Recovering Learning Losses from COVID-19 Pandemic in Brazil Program Environmental and Social System Assessment Component 1 March 3th, 2022 1 Table of Contents Executive Summary .............................................................................................................................................. 3 Introduction and Methodology ........................................................................................................................... 4 1. Program Description .................................................................................................................................... 5 1.1. Program Objective ........................................................................................................................ 5 1.2. Components .................................................................................................................................. 5 1.3. Thematic Scope ........................................................................................................................... 13 School Dropout ........................................................................................................................................... 13 Learning Achievements and Performance .................................................................................................. 14 Learning Inequalities among Students of the Same Schools ...................................................................... 14 Connectivity and Pedagogical Use of Digital Technologies ........................................................................ 14 1.4. Geographic Scope........................................................................................................................ 15 1.5. Institutional Arrangement .......................................................................................................... 17 1.6. Previous Experience of the Implementing Agencies with the Program or Similar Activities ...... 18 2. Description of Expected Environmental and Social Effects of the Program ............................................ 18 2.1. Likely Environmental and Social Effects ...................................................................................... 18 2.2. Contextual Risk Factors ............................................................................................................... 21 2.3. Institutional Capacity and Complexity Risks ............................................................................... 25 2.4. Reputational and Political Risks .................................................................................................. 29 3. Assessment of the Borrower’s Environmental and Social Management System .................................... 31 Core Principle 1 ....................................................................................................................................... 31 Core Principle 2 ....................................................................................................................................... 32 Core Principle 3 ....................................................................................................................................... 33 Regulatory Framework ............................................................................................................................... 34 Enforcement Capacity................................................................................................................................. 37 Core Principle 4 ....................................................................................................................................... 37 Core Principle 5 ....................................................................................................................................... 40 Indigenous Peoples ..................................................................................................................................... 41 Countryside and Quilombola School Education ......................................................................................... 47 Measures to Promote Equitable Access to The Benefits of The Program .................................................. 49 Core Principle 6 ....................................................................................................................................... 50 4. Stakeholder Consultations ......................................................................................................................... 51 5. Overall Findings of The ESSA...................................................................................................................... 52 Overall Findings on Environmental and Social Risks of the Program...................................................... 52 2 On the Adequacy of the Environmental and Social Management System ............................................. 53 6. Action Plan.................................................................................................................................................. 55 Executive Summary The Recovering Learning Losses from COVID-19 Pandemic in Brazil Program is a hybrid Program that comprises a Program for Results (PforR) and an Investment Project Financing (IPF) components and has been proposed by the Brazilian Ministry of Education (MEC). This assessment is required the World Bank Policy: Program-for-Results Financing (Policy), the Bank Directive: Program-for-Results Financing (Directive), and Bank Guidance Program-for-Results Financing Environmental and Social Systems Assessment and addresses the Environmental and Social Risks and Management System available for the PforR component. Assessing the environmental and social risks, the assessment considers the likely environmental and social effects, the context-risk factors, the institutional capacity and complexity risks and the political and reputational risks. Assessing the Environmental and Social Management System, it considers six core principles related with (i) the environmental and social sustainability of the Program design, (ii) the adequate management of adverse impacts on natural habitats and cultural resources, (iii) the protection of public and worker safety, (iv) manage land acquisition and loss of access to natural resources in a way that avoids or minimizes displacement and assists affected people in improving, or at the minimum restoring, their livelihoods and living standards, (v) the due consideration to the cultural appropriateness of, and equitable access to, Program benefits by vulnerable social groups (including Indigenous Peoples) and (vi) the avoidance of social conflict exacerbation. The assessment of environmental and social risks concluded there was no unacceptable adverse risks, the likely effects in the environment would be negligible and the ones in society would mostly be positive and socially inclusive. Reputational and political risks would be low as the supported