management The PIU will ask all contractors under the Project to operate in a manner that complies with the ESS (including the requirements in the ESCP). Contractor management is conducted through the tendering process. The tendering documents shall meet the Bank’s requirements, including labor, OHS, and COVID-19 prevention and control. As part of the process to select construction contractors who will engage contracted workers, the Company will review the following information: • Information in public records, for example, corporate registers and public documents relating to violations of applicable labor law, including reports from labor inspectorates and other enforcement bodies; • Business licenses, registrations, permits, and approvals; • Documents relating to a labor management system, including OHS issues, for example, labor management procedures; • Identification of labor management, safety, and health personnel, their qualifications, and certifications; • Workers’ certifications/permits/training to perform required work; • Records of safety and health violations, and responses; • Accident and fatality records and notifications to authorities; • Records of legally required worker benefits and proof of workers’ enrollment in the related programs; • Worker payroll records, including hours worked and pay received; and • Copies of previous contracts with contractors and suppliers, showing inclusion of provisions and terms reflecting ESS2. The bidding document will screen out any bidder that uses child labor or involve historic child labor use. Per China’s Labor Law, the minimum working age is 16 years old. The contracts with 143 selected contractors will include provisions related to labor and occupational health and safety, as set out in ESS2 and China’s regulations. The Company will manage and supervise the performance of contractors, with focus on their contract compliance, possibly including regular auditing, on-site inspection and/or record review. Contractors’ labor management records and reports may include: • A representative sample of employment contracts or arrangements between third parties and contracted workers; • Records relating to grievances received and their resolution; • Reports relating to safety inspections, including fatalities and incidents and implementation of corrective actions; • Records relating to incidents of non-compliance with national law; and • Records of training provided for contracted workers to explain labor and working conditions and OHS for the subproject. Contractor labor performance should be part of the project implementation progress reports to Ningbo PMO. 11 Primary Suppliers’ Workers The Company will review primary suppliers to identify their labor force, and screen major risks and impacts, especially forced labor, child labor and serious safety problems. The centralized plastic waste sorting and processing plant involves primary suppliers’ workers mainly, who are also direct hires or contract workers of the recyclables sorting centers – one of the Batch 2 subprojects. The PIU (Ningbo Dabashou Eco-digital Technology Co., Ltd.) has also prepared and implemented an LMP according to ESS2, so primary supply worker risks are negligible. At the operation stage, if any additional primary suppliers are involved, the Company will review it to determine the number of primary suppliers’ workers, and screen major risks and impacts, with focus on forced labor, child labor and severe safety problems. The key points of review and proposed measures are as follows: • Evaluating the magnitude of major risks related to primary suppliers’ workers, and designing appropriate mitigation measures in the SMP; • Following up with primary suppliers on quarterly basis for the implementation status of environmental measures (if any), thereby ensuring that labor management is well implemented, and reporting their labor performance to the Ningbo PMO regularly as part of progress reports; • If it is impossible to take any remedy for any identified labor risk, the PIU will transfer primary suppliers to a suppliers who can prove its compliance with ESS2 within a reasonable period. 144 Appendix 2.3 LMP for WWTP of the Ningbo Resource Recycling Base The WWTP of the Ningbo resource recycling base (hereinafter, “this subproject”) is one of the Batch 2 subprojects. Its owner is Ningbo Qingyuan Water Environment Service Co., Ltd. (hereinafter, the “Company”), which was founded in March 2021, being a wholly-funded subsidiary of Ningbo Municipal Public Utilities Investment Co., Ltd. Since the Company has been newly established, its HR systems and policies are being formulated and improved, and follow those of its parent company (Ningbo Municipal Public Utilities Investment Co., Ltd.). Currently, all staff of the Company and project workers are from the parent company. This LMP is a living document, and the current version is based on the SIA on the Batch 2 subprojects, and the personnel policies of Ningbo Municipal Infrastructure Investment Co., Ltd. Since this subproject is under preparation, the Company has not started operation, and its personnel management and work safety systems are being established, which are expected to be issued and come into effect by the end of December 2022. As of March 2022, the Company had followed the personnel systems and policies of its holding company mainly. 1 Overview of Project Workers The WWTP of the Ningbo resource recycling base will be reconstructed and expanded within the existing leachate processing plant, with a floor area of 67 mu. After completion, it will have a treatment capacity of 2,500m3/d, including an additional capacity of 1,800m3/d and an existing capacity of 700m3/d. According to the definition of project workers in ESS2, project activities, key informant interviews and document review, this subproject involves direct workers, contracted workers and primary supply workers. Direct hires: People employed directly by the Ningbo PMO and PIUs specifically for project management24, including technicians, and operation and dispatching center staff, all with relevant experience Contract workers: Construction workers of this subproject, and workers of the third-party operation company that may be appointed at the operation stage Primary suppliers’ workers: Transport and installation workers of new equipment suppliers during future project construction, and workers of suppliers supplying raw materials (e.g., coagulants) An estimate of types and numbers of workers is shown in Table 1. Table 1 Estimate of Types and Numbers of Project Workers Subproject Stage Direct hires Contract workers Primary suppliers’ workers WWTP of Construction Civil works 8 300 5 the Ningbo Equipment installation 8 30 30 24 Some workers may be full-time or part-time civil servants. If there is no valid transfer certificate indicating that he/she has been employed for the Project, his/her public sector employment agreement applies, and the requirements on labor protection (Clauses 17~20) and OHS (Clauses 24~30) of ESS2 should be met. 145 Subproject Stage Direct hires Contract workers Primary suppliers’ workers resource recycling Operation 20 5 5 base Source: estimated by the Company All direct hires will be from Ningbo Municipal Public Utilities Investment Co., Ltd. Currently, Ningbo Municipal Public Utilities Investment Co., Ltd. has a workforce of 41, including 19 female workers. All workers have received junior college or above education, are aged 18 years or above, and have mostly settled in Ningbo. All workers have signed an employment contract, and their salaries, benefits, working hours, and OHS management comply with the applicable state and local laws and regulations. The Company will review labor management systems of bidding contractors through its bidding mechanism, and ask contractors to establish labor management procedures in accordance with ESS2. Bidding is under preparation, so it is uncertain if contracted workers include non-local workers, which will be further identified during implementation. 2 Screening of Potential Significant Labor Risks 2.1 Subproject activities The scope of construction of this subproject includes: 1) Reconstruction and expansion within the existing leachate processing plant, including the demolition of the existing administrative room and two-stage wastewater treatment A/O system, and construction of a conditioning tank, two MBR complexes, a vehicle washing center, an administrative room, etc.; 2) Construction of the compound wall, roads, landscaping and other associated works of the plant; 3) Purchase and installation of process equipment 2.2 Major labor risks At the preparation stage, a social impact survey and extensive stakeholder engagement were conducted on this subproject, and major labor risks were identified. According to the SIA of the Batch 2 subprojects, the Project is located in the developed city of Ningbo, where the government has a well-established labor management and supervision system for enterprises, so this subproject’s labor risks are negligible or very low, mainly including: • Forced labor and child labor • Discrimination in recruitment According to the scope, scale and nature of this subproject, major labor risks related that may be encountered by workers include: A. Construction stage • Dangerous work: Construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials; • Safety risks in machinery operation: Accidents of construction workers during construction, such as welding, cutting and operating relevant tools; • Noise from mechanical construction: Loud, repeated and excessive noises that may arise during construction, possibly leading to long-term hearing problems, such as 146 deafness, and also being a dangerous distraction that increases accident risks; • Emergency risks: Emergencies and quality safety accidents arising from unsound civilized construction and quality safety management measures, or inadequate management; • Sexual harassment or gender-based violence risks: Physical or mental violence against women due to gender or lifestyle differences; • Workplace accidents: Safety accidents arising from work shed collapse due to quality problems or natural disasters; • Health and infection risks: Disease infection risks (e.g., COVID-19) arising from the improper diet and accommodation management, or health management of construction workers; • Renumeration risks: Workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts. B. Operation stage • OHS risks: Health problems of WWTP staff due to noise and exposure to chemicals, such as ammonia, hydrogen sulfide and sodium hydroxide; • Toxic gases: Exposure to high-level toxic gases when repair workers work in wastewater manholes and box culverts, such as ammonia and sodium hydroxide; • Emergency accidents: Leakage of wastewater or harmful gases due to system failure, or mistakes in the operation of smart equipment during installation and adjustment leading labor health and life risks; • Noise and vibration: Noise and vibration generated by pumps and blowers in the plant • Eye injury: use of hydrochloric acid, sodium hypochlorite and other liquids; • Disease Infection: Disease infection risks (e.g., COVID-19) during contact with water, and close contact with people; • Renumeration: workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts. 3 Brief Overview of Labor Legislation: Terms and Conditions China has established a sound system of laws and regulations on labor management. As a member of the International Labor Organization (ILO), China has approved 26 conventions (including 20 that have taken effect), including equal remuneration, discrimination, minimum age, child labor, OHS, employment policy, consulting, risk of association, etc. In general, the national and municipal policies make provisions on salary, working hours, labor protection and labor disputes, and prohibit forced labor and child labor, which is completely consistent with the requirements of ESS2. Table 2 Applicable PRC Laws relating to Labor and Working Conditions No. Title Effective year 1 China’s Labor Law 1995, amended in 2018 2 Provisions of the State Council on Working Hours of Workers and Staff 1995 3 China’s Emergency Incident Response Law 2007 4 Regulations on the Implementation of China’s Labor Contract Law 2008 147 No. Title Effective year 5 China’s Labor Contract Law 2008, amended in 2012 6 Special Rules on Labor Protection of Female Employees 2012 7 China’s Law on the Prevention and Control of Occupational Diseases 2017 Table 3 List of ILO Conventions Approved by China Convention Date Basic conventions (4) C100 - Equal Remuneration Convention, 1951 (No.100) 1990.12.02 C111 - Discrimination (Employment and Occupation) Convention, 1958 2006.01.12 (No.111) C138 - Minimum Age Convention, 1973 (No.138), specifying the minimum wage 1999.04.28 of 16 years C182 - Worst Forms of Child Labor Convention, 1999 (No.182) 2002.08.08 Governance (priority) conventions (2) C122 - Employment Policy Convention, 1964 (No.122) 1997.12.17 C144 - Tripartite Consultation (International Labor Standards) Convention, 1990.11.02 1976 (No.144) Technical conventions (14) C011 - Right of Association (Agriculture) Convention, 1921 (No.11) 1934.04.27 C014 - Weekly Rest (Industry) Convention, 1921 (No. 14) 1934.05.17 C019 - Equality of Treatment (Accident Compensation) Convention, 1925 (No. 1934.04.27 19) C026 - Minimum Wage-Fixing Machinery Convention, 1928 (No. 26) 1930.05.05 C027 - Marking of Weight (Packages Transported by Vessels) Convention, 1929 1931.06.24 (No. 27) C032 - Protection against Accidents (Dockers) Convention (Revised), 1932 (No. 1935.11.30 32) C045 - Underground Work (Women) Convention, 1935 (No. 45) 1936.12.02 C080 - Final Articles Revision Convention, 1946 (No. 80) 1947.08.04 C150 - Labor Administration Convention, 1978 (No. 150) 2002.03.07 C155 - Occupational Safety and Health Convention, 1981 (No. 155) 2007.01.25 C159 - Vocational Rehabilitation and Employment (Disabled Persons) 1988.02.02 Convention, 1983 (No. 159) C167 - Safety and Health in Construction Convention, 1988 (No. 167) 2002.03.07 C170 - Chemicals Convention, 1990 (No. 170) 1995.01.11 Maritime Labor Convention, 2006 (MLC) 2015.12.12, According to A4.5 (2) and (10), the government designates the following social amended in security sectors: medical, unemployment benefit, pension, employment injury 2016 and benefit, and maternity benefit. 2018 Source: official website of ILO, December 29, 2020 148 On this basis, Ningbo Municipal Public Utilities Investment Co., Ltd. has established detailed regulations on labor and working conditions, pending approval by the board of directors, including: • Human Resources Management System; • Workplace Attendance Management System; • Renumeration Management System; • Regulations on Duty Watch and Subsidies; • Training Management System; • Standard Labor Contract; • Note on the GRM for employees When Ningbo Public Utilities Investment Co., Ltd. signs a labor contract, its basic terms and conditions include detailed job requirements, scope and place of work, working and rest hours, remuneration, bonus, social insurance, labor protection, labor conditions, occupational hazard protection, and economic compensation. During contract term, an employee may consult the HR staff at any time. Both parties may alter the contract when reaching an agreement. The working hours comply with China’s policies. In case of overtime work, an overtime pay will be paid according to policies25. Employees are entitled to paid leaves. For example, if an employee has a service length of less than 10 years, he/she is entitled to a paid annual leave of 5 days; if an employee has a service length of 10 years or more, he/she is entitled to a paid annual leave of 10 days. The employees of Ningbo Municipal Public Utilities Investment Co., Ltd. are entitled to statutory social insurance (endowment, medical, unemployment, accident, maternity, etc.), and a housing provident fund. Female employees’ extra benefits are based on the applicable state and local regulations, such as the Measures for the Labor Protection of Female Workers of Zhejiang Province. China’s Labor Law and the Labor Contract Law have clear provisions on employment, labor contract management and leaves, and the relevant practices of Ningbo Municipal Infrastructure Investment Co., Ltd. comply with such provisions, and are communicated to all employees through induction training, on-the-job training and routine operations. In terms of contract terms and working conditions for direct hires, there is no gap between the practices of Ningbo Municipal Public Utilities Investment Co., Ltd. And ESS2. However, the policies used by the PIU in managing labor risks of contracted and primary suppliers’ workers have significant gaps from ESS2. Ningbo PMO and the Company have taken measures in this LMP to align them with ESS2. 4 Brief Overview of Labor Legislation: Occupational Health and Safety In China, there are over one hundred technical specifications and standards for the control of occupational safety and prevention of diseases under the Labor Law system. These technical specifications and standards are developed based on the industry best practice or updated toward the industry best practice, i.e. WHO, and relevant technical codes/norms of EU or USA, and the 25 In China, enterprises are required: 1) to pay no less than 150 percent of the normal wages if the extension of working hours is arranged; 2) to pay no less than 200 percent of the normal wages if the extended hours are arranged on days of rest and no deferred rest can be taken; and 3) to pay no less than 300 percent of the normal wages if the extended hours are arranged on statutory holidays. 149 requirements of the International Labor Conventions 26 . These technical specifications and standards become compulsory to apply in the design and operation of the facilities. According to the Labor Law and the Law on the Prevention and Control of Occupational Diseases, the main OHS requirements are as follows: 1) Employers shall establish a complete occupational health and safety system, strictly enforce relevant measures and standards, and offer relevant training to workers to prevent accidents at work, and reduce occupational hazards. 2) Labor safety and health facilities must comply with the applicable national standards. Newly constructed, reconstructed or expanded labor safety and health facilities must be designed, constructed and put into operation together with the main part of the project. 3) Employers shall provide labor safety and health conditions, and necessary labor protection articles complying with the state provisions to workers, and conduct regular health checkups for workers doing hazardous jobs. 4) Workers doing special jobs must receive special training and be qualified for such jobs. 5) Workers must comply strictly with safety operation regulations at work, and shall have the right to reject employer management staff’s nonconforming or risky instructions, and criticize or prosecute activities endangering life safety and physical health. 6) The state shall establish a counting, reporting and handling system for casualty accidents and occupational diseases. Labor authorities of governments at or above the county level and employers shall count, report and handle casualty accidents and occupational diseases of workers at work. The HR procedures and policies drafted by the Company cover OHS requirements for workers. For the construction and operation of this subproject, the Company will provide labor safety and health conditions, and necessary labor protection articles complying with the state provisions to workers, and conduct regular health checkups for workers by reference to the rules and regulations of its parent company (Ningbo Municipal Public Utilities Investment Co., Ltd.). There is no gap found between the Company’s practices and ESS2. Employees have the right to report any act endangering their health and safety. In addition, employees may file an OHS complaint to the municipal human resource and social security bureau. Therefore, the employee GRM complies with ESS2. 5 Responsible Staff The agencies responsible for this subproject are the Ningbo PMO (civil servants) and the Company. ⚫ Ningbo PMO: Ningbo PMO will be responsible for the overall project organization, coordination, supervision and guidance, and communicate with the Bank. Ningbo PMO has promised to appoint an environmental staff and a social staff to be responsible for E&S policy training, document preparation, implementation and performance evaluation, including labor management. 