BANGLADESH ENVIRONMENTAL SUSTAINABILITY AND TRANSFORMATION PROJECT (BEST) (P172817) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) People’s Republic of Bangladesh January 2022 People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 1. The People’s Republic of Bangladesh is planning to implement the Bangladesh Environmental Sustainability and Transformation Project (BEST) (the Project), with the involvement of the Ministry of Environment, Forest and Climate Change (MoEFCC), (Department of Environment (DoE)), and other Implementing Agencies (IAs) — Bangladesh Road Transport Authority (BRTA), Bangladesh Bank (BB) and Bangladesh Hi-Tech Park Authority (BHTPA). The International Development Association (Association) has agreed to provide financing for the Project. 2. The People's Republic of Bangladesh will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs) of the World Bank Environmental Social Framework (ESF). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, specific documents or plans, as well as their timing. 3. The People’s Republic of Bangladesh through the DoE, BRTA, BB and BHTPA will also comply with the provisions of all Environmental and Social (E&S) documents required under the World Bank ESF and referred to in this ESCP, such as Environmental and Social Management Framework (ESMF), Resettlement Policy Framework (RPF), Stakeholder Engagement Plan (SEP), Small Ethnic Community Development Planning Framework (SECDPF), Labor Management Procedures (LMP), Environmental and Social Impact Assessment (ESIA), Environmental and Social Management Plans (ESMP), Resettlement Action Plans (RAP), Small Ethnic Community Development Plans (SECDP), and Bank of Bangladesh Environmental and Social Management System (ESMS) the timelines specified in those E&S documents. 4. The People’s Republic of Bangladesh is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions are conducted by the Ministry, agency or unit referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Association by The People’s Republic of Bangladesh through DoE, BRTA, BB and BHTPA and consolidated by the Project Coordination and Monitoring Unit (PCMU) as required by the ESCP and the conditions of the legal agreement, and the Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Association and the People’s Republic of Bangladesh, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, the People’s Republic of Bangladesh will agree to the changes with the Association and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the Association and the People’s Republic of Bangladesh. The Implementing Agencies will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, Project performance result in changes to the risks and impacts during Project implementation, the People’s Republic of Bangladesh shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. BEST: Environmental and Social Commitment Plan (ESCP) 1|P a g e Ministry of Environment, Forest and Climate Change People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Every six�months during the Project MoEFCC/ Project Coordination and Monitoring Unit (PCMU) Prepare and submit to the Association regular monitoring reports on No later than 45 days after the last day of the environmental, social, health and safety (ESHS) performance of each period. PIUs of the 4 Implementing Agencies the Project, including but not limited to the implementation of the (DoE BRTA, BB and BHTPA) will provide ESCP and status of preparation and implementation of ES documents. reports to PCMU who would consolidate all reports in one and send to WB B INCIDENTS AND ACCIDENTS Initially notify the Association within 24 PCMU upon receipt of notification from hours of learning of the incident or IAs. Promptly notify the Association of any incident or accident related to accident. A detailed report will be the Project which has, or is likely to have, a significant adverse effect PIUs of the 4 Implementing Agencies provided within 96 hours including on the environment, the affected communities, the public or workers (DoE BRTA, BB and BHTPA) classification of incident. Carryout Root including accidents that could result in fatalities, injuries, and Cause Analysis (RCA) within 10 (ten) incidents of Gender Based Violence/Sexual Exploitation and Abuse/ calendar days of the incidence. Develop Sexual Harassment (GBV/SEA/SH), concerns of COVID-19 infections, Safeguard Corrective Action Plan (SCAP) serious mismanagement in handling waste, security breach, etc., and after approval from WB implement provide sufficient details regarding the incident or accident, the same. indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and supervising entity, as appropriate. Subsequently, as per the Bank’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. C CONTRACTORS MONTHLY REPORTS PIUs of the 4 Implementing Agencies Prepare and submit consolidated quarterly progress reports based on The first week of each quarter for the (DoE BRTA, BB and BHTPA) will provide the contractors’ monthly reports preceding quarter the reports after communicating with their respective contractors to PCMU to send one consolidated report to WB ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE BEST: Environmental and Social Commitment Plan (ESCP) 2|P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY Establish Project Implementation Units (PIUs), under each Recruitment process of the Specialists for PIUs of the 4 Implementing Agencies Implementing Agency (DoE, BB, BRTA and BHTPA). All four PIUs will PIUs will be completed within 2 months (DoE BRTA, BB and BHTPA) have their own Environmental Specialist, Social Development from Project effectiveness. PIUs will Specialist. The Social Specialists must have Gender and related designate own staff in the interim period experience. to administer and address ES issues. PMC, DSC, Operators of Municipal and E-Waste Facilities and Vehicle Contractors and operators of Vehicle Contractors and respective waste Inspection Centers (VICs) and other Contractors will recruit their own Inspection Centers (VICs), E-waste management facility and VICs operators Environmental, Health, and Safety Specialist (EHSS). management facility and Municipal waste (respective PIUs shall ensure) management entities will deploy required number of Environmental, Health, and Safety Specialist (EHSS) as stated in the contract within 1 months of the contract award by the respective PIUs. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT PCMU and PIUs Carry out subproject screening and thereafter site-specific ES ES screening at the identification of assessment (if deemed essential from screening results) and ES subproject and if warranted from Management Plan (ESMP) in accordance with applicable national screening results the ESIA/ES assessment legal framework, the World Bank ESF and ES standards reflected in of subprojects will be done prior to the project ESMF, to identify and assess environmental and social bidding and updated within 30 days of risks and impacts of project interventions including vulnerability to any change. access development benefits, risks of GBV/SEA/SH and appropriate mitigation measures. Before the carrying out of the relevant Prepare, disclose, adopt, and implement site-specific ESIA and ESMPs Project activities, and thereafter during (if warranted from screening results) required for the Project carrying out of such activities. activities based on the assessment process, in accordance with the ESSs, the ESMF, the EHSGs and relevant national and WHO Guidelines on COVID-19 response, in a manner acceptable to the Association. Update and redisclose ESMF on Environmental Fund (endowment) Within 30 days of finalization of activities Environment Fund (relevant GO issued) is done during project implementation. BEST: Environmental and Social Commitment Plan (ESCP) 3|P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY Update/prepare supplementary ESMF and re-disclose/disclose the Within 90 days from CERC activation updated/supplementary ESMF upon activation of the Contingent Emergency Response Component (CERC), including adding a positive list of eligible activities/ expenditures at the time of CERC activation, if new activities under CERC are not covered by existing ESMF. Technical Assistance: Ensure that the consultancies, studies, capacity Throughout the Project building, training, and any other technical assistance activities under the Project, including with respect to the proposed regulatory reforms under sub-component 1.1, are carried out in accordance with terms of reference acceptable to the Association, that incorporate the relevant requirements of the ESSs. 1.3 MANAGEMENT TOOLS AND INSTRUMENTS Screen any proposed subproject in accordance with the ESMF During detailed design and before bidding PIUs and Contractors prepared for the Project, and, thereafter, depending on the Screening process of the respective subproject. outcome, prepare, adopt, disclose and implement the subproject specific ESIA along with ESMP, with Waste Management Plan (including e-waste management), OHS Plan, Community Health and Safety Plan, Laboratory Safety Protocol and COVID-19 SOP as part of the ESMPs. 1.4 MANAGEMENT OF CONTRACTORS AND OPERATORS OF MUNICIPAL WASTE MANAGEMENT FACILITY, E-WASTE AND MUNICIPAL PIUs MANAGEMENT FACILITY VEHICLE INSPECTION CENTERS (VICs) Incorporate the relevant aspects of the ESCP, including the relevant During Bid document preparation and ES documents and/or plans, and the LMP, into the Environmental, Prior to invitation of bid of the respective Social, Health and Safety (ESHS) specifications of the respective subproject. procurement documents. Bidding documents and works contracts will include relevant measures for labor management, workers Codes of Conduct (CoC) to ensure gender inclusion and management of risk of GBV/SEA/SH, incorporate relevant national and WHO Guidelines on COVID-19 response and other communicable diseases risks with BEST: Environmental and Social Commitment Plan (ESCP) 4|P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY respect to workers and surrounding communities, OHS issues and incidence management and reporting particulars. Prior to commencement of civil Contractor, Operators of facilities and Preparation of Contractors and facility operators-ESMP (including a works and operation of waste VICs and respective PIU Labor Management Plan with OHS, Safety Management Plan, management and VIC facilities Emergency Protocols, Facility Operation SOP, Traffic Management Plan, Waste Management Plan, as appropriate) and other plans as described in 1.3 relevant for contractors. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES: Implement Project in Will be implemented throughout Project PIUs accordance with the applicable requirements of ESS2, in a manner implementation. acceptable to the Association, including through, inter alia, implementing adequate OHS measures (including COVID-19 response measures), provision of training on handling emergency situation especially health related issues and accidents, provision of Code of Conduct signing and GBV/SEA/SH training by all workers; and setting out grievance arrangements for project workers, and incorporating labor requirements in the procurement documents and contracts with contractors and consultants. Ensure that child labor (any person under the age of 18), forced labor and trafficked persons are not employed under works contracts. Prepare and implement the Labor Management Procedures (LMP) Prior the Project appraisal and including the labor related GRM implemented throughout project implementation 2.2 GRIEVANCE REDRESS MECHANISM FOR PROJECT WORKERS GRM for the workers will be established PIUs and Contractors for every works package before Establish, maintain, and operate a Grievance Redress Mechanism commencement of civil works and it will (GRM) for Project workers, as described in the LMP and consistent remain operational throughout works with ESS2. The GRM should also be designed to address labor related contract implementation. GBV/SEA/SH issues including provision of a referral system. Other BEST: Environmental and Social Commitment Plan (ESCP) 5|P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY than GRM at works site, responsive system will be in place at the PCMU and all PIUs. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Before commencement of civil works and PIUs, Contractors, Operators of remain operational throughout works Municipal and e-waste facilities and VICs Prepare, adopt, and implement occupational, health and safety (OHS) contract implementation and during measures including health protocol in response to the COVID-19 and operations of completed facilities. other communicable diseases as specified in the LMP and ESMP. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND The site specific ESMPs and Waste PIUs MANAGEMENT: Carryout screening of subproject and depending Management Plans to address the issues upon screening results develop and implement site specific ESIAs of resource efficiency and pollution along with the ESMPs and specific Waste Management Plan that will prevention respectively to be developed include resource efficiency guidelines, pollution prevention measures as soon as project specific locations are and take initiative to reduce, reuse or recycle waste material to the known and before commencement of extent possible. Wastes generated in the sanitary systems and e- civil works and remain operational wastes management center to be disposed in a manner that does not throughout works contract harm the environment and human health and in an environmentally implementation. safe manner. For any infrastructure repair/rehab/construction works, the energy/water efficiency measures detailed in ESS 3 will be taken DoE/PIU into consideration in the ESMPs. Standard Operation Protocol (SOP) will be prepared for the operation SOP/Lab Safety Protocol will be prepared of the proposed Laboratories by DoE. before operation of the Laboratories. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Adopt and implement measures and Before commencement of civil works and PIUs and Contractors. actions to assess and manage traffic and road safety risks as required remain operational throughout works in the ESMPs to be developed under action 1.3 above. Contractors will contract implementation. develop Traffic Management Plans, and this will be binding in Contract document. BEST: Environmental and Social Commitment Plan (ESCP) 6|P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 4.2 COMMUNITY HEALTH AND SAFETY: Prepare, adopt, and implement Throughout Project implementation PIUs measures and actions to assess and manage specific risks and impacts (including all required updates to the to the community arising from subproject activities, including, inter documents). alia, workers behavior, risks of labor influx, risks of GBV/SEA/SH incidents, emergency situations, infectious diseases including COVID- 19, incidence due to use of services and include these measures in the ESMPs to be prepared in accordance with the ESMF, and national and WHO guidelines of social distancing and other measures in a manner acceptable to the Association. Though GBV/SEA/SH risk is Low, the risk will be mitigated through PIU sensitization, awareness raising of communities, mapping of GBV/SEA/SH service provider, worker training and signing of Code of Conduct and establishment of GRM designed to address GBV/SEA/SH issues. Response measures are included in the SEP along with a Grievance Redress Mechanism (GRM) under SEP as well as a labor related GRM under LMP. Project GRM will also manage the risks of GBV/SEA/SH and those related to small ethnic communities. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT RPF prepared and disclosed Appraisal and 5.1 Prepare, disclose and implement Resettlement Policy Framework PIUs (RPF). will be implemented throughout project implementation Prepare, disclose and implement Resettlement Action Plan (RAP) or RAP/A-RAP will be prepared prior to the Abbreviated Resettlement Action Plan (ARAP) for each activity where commencement of any works for land land acquisition will be required, and/or displacement of informal acquisition and/or where physical and settlers will occur and/or physical and economic displacement will economic displacement will occur and/or take place (the ARAPs can be in the form of a specific section of the informal settlers will be impacted. relevant ESMPs rather than free-standing documents if impact is minimal) BEST: Environmental and Social Commitment Plan (ESCP) 7|P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: Not Relevant. The project is not likely to affect any biodiversity, NA habitat or living natural resources given locations of subprojects in industrial built-up areas and urban and peri-urban areas. Subprojects with significant adverse impacts on biodiversity will be excluded from project financing. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES SMALL ETHNIC COMMUNITY DEVELOPMENT PLAN: Prior to Project appraisal and 7.1 PIUs implemented throughout project Prepare, disclose and Implement Small Ethnic Community implementation Development Planning Framework (SECDPF) Prepare, disclose and Implement Small Ethnic Community Prior to start of activity that has potential Development Plan (SECDP) by carrying out due diligence for inclusion impacts (positive and negative) on the of the targeted beneficiaries for each subproject/activity, where small ethnic communities and as per the needed. The Project will exclude any activities that will require Free, guidance of SECDPF Prior, Informed Consent (FPIC) from the SECs. ESS 8: CULTURAL HERITAGE. 