activities are linked and positively contribute to the goals of the National Education Plan (PNE) and the specific Programs supported have been widely known and supported by key stakeholders. There is a context-risk factor that needs some attention as it may hamper the achievement of the Program’s objective and, particularly, its potential to promote social inclusion – namely, the “digital divide�. And there is an institutional complexity risk – the varied capacity of the municipalities in the North and Northeast region – that is also an obstacle to be reverted. The Programs supported under the PforR component and some technical assistance activities financed under the IPF component embed actions to deal with these risks. The assessment considering the environmental and social risk management system (regulatory framework, institutional capacity and track record) concluded there is adequate capacity to deal with the negligible to moderate level of the risks posed by the Program. An action plan to enhance the capacity of the Borrower to deal mostly with risks related with the potential social exclusion of some culturally distinct and socially vulnerable social groups due to the digital divide and the potential risks caused by the poor institutional capacity of some municipalities in the North and Northeast region on the ability to provide equitable access to Program benefits has been agreed upon. 3 Introduction and Methodology A hybrid Program comprising a Program for Results and an Investment Project Financing (IPF) components has been proposed by the Brazilian Ministry of Education (MEC). The proposed Program will institutionalize the federal government’s financial and technical efforts to systematically help subnational Secretariats of Education to recover from COVID-19 impacts. Its activities concentrate on the students most affected by the pandemic by targeting: (i) Underprivileged students, by prioritizing schools with at least 70 percent of students receiving Conditional Cash Transfers in some of its policies; and (ii) The most vulnerable regions, as only municipalities and states located in the North and Northeast Brazil are part of the Program. Additionally, and in alignment with the national policy, the Program will focus on two main pillars: (i) Recovery, which includes activities to mitigate school dropouts and learning losses related to the pandemic; and (ii) Resilience and Capacity Building, which prepares local governments to respond to the pandemic, or upcoming natural disasters, by providing effective management tools and better capacity to implement federal programs. Following the World Bank Policy: Program-for-Results Financing (Policy), the Bank Directive: Program-for- Results Financing (Directive), and Bank Guidance Program-for-Results Financing Environmental and Social Systems Assessment, the Task Team carried out an initial screening of environmental and social risks of the activities included in the Results Areas that will be supported by the PforR Program. This assessment has four objectives:1 • To ensure that the Program is designed in a manner that maximizes potential environmental and social benefits, while avoiding, minimizing, or otherwise mitigating environmental or social harm. • To identify whether any proposed activity supported by the Program falls under the exclusionary principle of the Policy and should be excluded because of their inherently high risk; • To determine whether the potential Environmental and social (E&S) effects (which may not meet the Policy’s criteria for exclusion) of the Program lead to unacceptable adverse risks associated with one or more of the four risk criteria defined by the PforR Policy – namely: (a) the likely environmental and social effects, (b) the context risk factors; (c) the institutional capacity and complexity risks, and (d) the political and reputational risks; and, • To assess the Environmental and Social Management System of the Borrower according to six core principles defined by the PforR Policy – namely: o Core Principle #1: Program E&S management systems are designed to (a) promote E&S sustainability in the Program design; (b) avoid, minimize, or mitigate adverse impacts; and (c) promote informed decision-making relating to a Program’s E&S effects; o Core Principle #2: Program E&S management systems are designed to avoid, minimize, or mitigate adverse impacts on natural habitats and physical cultural resources resulting from the Program. Program activities that involve the significant conversion or 1Environmental and social risk management of activities proposed for the IPF Technical Assistance Component will follow the principles and requirements of the World Bank’s Environmental and Social Framework and Environmental and Social Standards. 4 degradation of critical natural habitats or critical physical cultural heritage are not eligible for PforR financing; o Core Principle #3: Program E&S management systems are designed to protect public and worker safety against the potential risks associated with (a) the construction and/or operation of facilities or other operational practices under the Program; (b) exposure to toxic chemicals, hazardous wastes, and otherwise dangerous materials under the Program; and (c) reconstruction or rehabilitation of infrastructure located in areas prone to natural hazards; o Core Principle #4: Program E&S systems manage land acquisition and loss of access to natural resources in a way that avoids or minimizes displacement and assists affected people in improving, or at the minimum restoring, their livelihoods and living standards; o Core Principle #5: Program E&S systems give due consideration to the cultural appropriateness of, and equitable access to, Program benefits, giving special attention to the rights and interests of Indigenous Peoples, and to the needs or concerns of vulnerable groups; and, o Core Principle #6: Program E&S systems avoid exacerbating social conflict, especially in fragile states, post-conflict areas, or areas subject to territorial disputes. • To identify potential risks and opportunities that may be associated with the proposed Program that warrant further analysis through the Environmental and Social Systems Assessment. 