26 Historical So far, China has signed 25 of the International Labor Conventions, including Convention on Equal Pay for Equal Work (100th convention), Minimum Employment Age Convention (138 th convention), The Worst Forms of Child Labor Convention (182th convention), and Employment and Occupation Discrimination Convention (111 th convention), etc. 150 ⚫ PIU (the Company): According to the Company’s preliminary organization structure, the Company will comprise the General Office, Finance Dept., Project Dept., etc., in which the General Office is responsible for the Company’s personnel affairs, including recruitment, training, payroll, social insurance and performance evaluation, as well as training on OHS and job skills and duties. As discussed in Sections 3 and 4, the HR procedures and policies of the parent company of the Company cover working conditions and OHS for workers. The Company will appoint a full-time staff to be responsible for E&S document management, including labor conditions, OHS, employee grievance redress, direct workers’ performance, management of contracted and primary supply workers, etc. The Company will establish a sound GRM for employees, including internal and external channels. The Company will offer multiple channels for workers to raise workplace issues. A worker may first report to the person responsible for the workplace or his/her direct supervisor; if he/she is dissatisfied with the reply, he/she may report to the department manager, or finally report to the General Manager. All channels run in parallel, and workers may use any channel at their discretion. In sum, the Company has established a sound management procedure for direct workers (especially child labor, forced labor and OHS), meeting the requirements of ESS2. However, as confirmed by the Company, the company does not currently have policies or procedures for managing risks to workers employed by contractors or primary supplier that are anticipated under ESS2, and this LMP includes measures to address such gap. In addition, when employing a contractor, the Company will include labor management requirements in the tendering documents. The contractor should comply with ESS2 and this LMP (including the prohibition of child and forced labor, labor terms and conditions, OHS, etc.), include this in its contract, and cause any subcontractor to do the same. The Company will establish systems on HR, OHS management, work safety, etc. in accordance with the Bank’s ESS2, the applicable laws and regulations of China, and Section 6 below, especially the management and monitoring of contracted and primary workers recruited through third parties. 6 Policies and Procedures China has a relatively sound legal framework on labor and working conditions, especially child labor, forced labor and OHS. Contractors would usually develop a series of management plans and procedures, covering quality, environment, safety management, site management, worker management, etc. The Chinese laws stipulate that when an employer employs an employee, it should sign an employment contract with the employee equally and voluntarily to define their rights and obligations. Both China’s Labor Law (2018) and Labor Contract Law (2012) apply. The national and Ningbo’s municipal policies make provisions on salary, working hours, labor protection and labor disputes, and prohibit forced labor and child labor, which is completely consistent with the requirements of ESS2. According to Sections 3, 4 and 5, the labor risks identified in Section 2 have been managed effectively under the prevailing LMP. For the gaps from the ESS2 requirements (e.g., management of contracted and primary supply workers), Ningbo PMO and the Company will take measures to strengthen the LMP for this subproject to comply with ESS2. 151 ⚫ Ningbo PMO: Ningbo PMO will appoint a full-time staff member for routine labor risk communication, and provide support to the PIU. The PIU is also required to appoint a full- time staff member to supervise labor and safety performance. The Ningbo PMO will document the above arrangement in the ESCP. ⚫ PIU (the Company): The Company will take the following measures to strengthen the management of contracted and primary supply workers – o Appointing qualified employees to manage the performance of direct workers and contractors; o Implementing this LMP; o Ensuring that each contractor develops its own LMP according to this LMP; o Including detailed COVID-19 prevention and control measures in the contract; o Monitoring, supervising and reporting health and safety concerns related to COVID- 19, including main responsibilities and reporting arrangements related to contractors; o Strengthening workers’ awareness and training to prevent COVID-19 dissemination; o Strengthening workers’ awareness and training to prevent and reduce gender-based violence and sexual harassment; o Supervising contractors to perform the labor obligations in the General Contract Terms in the tendering documents, and meet the requirements of ESS2 and China’s Labor Law; o Supervising contractors to implement this LMP; o Ensuring that the workplace OHS standard complies with the state OHS laws and OHS plan; o Supervising project worker training; o Ensuring that a GRM available to all types of project workers is established, and supervising its implementation; o Supervising primary suppliers to take measures to correct potential risks related to child labor forced labor and OHS; o Reporting the performance of project workers to the Ningbo PMO semi-annually ⚫ Contractors: The contract shall include provisions on compliance with ESS2. Contractors and subcontractors shall assume the following duties – o Developing an LMP and an OHS plan, which will be submitted to the PIU for approval; o Keeping recruitment and employment records of contracted workers; o Notifying job descriptions and labor conditions to contracted workers; o Developing and implementing a labor GRM; o Implementing prevention and control measures for COVID-19 and other infectious diseases; o Monitoring, supervising and reporting health and safety concerns related to COVID- 19, o Strengthening workers’ awareness and training to prevent and reduce COVID-19 dissemination risks; 152 o Strengthening workers’ awareness and training to prevent and reduce gender-based violence and sexual harassment; o Establishing a regular review and reporting system on worker OHS performance; o Offering induction, and health and safety training to workers regularly; o Ensuring that all workers confirm that they understand the working requirements in writing; o Updating its LMP if necessary; o Reporting the labor performance of contracted workers to the PIU monthly ⚫ Third-party monitor: Ningbo PMO will appoint a third-party monitor to evaluate the performance of all types of workers, and the TORs should meet the Bank requirements. 7 Age of Employment China’s Labor Law (2018) defines minimum working age at 16, which is more stringent than the requirements of ESS 2 (14 years old). Both China’s Labor Law (2018) and Regulation on Special Protection for Juvenile Workers (1994) sets out specific protection for juvenile workers (aged from 16 to 18). Juvenile workers should be prohibited in working in a few hazardous positions such in unhealthy, hazardous or toxic circumstance, during the night, with dangerous machinery, equipment or tools, or involving handling or transport of heavy loads. The Company complies strictly with China’s policy on the prohibition of child and forced labor. Qualified candidates should have received undergraduate or above education, with a minimum age of 21-22 years. As of August 2021, the youngest employee of Ningbo Municipal Infrastructure Investment Co., Ltd. was 22 years old. Before employment, Ningbo Municipal Infrastructure Investment Co., Ltd. asks every candidate to provide basic information (e.g., a copy of the ID card) for further verification by the HR Dept. During the construction and operation of this subproject, the Company will ask its contractors and primary suppliers to verify the ages of all workers to assure no child labor will be employed or engaged with this subproject. This will require workers to provide official documentation, which could include a birth certificate, national identification card, or medical or school record. If a child under the minimum age is identified working on this subproject, measures will be taken to immediately terminate the employment or engagement of the child in a responsible manner, considering the best interest of the child. 8 Terms and Conditions As shown in legal review (Section 3 in this LMP), China has established very comprehensive regulations regarding terms and conditions for a labor contract, which are deemed in alignment with relevant requirements of ESS2. Ningbo Municipal Public Utilities Investment Co., Ltd. can sign a labor contract in writing with an employee. The labor contract should cover the basic terms and conditions, including the term of specific job positions, work content and place of work, work time and rest time, labor remuneration, bonus and social insurances, labor protection, labor conditions and protection against occupational hazards, and specified economic compensation. The content of a labor contract should be reached through prior consensus between the employer and an employee, 153 without any violation against China’s labor related regulations and the requirements of ESS2. The Company promises to adopt the same personnel management systems. The contractors’ labor management procedures will set out terms and conditions for the contracted workers. These terms and conditions will meet the requirements of ESS2 and the ESCP, and be aligned with this LMP. 9 GRM Ningbo PMO and the Company will establish and implement a GRM for workers, including direct hires. Ningbo PMO and the Company have established grievance redress hotlines (0574-8719 1097 and 0574-8738 4952). In addition, the Company will ask contractors to develop and implement a GRM for workers. The construction contractors will prepare their labor management procedure before subproject construction, which will also include detailed description of the GRM for workers, which includes: • A procedure to receive grievances such as comment/complaint form, suggestion boxes, email, a telephone hotline; • Stipulated timeframes to respond to grievances; • A registration system to record and track the timely resolution of grievances; • A responsible unit to receive, record and track resolution of grievances. The Company will assign dedicated staff to supervise grievance redress by contractors, and