8.1 CHANCE FINDS PROCEDURE: During preparation of bid documents and PIUs prior to the commencement of civil works Prepare and implement chance finds procedure described in the ESMF and include as a requirement in ESIA/ESMP and also in the bid documents for civil works ESS 9: FINANCIAL INTERMEDIARIES BEST: Environmental and Social Commitment Plan (ESCP) 8|P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY Conduct due diligence review of Bangladesh Bank’s Environmental and Prior the Project appraisal and maintained 9.1 PCMU and PIU of BB Social Management System (ESMS), a system for identifying, throughout project implementation assessing, managing, and monitoring the environmental and social risks and impacts of FI subprojects on an ongoing basis and provide recommendations to develop gap filling measures to address risks and impacts for interventions undertaken by BB and other FIs. The following recommendations are made to fill the gap of BB ESRM: Bangladesh Bank will update and disclose BB and PFIs • The ES policy should be periodically updated, endorsed by updated ESMS before carrying out of the the BB’s senior management that will reflect lessons learnt relevant Sub-Project activities. The from project interventions in the field specifics of ESMS will be maintained • Set up a permanent ES unit with Environmental and Social throughout project implementation. Experts under its organogram • The consideration for a Training Policy, assessment of competence and training modules development. • Development of OHS measure as per Good International Industry Practices (GIIP) • Procedure for assessment and identification of various stakeholders (including disadvantaged and vulnerable) • Communication procedure with various stakeholders including meaningful consultation (keeping in mind differentiated measures for the disadvantaged), and consideration for their input for project design (completion of feedback loop) • Designation of a representative of the senior management to have overall accountability for environmental and social performance of the subprojects Implementation of the strengthened ESMS by the BB and PFIs as per recommendations above BEST: Environmental and Social Commitment Plan (ESCP) 9|P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND The project SEP will be developed and PCMU and all PIUs IMPLEMENTATION disclosed before appraisal. Develop, implement and monitor the Stakeholder Engagement Plan (SEP), including project level GRM. The SEP may be amended anytime during implementation in agreement with the Association and it will be updated and redisclosed to address periodically to address recent and upcoming issues necessitating consultation with the stakeholder and closing the feedback loop. 10.2 PROJECT GRIEVANCE REDRESS MECHANISM (GRM) Within 2 months of project effectiveness PCMU and all PIUs and updated from time to time as needed Prepare, adopt, maintain, and operate a GRM, as described in the and maintained throughout project SEP, which should be able to address GBV/SEA/SH related complaints implementation. and small ethnic community grievances. BEST: Environmental and Social Commitment Plan (ESCP) 10 | P a g e People’s Republic of Bangladesh Bangladesh Environmental Sustainability and Transformation Project (BEST) CAPACITY SUPPORT (TRAINING) All staff of the PCMU and PIUs, Contractors and Operators of facilities and VICs will be given capacity building training and orientation on environmental, social, health and safety (ESHS) management following the national legal and policy requirements, international treaties, WHO guidelines and the World Bank ESF, with support of PIU E&S specialists. PIUs will design and implement training for targeted groups involved in the project to improve their awareness of risks and mitigate the impacts. This ESCP proposes a preliminary training plan that can be adapted to meet needs during Project implementation according to the approved training plan and budget by the Association. Based on E&S Capacity Assessment (under ESMF) following types of PIUs E&S Specialists, M&E Specialist training will be provided to the relevant target groups, such as PIU Training of PCMU and PIU staffs to be staff, stakeholder community, project workers, consultants, completed within 6 months of contractors and sub-contractors, operators of e-waste and municipal Effectiveness and thereafter yearly once. waste management facilities and VICs: 1. Introduction to World Bank ESF guidelines and ESMF 2. Screening and preparation of ESIA under ESMF 3. Preparation of RAP and SECDP Staffs at PFIs of BB, Contractors, 4. Labor and working conditions Operators of facilities and VICs will be 5. GBV and SEA/SH risk in the project and its implementation, trained within two months of Contract need to understand and sign Code of Conduct signing. PIUs will select training modules 6. Occupational Health & Safety from the list of previous columns as 7. Community health and safety appropriate. 8. Stakeholder Engagement 9. Environmental compliance monitoring and audit 10. Issues related to COVID-19: use of PPE; working in COVID-19 environment; WHO, CDC and national guidelines on quarantine; compliance with local rules and regulations. 11. ESMS implementation by BB and PFIs 12. Efficient use of resources and prevention of pollution 13. Emergency procedure and response 14. SOPs of VIC, waste management and laboratory facilities including ES issues management BEST: Environmental and Social Commitment Plan (ESCP) 11 | P a g e