1. Program Description 1.1. Program Objective The Program Development Objective (PDO) is to support state and municipal governments in the North and Northeast regions of Brazil to: (i) recover from school dropouts and learning losses related to the COVID-19 pandemic, and (ii) strengthen local resilience in primary and lower secondary schools. This Program will finance 50.6 percent of the estimated government expenditures on the programs implemented by the Ministry of Education’s (MEC) national COVID-19 response on education. It concentrates its support in the North and Northeast regions, which are estimated at US$493.61 million over five years. MEC’s financial support is carried out through transfers to local education secretariats and schools via National Fund for Education Development (Fundo Nacional de Desenvolvimento da Educação, FNDE)2 and endorsed and monitored by SEB. 1.2. Components The Program comprises two components: Component 1 is a PforR financing for US$215 million, whereas Component 2 is an IPF in the amount of US$35 million to develop technical assistance to strengthen the Program’s implementation and the World Bank will finance 100 percent. Component 1 (PforR, US$215M): Recovery aims to recover from increased school dropouts and learning losses caused by the COVID-19 pandemic in Brazil. The focus is on recovery and accelerating strategies in primary and lower secondary schools located in the North and Northeast Brazil. Additionally, with the emphasis on recovering education losses, the policies under Component 1 also promote the acceleration 2 FNDE is responsible for executing most actions and programs in Basic Education in Brazil. From school meals to school transportation, FNDE manages the financial aspects of Ministry of Education programs. 5 of learning by implementing a structure to mitigate school dropout and flexible learning programs concentrated on schools with the most vulnerable students. The component proposes to tackle the challenges of decentralized implementation, typical to federative countries like Brazil, by transitioning from an uncoordinated myriad of programs, where states and municipalities have distinct implementation capacities, to a national and tailored approach. This component supports activities in three results areas. They are: Results Area 1: Recovery from School Dropouts. The first step after schools reopen in the aftermath of the Covid-19 outbreak is to ensure that students return to school and remain enrolled. The Results Area 1 supports three activities: Activity 1: National and States Observatories of School Dropouts (OSD). This activity supports the regulation and implementation of a National and 14 State Observatories of School Dropout in the North and Northeast Brazil (out of 16 states in the region) to coordinate the implementation of three anti-dropout policies: (i) the Student Active Search Program, which uses a centralized platform and a cellphone app to guide community agents in the active search for students that did not (re)enroll in public schools;3 if missing students could not be found by the Student Active Search agents, (ii) the School Dropout Call Center (Disque 100 Brasil Na Escola) will be an option for community members to notify authorities about out-of-school children using a hotline; and finally, Early warning systems. Activity 2: Early Warning System (Sistema de Alerta Preventivo, SAP). Given that vulnerable students are still at risk of dropping out once they are back to school, the Early Warning System (EWS) aims to make schools proactively identify students at high risk of dropping out and offer personalized intervention while they are still in school. In essence, it is a hotline for community notification of out-of-school children and aims the development and expansion of activities focused on strengthening monitoring of timely and relevant data to prevent students leaving schools prematurely. It follows four steps: (i) a Dropout Risk Questionnaire (Yes/No questions) applied to students; (ii) a Dropout triggering factors (e.g., teenage pregnancy, sexual violence, and bullying) applied to school coordinators, (iii) “Escuta Ativa� as a qualitative interview with students at high risk; and (iv) personalized interventions based on the mappings. The PBE offers the questionnaires, training and structure to schools implement the EWS three times a year. Activity 3: Education and Family Program (Educação e Família). The aim of Education and Family program is to integrate families and schools on tasks focused on reducing dropout rates at schools, by reversing and preventing school dropout, especially for vulnerable groups. The program elaborates a school-community engagement program to increase awareness in students and their families about the importance of education and having a life-project. A set of issues related to gender, inclusion and climate change will be addressed under this Results Area. Considering that the underlying reasons to dropout from school vary according to sex, economic status and climate events, the Program will strengthen the local capacity to deal with these circumstances. First, the National Observatory of School Dropouts will have a specialist on school dropout focused on gender and inclusion. A second activity develops protocols to guide community agents approaching households, families, or students that dropped out because of gender-based violence and teenage pregnancy. The 3 The Active Search Program is implemented at municipal level by UNDIME and UNICEF. In the context of this program, there is no transfer of resources to this program. 6 third activity relates to the first questionnaire of SAP mapping the influence of “floods, droughts and landslides on not coming to schools� and the second questionnaire which identifies causalities relates to household chores, gender-based violence and risk of teenage pregnancy.4 Results Area 2: Recovering from Learning Losses – Offline. Once students return to schools, recovering the learning losses caused by the pandemic is of utmost priority. The Results area 2 supports two federal policies aiming at recovering learning losses at schools. Activity 1: Personalized Tutoring (Acompanhamento Personalizado da Aprendizagem, APA). This activity is an approach that adapts teacher instruction levels by reorganizing students in small groups with similar learning difficulties and providing tutoring classes in mathematics and Portuguese for two weeks. It starts by mapping students learning (“Mapa de Aprendizagens�) and offers to tutors structured materials designed to support them during the classes for each group of students. The PBE has a timeline of implementing APA four times per year. This policy is the main learning recovery strategy implemented by the Government of Brazil that is currently being expanded to primary schools in the North and Northeast Brazil. Activity 2: Socioemotional Initiative (Semeando Inteligências Socioemocionais, SIS). This program focuses on promoting structured groups of discussion based on the Cognitive Behavioral Therapy (CBT). The aim is to rebuild socioemotional skills of students after the pandemic and incentivize students to learn well. This activity is built around five socioemotional skills included in BNCC and provides structured activities for each discussion group and training to local monitors to implement the strategy. The APA and SIS are complementary policies on recovery and acceleration of learning. APA is particularly focused on rebuilding foundational skills in mathematics and Portuguese (i.e., students with proficiency below level 3 in the SAEB scale, see Annex 15).5 SIS takes the advantage that five socioemotional skills are already in the BNCC (self-management, self-awareness, social awareness, decision making and sociability) to incentivize its inclusion at school daily activities as a key COVID-19 