report to the PMO in monthly progress reports. The GRM for workers will be described in staff induction training, which will be provided to all project workers. The mechanism will be based on the following principles: • The process will be transparent and allow workers to express their concerns and file grievances. • There will be no discrimination against those who express grievances and any grievances will be treated confidentially. • Anonymous grievances will be treated equally as other grievances, whose origin is known. • Grievances will be seriously treated and timely and appropriate action in response will be taken. Information about the existence of the GRM will be readily available to all project workers (direct and contracted) through the PIU’s website, staff meetings, and other means as needed. In addition, the Ningbo Municipal Human Resources and Social Security Bureau has disclosed the appeal hotlines of all municipal and district labor protection supervision agencies on its official website (http://rsj.ningbo.gov.cn/art/2018/10/9/art_1229130162_49605564.html), so that all workers can file grievances about labor contracts, remuneration, working conditions, etc. The GRM for workers will not prevent workers to use the mediation procedure provided in the China’s Labor Law. The basic procedure is as follows: Stage 1: The party that asks for arbitration shall file a written application to the labor dispute arbitration committee within 60 days starting from the date of the occurrence of labor dispute. In general, the arbitration committee shall produce a ruling within 60 days after receiving the application. The parties involved shall implement arbitration rulings if they do not have any objections to these rulings. Labor dispute arbitration 154 committees shall be composed of the representatives of labor administrative departments, representatives from trade unions at the same level, and the employer representatives. The chairmanship of such a committee shall be held by the representative of a labor administrative department. Stage 2: If any of the parties involved in a labor dispute has objections to an arbitration ruling, it can raise a lawsuit with the People’s Court within 15 days after receiving the ruling. 10 Contractor Management The Company will ask all contractors participating in the Project to operate in a manner that complies with the ESS (including the requirements in the ESCP). Contractor management is conducted through the tendering process. The tendering documents shall meet the World Bank’s requirements, including labor, OHS, and COVID-19 prevention and control. As part of the process to select construction contractors who will engage contracted workers, the Company will review the following information: • Information in public records, for example, corporate registers and public documents relating to violations of applicable labor law, including reports from labor inspectorates and other enforcement bodies; • Business licenses, registrations, permits, and approvals; • Documents relating to a labor management system, including OHS issues, for example, labor management procedures; • Identification of labor management, safety, and health personnel, their qualifications, and certifications; • Workers’ certifications/permits/training to perform required work; • Records of safety and health violations, and responses; • Accident and fatality records and notifications to authorities; • Records of legally required worker benefits and proof of workers’ enrollment in the related programs; • Worker payroll records, including hours worked and pay received; and • Copies of previous contracts with contractors and suppliers, showing inclusion of provisions and terms reflecting ESS2. The bidding document will screen out any bidder that uses child labor or involve historic child labor use. Per China’s Labor Law, the minimum working age is 16 years old. The contracts with selected contractors will include provisions related to labor and occupational health and safety, as set out in ESS2 and China’s regulations. The Company will manage and supervise the performance of contractors, with focus on their contract compliance, possibly including regular auditing, on-site inspection and/or record review. Contractors’ labor management records and reports may include: • A representative sample of employment contracts or arrangements between third parties and contracted workers; • Records relating to grievances received and their resolution; • Reports relating to safety inspections, including fatalities and incidents and implementation of corrective actions; • Records relating to incidents of non-compliance with national law; and 155 • Records of training provided for contracted workers to explain labor and working conditions and OHS for the subproject. Contractor labor performance should be part of progress reports submitted to the Ningbo PMO. 11 Primary Supplier’s Workers The Company will review primary suppliers to identify their labor force, and screen major risks and impacts, especially forced labor, child labor and serious safety problems. If a primary supplier has any major child labor or forced labor risk, or any serious safety problem, the Company should take the following measures: • Evaluating the magnitude of major risks related to primary supply workers, and designing appropriate mitigation measures in the SMP; • Following up with primary suppliers on quarterly basis for the implementation status of environmental measures (if any), thereby ensuring that labor management is well implemented, and reporting their labor performance to Ningbo PMO regularly as part of progress reports; • If it is impossible to take any remedy for any identified labor risk, the PIU will transfer primary suppliers to suppliers that can prove their compliance with ESS2 within a reasonable period. 156 Appendix 2.4 LMP for Recyclables Sorting Centers The recyclables sorting centers (hereinafter, “this subproject”) are one of the Batch 2 subprojects. Its PIU is Ningbo Dabashou Eco-digital Technology Co., Ltd. (hereinafter, the “Company”), which was founded in May 2021, being one of the PIUs of the Batch 1 subprojects. At the preparation stage of the Batch 1 subprojects, an LMP was prepared based on the SIA on the Batch 1 subprojects27. The Company is 44% funded by NBSMC Renewable Resources Technology Co., Ltd., 32% by Ningbo Municipal Public Utilities Investment Co., Ltd., and 24% by the contribution representatives of 8 urban districts. This LMP is a living document, and has been updated on the SIA Report for the Batch 2 subprojects. 1 Overview of Project Workers The 4 recyclables sorting centers are located in Zhenhai, Beilun, Yinzhou and Haishu Districts of Ningbo City. Among the Batch 2 subprojects, the recyclables sorting centers in Yinzhou and Haishu districts will be reconstructed based on existing facilities, and the other two will be newly constructed, with a treatment capacity of 50-75t/d each. The sorting centers target recyclables, including plastic bottles, low-value dirty plastics, daily chemical plastic waste, waste paper, waste glass, waste metals, waste textiles, etc., and recyclables are mainly from smart dustbins in communities. According to the definition of project workers in ESS2, social audit and SIA, this subproject involves direct and contracted workers. Direct hires: Management staff, technicians, dispatching center staff, etc. at the construction and operation stages, all with relevant experience Contract workers: Construction workers of this subproject, and sorters and drivers (from smart dustbins in communities to sorting centers) hired by the third-party operation company that may be appointed at the operation stage An estimate of types and numbers of workers is shown in Table 1. Table 1 Estimate of Types and Numbers of Project Workers Subproject Stage Direct hires Contract workers Primary suppliers’ workers Preparation 8 0 0 Recyclables Civil works 8 100 2 sorting Construction centers Equipment installation 8 32 1 Operation 12 48 0 Source: The Company The Company has been newly established, and has a workforce of less than 10, all having received undergraduate or above education. The Company is recruiting staff gradually as necessary. The Company will review labor management systems of bidding contractors through its bidding mechanism and ask contractors to establish labor management procedures in accordance with ESS2. Bidding is under preparation, so it is uncertain if contracted workers include nonlocal workers, which will be further identified during implementation. 27 See the SIA Report for the Batch 1 subprojects approved by the Bank in February 2021. 157 According to the social audit, the sorters (about 10 at each sorting center) and drivers will be mainly from nearby villages, mostly women aged 35-55 years. 2 Screening of Potential Significant Labor Risks 2.1 Subproject activities The 4 recyclables sorting centers are located in Zhenhai, Beilun, Yinzhou and Haishu districts of Ningbo City, with a floor area of about 10 mu each. Recyclable waste includes waste paper, waste plastics, waste textiles, waste glass, etc., and is from smart waste collection cabins deployed in the urban communities. Such waste is transferred by vans to the recyclables sorting center for simple manual sorting and compression, and then are sold to terminal waste utilization enterprises. 2.2 Major labor risks At the preparation stage, a social impact survey and extensive stakeholder engagement were conducted on this subproject, and major labor risks were identified. According to the SIA of the Batch 2 subprojects, the Project is located in the developed city of Ningbo, where the government has a well-established labor management and supervision system for enterprises, so this subproject’s labor risks are negligible or very low, mainly including: • Forced labor and child labor • Discrimination in recruitment According to the scope, scale and nature of this subproject, major labor risks related that may be encountered by workers include: A. Construction stage • Dangerous work: Construction workers working at height or in confined spaces, or using heavy machinery or dangerous materials; • Safety risks in machinery operation: Accidents of construction workers during construction, such as welding, cutting and operating relevant tools; • Noise from mechanical construction: Loud, repeated and excessive noises that may arise during construction, possibly leading to long-term hearing problems, such as deafness, and also being a dangerous distraction that increases accident risks; • Emergency risks: Emergencies and quality safety accidents arising from unsound civilized construction and quality safety management measures, or inadequate management; • Sexual harassment or gender-based violence risks: Physical or mental violence against women due to gender or lifestyle differences; • Workplace accidents: Safety accidents arising from work shed collapse due to quality problems or natural disasters; • Health and infection risks: Disease infection risks (e.g., COVID-19) arising from the improper diet and accommodation management, or health management of construction workers; • Renumeration: Workers’ rights and interests unsecured because contractors fail to strictly enforce the applicable laws and regulations, and enter into employment contracts. B. Operation stage 158 • Traffic risks: Potential traffic accidents during the transport of recyclables from smart dustbins in communities to sorting centers; • Physical injuries: Scratches by recyclables (plastics, glass, etc.) during sorting; • Noise: Noises generated by equipment operation, which may harm the workers’ hearing and physical health; • Heat and odor: odor arising from deteriorating residues of recyclables in summer, which may harm the workers’ physical health; • Dust pollution: dust generated by the sorting and packing of recyclables (e.g., paperboards), which may harm the workers’ physical health; • Emergency risks: operating mistakes in forklift operation and recyclable packing, which pose health and life risks to workers; • Infection: Disease infection risks (e.g., COVID-19) during recyclable (waste) collection and transfer, and close contact with people. 3 Brief Overview of Labor Legislation: Terms and Conditions China has established a sound system of laws and regulations on labor management. As a member of the International Labor Organization (ILO), China has approved 26 conventions (including 20 that have taken effect), including equal remuneration, discrimination, minimum age, child labor, OHS, employment policy, consulting, risk of association, etc. In general, the national and municpal policies make provisions on salary, working hours, labor protection and labor disputes, and prohibit forced labor and child labor, which is completely consistent with the requirements of ESS2. Table 2 Applicable PRC Laws relating to Labor and Working Conditions No. Title Effective year 1 China’s Labor Law 1995, amended in 2018 2 Provisions of the State Council on Working Hours of Workers and Staff 1995 3 China’s Emergency Incident Response Law 2007 4 Regulations on the Implementation of China’s Labor Contract Law 2008 5 China’s Labor Contract Law 2008, amended in 2012 6 Special Rules on Labor Protection of Female Employees 2012 7 China’s Law on the Prevention and Control of Occupational Diseases 2017 Table 3 List of ILO Conventions Approved by China Convention Date Basic conventions (4) C100 - Equal Remuneration Convention, 1951 (No.100) 1990.12.02 C111 - Discrimination (Employment and Occupation) Convention, 1958 (No.111) 2006.01.12 C138 - Minimum Age Convention, 1973 (No.138), specifying the minimum wage of 16 years 1999.04.28 C182 - Worst Forms of Child Labor Convention, 1999 (No.182) 2002.08.08 Governance (priority) conventions (2) C122 - Employment Policy Convention, 1964 (No.122) 1997.12.17 C144 - Tripartite Consultation (International Labor Standards) Convention, 1976 (No.144) 1990.11.02 159 Convention Date Technical conventions (14) C011 - Right of Association (Agriculture) Convention, 1921 (No.11) 1934.04.27 C014 - Weekly Rest (Industry) Convention, 1921 (No. 14) 1934.05.17 C019 - Equality of Treatment (Accident Compensation) Convention, 1925 (No. 19) 1934.04.27 C026 - Minimum Wage-Fixing Machinery Convention, 1928 (No. 26) 1930.05.05 C027 - Marking of Weight (Packages Transported by Vessels) Convention, 1929 (No. 27) 1931.06.24 C032 - Protection against Accidents (Dockers) Convention (Revised), 1932 (No. 32) 1935.11.30 C045 - Underground Work (Women) Convention, 1935 (No. 45) 1936.12.02 C080 - Final Articles Revision Convention, 1946 (No. 80) 1947.08.04 C150 - Labor Administration Convention, 1978 (No. 150) 2002.03.07 C155 - Occupational Safety and Health Convention, 1981 (No. 155) 2007.01.25 C159 - Vocational Rehabilitation and Employment (Disabled Persons) Convention, 1983 (No. 1988.02.02 159) C167 - Safety and Health in Construction Convention, 1988 (No. 167) 2002.03.07 C170 - Chemicals Convention, 1990 (No. 170) 1995.01.11 Maritime Labor Convention, 2006 (MLC) 2015.12.12, According to A4.5 (2) and (10), the government designates the following social security amended in sectors: medical, unemployment benefit, pension, employment injury benefit, and maternity 2016 and 2018 benefit. Source: official website of ILO, December 29, 2020 The Company is also a PIU of the Batch 1 subprojects. With the implementation of the Batch 1 subprojects, the Company’s systems have improved greatly, including/l • General Manager’s Office Meeting System (trial), October 2021; • Workplace Attendance Management System (trial), October 2021; • Renumeration Management System (trial), October 2021; • Supplier Management System (trial), October 2021; • Human Resources Management System (trial), April 2022; • Work Safety Management System (trial), April 2022; • Occupational Health Management System (trial), April 2022; • Safety Education and Management System (trial), April 2022; • Accident Reporting System (trial), April 2022; • Office Emergency Response Plan (trial), April 2022. When the Company signs a labor contract, its basic terms and conditions include detailed job requirements, scope and place of work, working and rest hours, remuneration, bonus, social insurance, labor protection, labor conditions, occupational hazard protection, and economic compensation. During contract term, an employee may consult the HR staff at any time. Both parties may alter the contract when reaching an agreement. The working hours of the Company comply with China’s policies. In case of overtime work, an overtime pay will be paid according to 160 policies28. Employees are entitled to paid leaves. For example, if an employee has a service length of less than 10 years, he/she is entitled to a paid annual leave of 5 days; if an employee has a service length of 10 years or more, he/she is entitled to a paid annual leave of 10 days. The employees of the Company are entitled to statutory social insurance (endowment, medical, unemployment, accident, maternity, etc.), and a housing provident fund. Female employees’ extra benefits are based on the applicable state and local regulations, such as the Measures for the Labor Protection of Female Workers of Zhejiang Province. The Company’s Renumeration Management System specifies that the basic salary structure is: monthly salary = base salary + job salary + performance bonus + traffic subsidy + communication subsidy + meal subsidy. In general, the employees’ monthly salaries are much higher than the local minimum salary standard29; the annual salary is 13 times the monthly salary. According to the information provided by the General Office of the Company, the minimum monthly salary is over 4,000 yuan. For duty watch in non-working hours, the Company offers subsidies, such as 200 yuan per day per capita on legal holidays and 100 yuan per day per capita at weekends. In addition, an employee having worked at the Company for one year and having attained 35 years is entitled to a health checkup every two years. China’s Labor Law and the Labor Contract Law have clear provisions on employment, labor contract management and leaves, and the relevant practices of the Company comply with such provisions, and are communicated to all employees through induction training, on-the-job training and routine operations. In terms of contract terms and working conditions for direct hires, there is no gap found between the practices of the Company and ESS2. However, the policies used by the PIU in managing labor risks of contracted, community and primary supply workers have significant gaps from ESS2. The Ningbo PMO and the Company have taken measures in this LMP to align them with ESS2. 4 Brief Overview of Labor Legislation: Occupational Health and Safety In China, there are over one hundred technical specifications and standards for prevention and control of occupational safety and diseases under the Labor Law system. These technical specifications and standards are developed based on the industry best practice or updated toward the industry best practice, i.e. WHO, and relevant technical codes/norms of EU or USA, and the requirements of the International Labor Conventions 30 . These technical specifications and standards become compulsory to apply in the design and operation of the facilities. The Company attaches great importance to the OHS of direct workers, and has established and implemented relevant management procedures and policies. 28 In China, enterprises are required: 1) to pay no less than 150 percent of the normal wages if the extension of working hours is arranged; 2) to pay no less than 200 percent of the normal wages if the extended hours are arranged on days of rest and no deferred rest can be taken; and 3) to pay no less than 300 percent of the normal wages if the extended hours are arranged on statutory holidays. 