response action. These activities under the Results Area 2 will be reinforced by developing training courses to support APA tutors to teach the foundation skills and SIS monitors on how to structure the group discussions. These strategies are called “offline� because they require students to be physically in school. Results Area 3: Recovering from Learning Losses – Online. Learning losses can also be recovered through “online� or hybrid activities (combining online and face-to-face learning). The Results area 3 aims to support the national program in three activities related to connectivity and hybrid learning. Activity 1: Internet Connectivity at Schools. The first step to implement hybrid learning models is to ensure that schools have adequate connectivity. The Program supports the Connected Education Innovation Program (Programa Inovação Educação Conectada, PIEC) on expanding internet coverage in schools, which is meant to help teachers enhancing students’ learning experience through pedagogical approaches supported by technology. This program transfers 4To track the progress of these activities on reducing gender gaps in dropout rates, three Intermediary Results Indicators are proposed (see Annex 2): (i) Hiring the gender specialist to the National Observatory of School Dropouts, (ii) The number of notifications in Disque 100 Brasil na Escola in the North and Northeast per sex; and (iii) the number of school dropout protocols available to schools in the North and Northeast Brazil. 5 The Acompanhamento Personalizado das Aprendizagens (APA) regroups students not presenting adequate performance for their grade. It groups students based on SAEB levels from 0 to 3 (See Figure 3). 7 resources and provides technical supports to primary and lower secondary schools across Brazil to deploy or expand internet connectivity. Activity 2: Access to computing devices. As a complement to activity 1, students also need to be able to access the internet for learning when they are not at school and undertake learning activities at home. This operation finances the activity 2 by supporting the implementation of the legislation 14.172 from 2021 allocating R$3.5 billion to the Ministry of Education purchase computing devices (Tablets, SIM cards and Computers) for students and teachers. These purchases are decentralized to states and have to be implemented within 6 months. The beneficiaries are students from vulnerable families (registered in CadÚnico) and students from indigenous and quilombos schools.6 Activity 3: Innovation Lab (LabCrie). The Program will support the expansion of Innovation Labs (LabCrie) to municipalities in the North and Northeast Brazil. The aim of LabCries is to offer and certify teachers and school principals training courses on the use of technology for learning. Component 2 will support the development of a set of courses (hybrid, face-to-face, or online) for teachers and school principals in three main areas: i) Effective pedagogical practices to rebuild foundational learning; ii) Cultural diversity and inclusion; iii) how to empower girls in STEM (science, technology, engineering, and math) careers. One example of the training course is a high-quality teacher professional development (TPD) program, inspired by the WGB's COACH initiative, to recover and accelerate learning. The course will cover a set of Foundational Teaching Skills that teachers can leverage in the classroom, providing clear step-by-step guidance on implementing them effectively. As schools reopen, teachers face the challenge of rapidly assessing students' knowledge to identify learning gaps and adapt their teaching to the level of students. Activity 4. Education Solution Ecosystems. The Education Solution Ecosystem seeks to incorporate, in an open environment, possible solutions and initiatives involving information technology to support education systems at their different levels of maturity. This initiative seeks to consolidate, in a single platform, the various EdTech solutions available in the market properly vetted and curated, while maintaining the autonomy of states and municipalities to choose. Among the main benefits stand out the development of a private market with consolidated and innovative solutions in a controlled environment to accelerate the process of development and diffusion of EdTech solutions in Brazil. By emphasizing foundational cognitive and socioemotional skills, as well as the use of Education Technology, the Result Areas 1, 2 and 3 under Component 1 go beyond than recovering learning losses. They will contribute to accelerate learning after the pandemic and to building more resilience by preparing the education system to deal with similar circumstances where either students or teachers are unable to attend classes. Not only students will be able to join school classes remotely, but also teachers will be able to deliver lessons remotely to schools. The different learning solutions envisioned, such as the Adaptive Learning platforms, will further enhance these capabilities by allowing students to learn 6 http://www.planalto.gov.br/ccivil_03/_ato2019- 2022/2021/Lei/L14172.htm#:~:text=LEI%20N%C2%BA%2014.172%2C%20DE%2010%20DE%20JUNHO%20DE%202 021&text=Disp%C3%B5e%20sobre%20a%20garantia%20de,do%20par%C3%A1grafo%205%C2%BA%20do%20art. 8 anytime, anywhere, at their own pace and follow a uniquely crafted learning path adapted to their knowledge. Component 2 (IPF, US$35M): Resilience and Capacity Building. The COVID-19 pandemic exposed the urgent need to incorporate risk reduction strategies into educational planning for resilient systems. This component will strengthen the resilience and capacity of states, municipalities and school networks to design policy responses, implement federal policies, and counterbalance the impacts of the ongoing and upcoming crises. The proposed TA activities will be focused on three areas: i. Subcomponent 2.1: Capacity Building. This sub-component supports the implementation capacity of activities under Component 1 as: State Observatories of School Drop Outs, designing training for school staff, updating platforms and apps, developing school dropout protocols, development of structured materials, decentralized technical teams to work with municipalities on the management of PDDE and PAR4 programs.7; undertake viability studies, and training local staff to implement projects. ii. Subcomponent 2.1: Education Solution Ecosystems and the Integrated Education Management System. The first activity under this subcomponent is the implementation of an Integrated Education Management System which aims at incorporating MEC’s current systems in a single platform, reducing inefficiencies and costs with maintenance and training. The integration will promote the systems’ interoperability, increasing access to timely information and a more comprehensive management process for the current and future crisis, especially for vulnerable groups. The second activity in the Program will be supported by the development, and provision, of digital solutions in