29 Being 2,010 yuan/month in 2020 30 Historical So far, China has signed 25 of the International Labor Conventions, including Convention on Equal Pay for Equal Work (100th convention), Minimum Employment Age Convention (138th convention), The Worst Forms of Child Labor Convention (182th convention), and Employment and Occupation Discrimination Convention (111th convention), etc. 161 The Company’s Work Safety Management System includes 31 sets of regulations related to potential business risks. The potential labor risks identified can be managed effectively through this system, including the work safety responsibility system, safety management system for equipment, facilities and goods, work safety training and education system, work safety supervision and potential risk management system, accident reporting and investigation system, driver file management system, vehicle safety inspection system, PPE management system, road transport management system, emergency rescue support system, occupational health management system, etc. In addition, the Work Safety Management System also includes the work safety reporting and investigation system, and the reporting hotline and e-mail address are disclosed. When the Company receives any report or complaint, the General Manager will establish an investigation team, which will keep the reporter’s information confidential. For COVID-19 and other potential infectious diseases, pandemic prevention and control organizations have been established at the municipal and district levels, and the Company has established an internal pandemic prevention and control system, and prepared a working plan, covering material reservation, living support, security. Dedicated staff is assigned for temperature taking, ventilation, disinfection, PPE distribution, publicity and education, pandemic information collection and submission, and emergency measures and a handling process have been defined to reduce infection risks. The Company has established a sound OHS system according to the Labor Law, and Law on the Prevention and Control of Occupational Diseases, complies strictly with the national regulations and standards on OHS, and conducts OHS education for workers to prevent work-related accidents, and reduce occupational hazards. OHS facilities must comply with the national standards. The Company provides labor safety and health conditions, and necessary labor protection articles complying with the state provisions to workers, and conducts regular health checkups for workers. Employees have the right to report any act endangering their health and safety. There is no gap found between the Company’s practices and ESS2. 5 Responsible Staff The agencies responsible for this subproject are the Ningbo PMO (civil servants) and the Company. ⚫ Ningbo PMO: Ningbo PMO will be responsible for the overall project organization, coordination, supervision and guidance, and communicate with the Bank. Ningbo PMO has promised to appoint an environmental staff and a social staff to be responsible for E&S policy training, document preparation, implementation and performance evaluation, including labor management. ⚫ PIU (the Company): The Company is a PIU of the Batch 1 subprojects, and the recyclables sorting centers in the Batch 2 subprojects. The Company comprises the Procurement Center, Finance Center, General Office, Strategic Planning Center, Project Management Center, and Software Center, in which the General Office is responsible for the Company’s HR affairs, including recruitment, training, payroll, social insurance and performance evaluation, as well as training on OHS and job skills and duties. As discussed in Sections 3 and 4, the personnel management procedures and policies of the parent company of the Company cover working conditions and OHS for worker. 162 The Company will appoint a full-time staff to be responsible for E&S document management, including labor conditions, OHS, employee grievance redress, direct workers’ performance, management of contracted workers, etc. The Company has established a trade union, and employees may join it voluntarily. The trade union’s main duties include: 1) conducting occupational disease p revention and control, and health checkups for workers; 2) supervising the implementation of resolutions of the workers’ congress; 3) directing workers to sign labor contracts, and negotiate remuneration, working hours, work safety and health, benefits, etc.; 4) signing collective labor contracts on behalf of workers, supervising the performance thereof, and mediating labor disputes; and 5) protecting the special rights and interests of female workers. The Company has established a sound GRM for employees, including internal and external channels. A. Internal channels, including: • Workplace head or direct supervisor; • Manager in charge; • Personnel officer of the General Office; • Labor union chairman and internal hotline; • General Manager; • Public account, applet, website feedback and “400” hotline The Company will offer multiple channels for workers to raise workplace issues. A worker may first report to the person responsible for the workplace or his/her direct supervisor; if he/she is dissatisfied with the reply, he/she may report to the department manager, or finally report to the General Manager. All channels run in parallel, and workers may use any channel at their discretion. B. External channels: The Company has established a work safety reporting and investigation system, and assigned dedicated staff to accept complaints related to work safety. The GRM operates well, and can usually handle employee complaints and give feedback. The Company has dedicated and qualified HR staff responsible to manage day-to-day work and handle employee complaints, which is consistent with the requirements of ESS2. In sum, the Company has established a sound management procedure for direct workers (especially child labor, forced labor and OHS), meeting the requirements of ESS2. However, as confirmed by the Company, the Company does not currently have policies or procedures for managing risks to workers employed by contractors or primary supplier that are anticipated under ESS2, and this LMP includes measures to address such gap. In addition, when employing a contractor, the Company will include labor management requirements in the tendering documents. The contractor should comply with ESS2 and this LMP (including the prohibition of child and forced labor, labor terms and conditions, OHS, etc.), include this in its contract, and cause any subcontractor to do the same. See Section 6 for detailed requirements. 6 Policies and Procedures China has a relatively sound legal framework on labor and working conditions, especially child 163 labor, forced labor and OHS. Contractors would usually develop a series of management plans and procedures, covering quality, environment, safety management, site management, worker management, etc. The Chinese laws stipulate that when an employer employs an employee, it should sign an employment contract with the employee equally and voluntarily to define their rights and obligations. Both China’s Labor Law (2018) and Labor Contract Law (2012) apply. The Chinese and Ningbo policies make provisions on salary, working hours, labor protection and labor disputes, and prohibit forced labor and child labor, which is completely consistent with the requirements of ESS2. According to Sections 3, 4 and 5, the labor risks identified in Section 2 have been managed effectively under the prevailing LMP. For the gaps from the ESS2 requirements (e.g., management of contracted and primary suppliers’ workers), Ningbo PMO and the Company will take measures to strengthen the LMP for this subproject to comply with ESS2. ⚫ Ningbo PMO: Ningbo PMO will appoint a full-time staff for routine labor risk communication, and provide support to the PIU. The Company is also required to appoint a full-time staff to supervise labor and safety performance. ⚫ PIU (the Company): To make up the above gaps, the Company will improve its LMP, and strengthen the following aspects – o Appointing qualified employees to manage the performance of direct workers and contractors; o Implementing this LMP; o Ensuring that each contractor develops its own LMP according to this LMP; o Supervising contractors to perform the labor obligations in the General Contract Terms in the tendering documents, and meet the requirements of ESS2 and China’s Labor Law; o Supervising contractors to implement this LMP; o Ensuring that the workplace OHS standard complies with the state OHS laws and OHS plan; o Including detailed COVID-19 prevention and control measures in the contract; o Monitoring, supervising and reporting health and safety concerns related to COVID- 19, including main responsibilities and reporting arrangements related to contractors; o Strengthening workers’ awareness and training to prevent COVID-19 dissemination; o Supervising project worker training; o Ensuring that a GRM available to all types of project workers is established, and supervising its implementation; o Supervising primary suppliers to take measures to correct potential risks related to child labor forced labor and OHS; o Reporting the performance of project workers to the Ningbo PMO semiannually 164 ⚫ Contractors: The contract shall include provisions on compliance with ESS2. Contractors and subcontractors shall assume the following duties – o Developing an LMP and an OHS plan, which will be submitted to the PIU for approval; o Keeping recruitment and employment records of contracted workers; o Notifying job descriptions and labor conditions to contracted workers; o Developing and implementing a labor GRM; o Implementing prevention and control measures for COVID-19 and other infectious diseases; o Monitoring, supervising and reporting health and safety concerns related to COVID- 19, o Strengthening workers’ awareness and training to prevent and reduce COVID-19 dissemination risks; o Establishing a regular review and reporting system on worker OHS performance; o Offering induction, and health and safety training to workers regularly; o Ensuring that all workers confirm that they understand the working requirements in writing; o Updating its LMP if necessary; o Reporting the labor performance of contracted workers to the PIU monthly ⚫ Third-party monitor: Ningbo PMO will appoint a third-party monitor to evaluate the performance of all types of workers, and the TORs should meet the Bank requirements. 7 Age of Employment China’s Labor Law (2018) defines minimum working age at 16, which is more stringent than the requirements of ESS 2 (14 years old). Both China’s Labor Law (2018) and Regulation on Special Protection for Juvenile Workers (1994) sets out specific protection for juvenile workers (aged from 16 to 18). Juvenile workers should be prohibited in working in a few hazardous positions such in unhealthy, hazardous or toxic circumstance, during the night, with dangerous machinery, equipment or tools, or involving handling or transport of heavy loads. The Company complies strictly with China’s policy on the prohibition of child and forced labor. Qualified candidates should have received undergraduate or above education, with a minimum age of 21-22 years. As of October 2021, the youngest employee of the Company was 23 years old. Before employment, the Company asks every candidate to provide basic information (e.g., a copy of the ID card) for further verification by the HR Dept. During the construction and operation of this subproject, the Company will ask its contractors and primary suppliers to verify the ages of all workers to assure no child labor will be employed or engaged with this subproject. This will require workers to provide official documentation, which could include a birth certificate, national identification card, or medical or school record. If a child under the minimum age is identified working on this subproject, measures will be taken to immediately terminate the employment or engagement of the child in a responsible manner, considering the best interest of the child. 