education, including: a. Adaptive Learning Platforms in Portuguese and Mathematics. Adaptive learning platforms to be used by schools in the classroom to personalize pedagogical activities. b. Student Enrollment System (SES). This system is going to be developed to digitalize and simplify school (re)enrollment processes at the local level and, as a consequence, optimize the formation of classes. c. Teacher Assignment System (TAS). This system automates and digitizes teacher assignment in the school network. d. School Attendance System (SAS). The SAS will digitize the registration of student attendance and automate control of teacher absenteeism. e. School-Meal Management System (SMMS). The SMMS will generate reliable data on the daily consumption and automated verification of food expenditures. f. School-Transport Management System (STMS). Municipalities manage multiple contracts for school transportation to contract and operate the transport of municipal and state students. iii. Subcomponent 2.3: Knowledge and Communication. This subcomponent will support consultancies and studies that augment the quality of COVID-19 programs undertaken by the 7 The Plano de Ações Articuladas (PAR) is multi-annual and multidimensional strategic plan that aligns the efforts and actions of the Ministry of Education, State and Municipal Departments into a list of objectives. 9 Ministry of Education. On Results Area 1, these activities will include: the development of protocols to guide local teams approaching households, families, or students that dropped out because of gender-based violence and teenage pregnancy, development of two questionnaires: one for students to identify issues highly correlated to the risk of dropping out, and a second for school coordinators and includes questions about gender-based violence and risk of teenage pregnancy, a longitudinal study on the reasons for dropping out, a menu of school policies to reduce school dropouts, and training. On Results Area 2, they will include: structured materials for personalized teaching and training for monitors and teachers. On Results Area 3, they will include: a market study on structure and connectivity, mapping the market solutions in education, generating interoperability in the systems of the Ministry of Education, ensuring data privacy, development of material for courses on effective pedagogical practices, cultural and linguistic diversity and empower girls in STEM career sustainable for LABCRIE and inclusive creche models, and promoting communication campaigns to facilitate implementation. Implementation support. In addition, the IPF component will support Program Management Unit (PMU) operational costs, basic equipment, and consumables; implementation of the Governance Risk Assessment System to identify possible fraud in public expenditures and the Spend Analysis System for strategic procurement; capacity building including on internal controls and verification of DLIs; environmental and social (E&S) risk data (such as implementation of the IPF Environmental and Social Commitment Plan and the PforR Environmental and Social Action Plan); and minor studies for participating agencies in line with emerging needs. The current assessment of the Environmental and Social Management System of the Borrower refers exclusively to Component 1, which is financed under the Program for Results modality. Box 1 – Governmental Programs Supported by the Program The Government of Brazil (GoB) is working on a national program to mitigate the impacts of COVID-19 pandemic in education. The highest priority for the Ministry of Education of Brazil during the coming years is to recover from the education losses generated by the COVID-19 pandemic. For this reason, the COVID-19 response program was formulated to establish a benchmark for recovering from learning losses and strengthening local resilience to overcome ongoing and upcoming barriers to improve education in Brazil. Its objectives are to: (i) promote equity by supporting the most vulnerable schools; (ii) reduce the proportion of students with low learning levels in SAEB; (iii) reduce dropout rates in primary and lower secondary education; (iv) strengthen the capacity of school networks to be resilient in terms of responding to new challenges; and (v) increase the efficacy of education spending. The Program is a comprehensive strategy to address the challenges inflicted by COVID-19 pandemic on education. The program is structured to combat the expected increase in school dropout rates, to promote recovery and acceleration of learning, and preparing the local school networks to deal with future crises. Using this rationale, the GoB deliberated over the mitigation of COVID-19 impacts on learning and generating the structure for overcoming an already high pre-pandemic hurdle. The Program combines different programs and activities. They include: 10 a) The Programa Brasil na Escola (PBE)8 is a national strategy to mitigate learning losses and school dropout rates caused by the COVID-19 pandemic. PBE is under the responsibility of the Secretary of Basic Education (SEB) at the Ministry of Education (MEC) and its objective is “ to induce strategies and innovations to ensure learning and school progression with equity and at the appropriate age in lower secondary schools.�9 PBE concentrates on the most vulnerable schools in Brazil. PBE focuses on schools fulfilling one of two criteria: (i) at least 70% of students receive conditional cash transfers and (ii) have an IDEB (the national learning indicator) lower than 3.5. These two rules illustrate the primary focus to have an impact on students with the most socially and economically vulnerable background. Despite PBE does not have a geographic focus per se, its criteria prioritizing schools attending a majority of students receiving conditional cash transfers, or with lower learning performance, tend to concentrate the program on the North and Northeast Brazil. PBE is organized around three pillars: (i) Technical Support to Schools for offering the Personalized Tutoring 10 and tackle learning gaps in mathematics and Portuguese and to establish the Early Warning System11 that predicts the risk of students dropping out and implements personalized mitigatory strategies while students at risk are still at school, reducing school dropout rates; (ii) Rewarding Learning Recovery by providing financial rewards to lower secondary schools that implement the strategies under Pillar 1 and reduced the level, or improved, the percentage of students below level 4 in the Basic Education Assessment System (SAEB) proficiency scale; and (iii) Promoting New Pedagogical Models by providing financial support for schools that present innovative pedagogical models, disseminating these new pedagogical strategies and creating a bank of best practices. b) The Innovation Education Connectivity Program (Programa Inovação Educação Conectada , PIEC)12 supports the expansion of internet connectivity and enables the use of technology by the education community, through the universalization of high-speed internet access in basic education and promotes pedagogical utilization of technology. PIEC started in 2017 and now aims to reach 100% of students of basic education by 2024 by providing financial support to public schools to purchase new, or stronger, internet connectivity, by helping teachers to obtain training on a technological content or proportionating new technologies to improve learning. The Ministry of Education pre-selects schools using national datasets based on the cumulative criteria of: (a) eligibility (schools must be located in areas with internet coverage according to the Ministry of Science, Technology, Innovation and Communication, having electricity, and with their own Unidade Executora); 13 (b) inclusion (schools must enroll more than 14 students and possess at least 3 computers for students or one computer for administrative issues, and one classroom); (c) classification (school must have IDEB below the national average in the last results and to be in a vulnerable municipality, according to the Municipal Human Capital Index (); and, (d) confirmation (schools are selected by the local secretary of education to participate in PIEC).14 There are 17.376 and 38.444 basic education schools in North and Northeast, 8 The Program Brasil na Escola was established by Portaria 177 of 30th March 2021. The Portaria can be accessed in the following link: https://www.in.gov.br/en/web/dou/-/portaria-n-177-de-30-de-marco-de-2021-311650714 9 Such objective derives from two specific goals in the National Education Plan (Plano Nacional de Educação, PNE): goal 2 is to “universalize primary and lower secondary education for children between 6 and 14 years old and ensure that 95% conclude this cycle�; goal 7 is to “promote learning quality in all education stages by reaching an IDEB of 6.0 in primary, 5.5 in lower secondary, and 5.2 in upper secondary education.� 10 “Acompanhamento Personalizado das Aprendizagens� – APA. 11 “Sistema de Alerta Preventivo� – SAP. 12 The Programa Inovação Educação Conectada (PIEC) was established by the legislation 14.180 from 1st July 2021. The legislation can be accessed here: https://www.in.gov.br/en/web/dou/-/lei-n-14.180-de-1-de-julho-de-2021-329472130. 13 Unidade Executora is defined as the unit officially responsible to manage the recourses transferred to schools. They can be composed by school staff, parents, or member in the community. Generally, small schools are clustered in one Unidade Executora. 14 During 2021, 40.155 primary and lower secondary schools applied to PIEC. In the North, there were 9.253 schools while in the Northeast there were 30.902 schools. In terms of students, these schools comprehend 8.2 million students, being 2.2 million in 11 respectively, with 2.714.473 and 6.365.124 students, respectively (School Census, 2021). Those students are distributed among 2244 municipalities (450 in North and 1794 in Northeast). Only 59 percent of those schools in North and Northeast have internet access: 7.195 in North and 25.922 in Northeast. Internet access and the use of technology in pedagogical practice are part of the goals and strategies of the Plano Nacional de Educação (PNE). c) The third action refers to Law 14.172/2021 that aims to provide internet access and devices to eligible underprivileged students and teachers through the purchase of tablets, SIM cards and computers. Given that the pandemic exposed significant inequality in access to connectivity in society, the Ministry of Education in Brazil is buying R$3.5 billion in devices and internet connectivity to vulnerable students and teachers. From this total amount, the North and Northeast regions will receive approximately R$ 1.2 billion (or around 35%). To be eligible to receive tablets and SIM cards, students must be registered in Cadastro Único (CadÚnico) or enrolled at indigenous or quilombola schools. The program also purchases computers for teachers from public schools. Currently there are about 7.724.580 potential beneficiaries in North and Northeast, considering only the primary and low secondary education (2.182.149 in North and 5.542.431 in Northeast). d) Because teachers should be prepared to use technology in the classroom, the fourth activity provides decentralized innovation spaces with training on education technology. The Creativity and Innovation Lab for basic Education (Laboratório de Criatividade e Inovação para a Educação Básica, LABCRIE) is to promote training for teachers and school principals on pedagogical use of technology in the classroom. The potential beneficiaries are around 650.000 teachers and 30.000 school principals in Brazil. e) The fifth activity refers to the Active School Search Program (Programa Busca Ativa Escolar). The Active School Search is a tool developed by UNICEF in partnership with UNDIME15, made available free of charge to states and municipalities. At the municipality level, the mayor subscribes online to the platform and designates an operational coordinator to work on the tool. This coordinator organizes a management committee, which can be formed by different bodies (i.e. members of CRAS, CREAS, Guardianship Council). The management committee is responsible for analyzing critical cases and systematizing lessons learned through the platform. The tool works as a database that stores follow-up information on students out of school (i.e, socioeconomic information and causes of dropout). In areas with Google Maps, it is possible to track the geographical location of children. In addition, the tool organizes who is responsible for the case and records the history of actions taken by those responsible. The search begins with the community agent, who, during family visits, identifies children out of school and inserts an alert into the system. An institutional supervisor accepts or rejects this alert. If accepted, a technician visits the household and prepares a technical report. The supervisor manages the case and articulates intersectoral, if necessary. When the student re-enters the school, the case is followed up for one year.16 f) The final action refers to the School and Family Programa (Programa Educação e Família). This program was established by MEC Ordinance 571/2021 and seeks to expand and qualify the participation of families in the school life and in the construction of the life projects’ of the students, focusing on the process of reflection on what each student wants to be in the future and on the planning of actions to build that future, within the scope of schools public basic education. The program strengthens the participation of school councils on the elaboration and implementation of the School Action Plan, which comprises actions organized under two axis (monitoring of school life and student life project). The the North and around 6 million in the Northeast. In its last round, PIEC transferred funds to schools in all municipalities in the North (100 percent, 450 municipalities) and 1.774 municipalities in the Northeast Brazil (or 98.9 percent). 