165 8 Terms and Conditions As shown in legal review (Section 3 in this LMP), China has established very comprehensive regulations regarding terms and conditions for a labor contract, which are deemed in alignment with relevant requirements of ESS2. The Company can sign a labor contract in writing with an employee. The labor contract should cover the basic terms and conditions, including the term of specific job positions, work content and place of work, work time and rest time, labor remuneration, bonus and social insurances, labor protection, labor conditions and protection against occupational hazards, and specified economic compensation. The content of a labor contract should be reached through prior consensus between the employer and an employee, without any violation against China’s labor related regulations and the requirements of ESS2. The contractors’ labor management procedures will set out terms and conditions for the contracted workers. These terms and conditions will meet the requirements of ESS2 and the ESCP, and be aligned with this LMP. 9 GRM As described in Section 5, the Company has established sound internal and external grievance redress channels. The Ningbo PMO and the Company will establish and implement a GRM for workers, including direct hires. Ningbo PMO and the Company have established grievance redress hotlines (0574- 87191097 and 0574-56177692). In addition, the Company will ask contractors to develop and implement a GRM for workers. The construction contractors will prepare their labor management procedure before subproject construction, which will also include detailed description of the GRM for workers, which includes: • A procedure to receive grievances such as comment/complaint form, suggestion boxes, email, a telephone hotline; • Stipulated timeframes to respond to grievances; • A registration system to record and track the timely resolution of grievances; • A responsible unit to receive, record and track resolution of grievances. The Company will assign dedicated staff to supervise grievance redress by contractors, and report to the PMO in monthly progress reports. The GRM for workers will be described in staff induction training, which will be provided to all project workers. The mechanism will be based on the following principles: • The process will be transparent and allow workers to express their concerns and file grievances. • There will be no discrimination against those who express grievances and any grievances will be treated confidentially. • Anonymous grievances will be treated equally as other grievances, whose origin is known. • Grievances will be seriously treated and timely and appropriate action in response will be taken. Information about the existence of the GRM will be readily available to all project workers (direct hires and contract workers) through the PIU’s website, staff meetings, and other means as needed. 166 In addition, the Ningbo Municipal Human Resources and Social Security Bureau has disclosed the appeal hotlines of all municipal and district labor protection supervision agencies on its official website (http://rsj.ningbo.gov.cn/art/2018/10/9/art_1229130162_49605564.html), so that all workers can file grievances about labor contracts, remuneration, working conditions, etc. The GRM for workers will not prevent workers to use the mediation procedure provided in the China’s Labor Law. The basic procedure is as follows: Stage 1: The party that asks for arbitration shall file a written application to the labor dispute arbitration committee within 60 days starting from the date of the occurrence of labor dispute. In general, the arbitration committee shall produce a ruling within 60 days after receiving the application. The parties involved shall implement arbitration rulings if they do not have any objections to these rulings. Labor dispute arbitration committees shall be composed of the representatives of labor administrative departments, representatives from trade unions at the same level, and the employer representatives. The chairmanship of such a committee shall be held by the representative of a labor administrative department. Stage 2: If any of the parties involved in a labor dispute has objections to an arbitration ruling, it can raise a lawsuit with the People’s Court within 15 days after receiving the ruling. 10 Contractor Management The Company will ask all contractors participating in the Project to operate in a manner that complies with the ESS (including the requirements in the ESCP). Contractor management is conducted through the tendering process. The tendering documents shall meet the Bank’s requirements, including labor, OHS, and COVID-19 prevention and control. As part of the process to select construction contractors who will engage contracted workers, the Company will review the following information: • Information in public records, for example, corporate registers and public documents relating to violations of applicable labor law, including reports from labor inspectorates and other enforcement bodies; • Business licenses, registrations, permits, and approvals; • Documents relating to a labor management system, including OHS issues, for example, labor management procedures; • Identification of labor management, safety, and health personnel, their qualifications, and certifications; • Workers’ certifications/permits/training to perform required work; • Records of safety and health violations, and responses; • Accident and fatality records and notifications to authorities; • Records of legally required worker benefits and proof of workers’ enrollment in the related programs; • Worker payroll records, including hours worked and pay received; and • Copies of previous contracts with contractors and suppliers, showing inclusion of provisions and terms reflecting ESS2. 167 The bidding document will screen out any bidder that uses child labor or involve historic child labor use. Per China’s Labor Law, the minimum working age is 16 years old. The contracts with selected contractors will include provisions related to labor and occupational health and safety, as set out in ESS2 and China’s regulations. The Company will manage and supervise the performance of contractors, with focus on their contract compliance, possibly including regular auditing, on-site inspection and/or record review. Contractors’ labor management records and reports may include: • A representative sample of employment contracts or arrangements between third parties and contracted workers; • Records relating to grievances received and their resolution; • Reports relating to safety inspections, including fatalities and incidents and implementation of corrective actions; • Records relating to incidents of non-compliance with national law; and • Records of training provided for contracted workers to explain labor and working conditions and OHS for the subproject. Contractor labor performance should be part of progress reports submitted to the Ningbo PMO. 11 Primary Supply Workers The Company will review primary suppliers to identify their labor force, and screen major risks and impacts, especially forced labor, child labor and serious safety problems. If a primary supplier has any major child labor or forced labor risk, or any serious safety problem, the Company should take the following measures: • Evaluating the magnitude of major risks related to primary supply workers, and designing appropriate mitigation measures in the SMP; • Following up with primary suppliers on quarterly basis for the implementation status of environmental measures (if any), thereby ensuring that labor management is well implemented, and reporting their labor performance to Ningbo PMO regularly as part of the implementation progress reports; • If it is impossible to take any remedy for any identified labor risk, the PIU will transfer primary suppliers to suppliers that can prove their compliance with ESS2 within a reasonable period. 168 Appendix 3 Conclusions and Suggestions of the Social Audit Report 1. Conclusions of Social Audit During this SIA process, a social audit was conducted for the 2nd batch subprojects and their associated facilities. Among Batch 2 subprojects, the existing facilities are the WWTP to be reconstructed, and two recyclable sorting centers (Jiangshan recyclable sorting center in Yinzhou District and Gulin recyclable sorting center in Haishu District). The existing facilities has no high social risk. WWTP: It will be reconstructed on the existing site, and its LAR risks are “low”. The company has entered into labor contracts with laborers, is free from child and forced labor, and has established an EHS department and an OHS system, including the construction and maintenance of occupational health protection facilities, PPE, occupational health monitoring and evaluation, publicity, worker health monitoring, etc. Based on the field survey and interviews, OHS risks are “low”. However, the company’s LMP has no specific requirement for contractor and primary supplier management. Recyclable sorting centers: Based on the currently selected sites, the land used has been acquired and reserved by the government, but the land use plan needs to be adjusted, and the PIU has not received a certificate of land use right, so land use risks are “moderate”; since all recyclables are from smart waste separation cabins deployed in communities, they are relatively clean. During waste sorting, worker occupational health risks are relatively minor, and the recyclable sorting centers have developed on-site operating regulations, and offer PPE for free to reduce occupational hazards. The PIU31 has established a sound LMP, but the social team found during the survey that some workers did not wear PPE (face masks, gloves, etc.) as required at work, and temporary workers might have not entered into a labor contract. Sound traffic risk control measures have been taken for vehicles, such as GPS speed monitoring, speed limit, voice prompt and anti-fatigue, and waste collection and transfer routes are kept away from densely populated communities. Therefore, traffic and community safety risks are “low”. Bulky and decoration waste disposal plant: It will be built on land acquired and reserved by the government, but it was found during the survey that some attachments on site were to be cleared, and the PIU had not received a certificate of land use right, so its LAR risks are “moderate”. For the associated facilities, a certificate of the right to use state-owned land has been obtained for the Haishu District landfill, Kaicheng Kitchen Waste Plant, and the Shouchuang Kitchen Waste Plant, so its LAR risks are “low”. The company has entered into labor contracts with laborers, is free from child and forced labor, and has established an EHS department and an OHS system, including the construction and maintenance of occupational health protection facilities, PPE, occupational health monitoring and evaluation, publicity, worker health monitoring, etc. 31 It is also a PIU of Batch 1 subprojects. 