15 With support of Colegiado Nacional de Gestores Municipais de Assistência Social (Congemas) and Conselho Nacional de Secretarias Municipais de Saúde (Conasems). 16 https://buscaativaescolar.org.br/downloads/guias-e-manuais/guia-a-implementacao-do-municipio.pdf. 12 proposed actions include: workshops, lectures and conversation circles on a topic relevant to education; guided tours: Guided visits to spaces that promote learning (such as museums, libraries, universities, cultural or scientific centers, parks, etc.); and talent meeting (i.e., meetings that aim to value the talents of students and family members, in addition to contributing to the integration of the family with the school). 1.3. Thematic Scope The Program will contribute to address challenges faced by the Brazil’s education system that have been highlighted and exacerbated by the COVID-19 pandemic as Brazil kept their schools closed for longer than most countries in Latin America, depriving 50 million students (where 11.5 million are just in the North and Northeast regions), in over 168,739 schools (both public and private) from the benefit of in-person instruction during the pandemic. On average, schools remained closed for over 279.4 school days – equivalent to one year and 4 months of the school calendar. Public schools remained closed longer than private schools (287.4 days on average vis-à-vis 247.7 days). Such a prolonged period of school closures has multiple negative impacts on education, among them: (i) increases in school dropout rates; (ii) large learning losses and inequality; (iii) negative shocks on socioemotional skills; (iv) demand of new pedagogical skills; and (v) the long-term challenge of making fragile school networks to manage the current and future crisis. Above all, as schools gradually reopen, vulnerable students are less likely to return to and stay in school. These adverse impacts of Covid-19 on the education sector tend to be lasting, to worsen learning inequalities and socially and gender exclusive. Children and Adolescent from low income families (the two lowest quintiles of the per capita income scale) are the majority among the students enrolled in public education networks. In 2019, they accounted for 67.1% of the students of Brazilian elementary public schools, whereas their peers from the top quintile accounted for just 3.8% of these studentes. Meanwhile, the 58.5% and 5.5% of the students of secondary public schools were recruited from the bottom 40 and top 20, respectively. These challenges refer to: school dropout, learning achievements and performance, learning inequalities and access to digital technologies for pedagogical use. They are briefly considered below: School Dropout It is estimated that nearly 1.1 million children and adolescent in school age were out of school in 2019. Covid-19 intensified this problem as students became more disengaged with their studies because of remote education, reduced direct link with the schools, increased housework loads and pressures to enter in the labor market. Thus, In 2021, according to the Brazilian Institute of Geography and Statistics (Instituto de Geografia e Estatística, IBGE), nearly 1.4 million school-age students, between 5 and 17 years old,17 were out of school. Half of them from the North and Northeast Brazil, the most vulnerable regions. 17 IBGE; Pesquisa Nacional por Amostra de Domicílios Contínua 2021 – Second .Quarter. 13 Figure 1 - The impact of COVID-19 pandemic on dropout rates per sex Learning Achievements and Performance The national learning assessment (Sistema de Avaliação da Educação Básica, SAEB) for 2019 demonstrates that only a small fraction of Brazilian students achieved adequate levels of learning for their grade - only 19 percent of all students in a typical 9th grade public school had an adequate learning level. The COVID- 19 pandemic significantly affected learning levels and inequality. According to World Bank simulations,18 there could be an increase of up to 70 percent in the proportion of 10-year-old Brazilian students unable to read a simple paragraph. Learning Inequalities among Students of the Same Schools According to SAEB 2019, even among students attending the same school there were large learning inequalities: the score differential between the 20 percent highest and lowest performing students in the same school – which means that this learning gap is equivalent to about 5 years of learning. The COVID- 19 pandemic significantly affected learning levels and inequality.19 Connectivity and Pedagogical Use of Digital Technologies According to the 2020 School Census, only 60 percent of public schools in Brazil have internet and only a small fraction of schools use the internet for pedagogical purposes because the average download speed is low. Students from public schools (particularly children from poor families, Afro-Brazilian students, students from rural and remote located areas, Indigenous Peoples and Quilombola children) have far less access to digital technologies at school than their counterparts in private schools and the higher ranks of the per capita income scale. During the pandemic, conducting live classes mediated by the internet and with the possibility of direct interaction between teacher and students was one of the strategies adopted by the schools of elementary 18 “World Bank. 2021. Acting Now to Protect the Human Capital of Our Children: The Costs of and Response to COVID-19 Pandemic’s Impact on the Education Sector in Latin America and the Caribbean. World Bank, Washington, DC. © World Bank. 19 These learning inequalities are partially expanded because teachers have tended to follow the curriculum and teach students who are at the appropriate level, causing students who are lagging behind not to assimilate the knowledge. Thus, learning inequality increases over the years and tends to worsen in the return to post-Covid classes as poorer children had greater difficulty in accessing remote education and little family support to study at home. 14 education that remained closed to offer pedagogical content to students. The available information shows that this strategy was carried out throughout 2020 by 42.6% of all schools with a huge difference between the public and the private networks (35.5% and 69.8%, respectively). Among the group of students (ages 6 to 17 years old) without school activities (10.8% in total), there was an uneven distribution. Notably, the percentage of students in the public network that remained without school activities was 4.3 times higher than in the private network (12.4% and 2.9%, respectively). The percentage of students without receiving activities who lived in the rural area was 15.9%, compared to 9.7% in the urban area. Afro-Brazilian students enrolled in schools without access to activities during the pandemic almost double the number of other students (12.5 percent vis-à-vis 6.4 percent).20 All these challenges vary largely according to the regions of the country and are much worse in the most vulnerable North and Northeast regions as considered in the next section. 