169 Based on the field survey and interviews, OHS risks are “low”. However, the company’s LMP has no specific requirement for contractor and primary supplier management. The Kaicheng Kitchen Waste Plant and Shouchuang Kitchen Waste Plant have developed strict waste collection and transfer management measures, and use fully sealed vehicles for transport via fixed routes, with minor community disturbances. In addition, it is found that adequate information disclosure and public participation were conducted for the existing and associated facilities of the Batch 2 subprojects during the EIA, social stability risk assessment, and LAR. However, compared to the Bank’s ESF, the existing and associated facilities of the Batch 2 subprojects need to be strengthened in community health and safety, communication, grievance redress, etc., such as disclosing E&S monitoring reports to the public regularly (especially water and air quality data), and responding to community concerns positively. 2. Issues and suggestions for correction Table 1 below summarizes the key issues identified in this social audit and the corresponding suggestions. In the future, the external social M&E agency appointed by Ningbo PMO will track M&E effectiveness continually, and report to the Bank regularly. 170 Table 1 Summary of issues identified in this social audit and suggestions for correction Applicable No. Concern Findings and issues Risk rating Suggestions Agency responsible Timing ESSs 1. WWTP of Ningbo resource recycling base Third party labor Improve the LMP to strengthen third Mingzhou and 1 ESS2 Labor management contract management is Moderate party labor management and Dec 31, 2022 Qingyuan unsound. monitoring. Environmental Disclose environmental monitoring At least monitoring shows that results to and strengthen Qingyuan semiannually (July wastewater and waste communication with nearby and January) gases meet the emission residents, and keep records. standards. Nearby Disclose annual environmental residents worry that reports to nearby communities Community health and odor produced by the ESS4 and timely, including basic corporate 2 safety, communication facility may affect their Moderate Qingyuan January ESS10 information, environmental mechanism health; residents may management, pollutants generated, express their concerns management and discharge, etc. through relevant channels, but there is no Establish a formal GRM, and offer relevant written record. sufficient resources (manpower and Qingyuan As per the SEP There are still some gaps finance) to ensure its proper from ESS10. operation. 2. Associated Facility 1 of WWTP — Haishu District landfill 171 Disclose environmental monitoring At least results to nearby residents timely, Qingyuan semiannually (July strengthen communication with There is no resident and January) them, and keep records properly. within 1km around the construction site. Disclose annual environmental However, nearby reports to nearby communities Community health and ESS4 and residents say that they timely, including basic corporate 1 safety, communication Moderate Qingyuan January ESS10 can still smell odor information, environmental mechanism sometimes, and have not management, pollutants generated, seen environmental management and discharge, etc. monitoring reports Establish a formal GRM, and offer timely. sufficient resources (manpower and Qingyuan As per the SEP finance) to ensure its proper operation. 3. Associated Facility 2 of WWTP — Kaicheng Kitchen Waste Plant There is no resident Disclose annual environmental within 1km around the reports to nearby communities At least construction site. timely, including basic corporate Community health and Kaicheng semiannually (July ESS4 and However, nearby information, environmental 1 safety, communication Moderate and January) ESS10 residents say that they management, pollutants generated, mechanism can still smell odor management and discharge, etc. sometimes, and have not Establish a formal GRM, and offer Kaicheng January seen environmental sufficient resources (manpower and 172 monitoring reports finance) to ensure its proper timely. operation. Establish a formal GRM, and offer sufficient resources (manpower and Kaicheng Operation stage finance) to ensure its proper operation. Improve the LMP to strengthen the management of primary suppliers Drivers may fail to Kaicheng July 2022 (drivers mainly), especially work observe the operating 2 ESS2 OHS Moderate safety and driving. regulations (e.g., over- Strengthen traffic safety training for speed). Kaicheng and district drivers, including traffic rules, speed At least quarterly sanitation offices and route requirements, etc. 4. Associated Facility 3 of WWTP — Shouchuang Kitchen Waste Plant There is no settlement Disclose environmental monitoring At least within 1km around the results to nearby residents timely, Shouchuang semiannually (July facility, but nearby strengthen communication with Community health and and January) ESS4 and residents can still smell them, and keep records properly. 1 safety, communication Moderate ESS10 odor sometimes; no mechanism Disclose annual environmental relevant environmental reports to nearby communities Shouchuang January monitoring report is timely, including basic corporate disclosed timely. information, environmental 173 management, pollutants generated, management and discharge, etc. Establish a formal GRM, and offer sufficient resources (manpower and Shouchuang Operation stage finance) to ensure its proper operation. Improve the LMP to strengthen the management of primary suppliers Drivers may fail to Shouchuang July 2022 (drivers mainly), especially work observe the operating 2 ESS2 OHS Moderate safety and driving. regulations (e.g., over- Strengthen traffic safety training for Shouchuang and speed). drivers, including traffic rules, speed district sanitation At least quarterly and route requirements, etc. offices 5. Bulky and decoration waste disposal plant Strengthen coordination with the Collective house village committee, and complete Ningbo PMO and 1 ESS5 Site clearing demolition and staff Low house demolition and staff Jun. 2022 Meijing resettlement resettlement 3 months before the beginning of construction. Notify the agency and staff Ningbo PMO and 2 ESS5 Site clearing Worker dormitory Low concerned to move 3 months before Jun. 2022 Meijing the beginning of construction. 174 Complete ownership negotiation with New CWI (Ningbo) Environmental Technology Co., Ltd. Abandoned workshop in coordination with the Haishu Ningbo PMO and 3 ESS5 Site clearing Low Dec. 2022 and equipment District Urban Administration Meijing Bureau, and complete equipment relocation by the end of December 2021. Strengthen communication and Once monthly until The PIU has not obtained coordination with the competent a certificate of the Ningbo PMO and 4 ESS5 Land approval the right to use state- Low authorities, and complete land right to use state- Meijing owned land. allocation or transfer before the owned land is beginning of construction. obtained 6. Recyclables sorting centers Some temporary workers Improve the management of 1 ESS2 Contract workers have not signed a labor Moderate contracted workers according to the Dabashou Upon recruitment contract. LMP. Some workers do not use Strengthen internal management to PPE as required during ensure that workers wear PPE Working days; at 2 ESS2 OHS Moderate Dabashou operation, which may properly, and train workers least quarterly lead to OHS risks. regularly. Community health and There is no formal Establish a formal community 3 ESS4 Moderate Dabashou As per the SEP safety community communication mechanism, 175 communication strengthen community mechanism. communication, and respond to community concerns timely. The selected sites, environmental sanitation Ningbo PMO, district Secure land, and complete land Site and planning facility plan, and land use urban 4 ESS5 Moderate adjustment in coordination with the October 2022 adjustment plan have not been administration competent authorities. approved by the bureaus, Dabashou government. Land for the sorting centers in Zhenhai and No right to use state- Jiangbei Districts The land will be leased for Acquisition of the owned land has been obtained by the construction for 30 years. The rental 5 ESS5 right to use state- obtained formally for the Moderate Dabashou end of 2022, and is about 50,000 yuan/mu. All land owned land 4 recyclables sorting that for those in use costs will be borne by the PIU. centers. Yinzhou and Haishu District to be obtained by the end of 2023 176 Appendix 4 Stakeholder Engagement Records Education on terminal waste disposal Education on terminal waste disposal for students for students FGD at NMII FGD at the WWTP FGD in Xuanpei Village FGD at the Dongqiao Town Government 177 Fieldwork at the resettlement site Seminar at the SIA agency FGD in Jiangbei District FGD in Yinzhou District Bank training Project survey plan seminar 178 Training of district heads Meeting registration form 179