1.4. Geographic Scope The proposed Program will focus in the most vulnerable North and Northeast regions of the country, where the challenges faced by the public education system are worse. With an area of, roughly, 5.3 million sq.km, the Brazilian North and Northeast regions comprise 16 states and 2,243 municipalities. They face greater social and economic difficulties than other regions in the country as reflected by regional disparities in the Human Development Index – ranging from 0.667 in the North and 0.663 in the Northeast to 0.766 in the Southeast and 0.754 in the South. Public education networks and learning achievements face huge gaps in these regions that have been exacerbated by the unprecedented consequences of Covid-19. The public school system in these regions serves 18.6 million students and engage 794.6 thousand teachers, working in 82,719 schools. Schools in the North and Northeast Brazil had the longest school closing periods during the Covid-19 Outbreak. The top five states with the longest closures are all located in the North and Northeast: the state of Bahia had the longest school closures (366.4 days on average), followed by Roraima (349.4 days), Rio Grande do Norte (336.5 days), Acre (332.7 days) and Amapá (332.4 days). During the pandemic, students from public schools in the Northeast region have lost 307.1 days of school classes (the longest period in the country) and less than half of them had access to remote education platforms or access to school activities. About half of the children out of school lives in the North and Northeast. In 2010, the average dropout rate in the final years of elementary school was 7.7% in the Northeast and 7.2% in the North, well above the Southeast region (4.5%). In 2017, the two regions continue to show high dropout rates: 5.7% and 5.8%, respectively. In 2019, the average school dropout rate in lower secondary was 5.9 percent in the North and Northeast Brazil, well above the rate of 3.5 percent in the Southeast region. After Covid-19, in 2021, it is estimated that nearly 700,000 children and adolescent were out of school in these backward regions. The learning performance in the North and Northeast has historically been below country levels. In 2005, the national learning indicator (IDEB) of the Southeast was 20% and 38% greater than in the North and 20In addition, students from public schools have far less access to digital technologies at home than their counterpart in private schools. This disadvantage is further faced by students from public schools located in rural areas and in the North and Northeast regions. It is also more present among students from the lower income brackets of the population and the Afro-Brazilians. 15 Northeast, respectively. In 2019, Southeast IDEB remained 17% higher than in the two regions.21 Learning achievements dropped during the pandemic and are expected to have dropped more in the both regions and increased the gaps between poor and rich children. According to World Bank simulations,22 vulnerable students from the North and Northeast Brazil are significantly less likely to know how to read and write after the pandemic started. While 15.9 percent of rich children in the Northeast were not able to read and write in 2019, the pandemic has not affected this group significantly (1.9pp increase). Yet, for poor children in the Northeast, the percentage of children unable to read and write was already 44.3 percent in 2019 and reached 59.7 percent in 2021, a 15.4 percentage point increase. In North Brazil, the difference between the percentage of rich and poor children knowing who to read and write in 2019 was approximately 29 percentage points, with a smaller increase in 2021. These regions also face the worst conditions in terms of digital exclusion – connectivity at school and at home that impair learning. Access to internet and use of internet for learning at schools is worse in rural than urban areas as well as worse in the North and Northeast regions than in other areas of the country. In the North and Northeast, only 48.5 percent of public schools have access to internet connectivity and 9 percent to broadband. Furthermore, only 33.2 percent and 32.7 percent of public urban schools use the internet for learning while in the South, Southeast, and Center-West these percentages exceed 55 percent. Connectivity is not better in the homes of public school students rendering remote learning still harder and increasing regional disparities in education opportunities. While in the South and Southeast more than 64% of elementary school students have a computer at home, this percentage drops to 42.6% and 36.8% in the North and Northeast, respectively. Thus, during the Covid-19 outbreak, the highest rates of students without school activities were registered in the North (25.4%) and Northeast (15.8%) regions. These regional inequalities in internet connectivity and access to remote learning among schools and students point to larger learning losses due to COVID-19 pandemic in the North and Northeast Brazil. It is worth to highlight that most of the Indigenous Peoples of the country live in the North and Northeast regions. In 2010, 38.2% of the country’s Indigenous Peoples population (a total of 896,917 people)23 lived in the North region, whereas 25.9% were found in the Northeast. According with data from the 2019 National School Census, there were 3,342 indigenous schools open in the country; 64.3 percent of them were located in the North region and 20.0 percent in the Northeast region. 21 Such regional learning inequalities start with access to adequate child daycare centers and preschools. Only 10.8% of the children aged 0 to 3 years in the North and 20.5% in the Northeast have access to daycare centers. This rate reaches 36.5% in the Southeast. Only 63.1% of the children aged 4 to 5 years in the North and 69.8% in the Northeast have access to early childhood education. This rate reaches 84% the Southeast. 22 World Bank (2021). 23 Some estimations consider the current Indigenous Peoples population may reach 1.3 million people. 16 Therefore, the Program will contribute to address some of the main challenges faced by the public education network in these backward regions of the country: high levels of school dropout, weak learning performance of public school students, poor accessibility to digital technologies and internet connectivity with adequate speed for pedagogical use. 1.5. Institutional Arrangement The proposed Program will be implemented over a five-year period, with effectiveness expected for April 28, 2022. The overall responsibility for the Program is on the Secretaria de Educação Básica (SEB) at the Ministry of Education (MEC). Given that it promotes interlinked policies, SEB will coordinate the work with the Directorate of Guidelines and Policy for Basic Education (Diretoria de Políticas e Diretrizes da Educação Básica, DPD) on the Results Areas 1 and 2, the Directorate of Articulation and Support to Basic Education Networks (Diretoria de Articulação e Apoio às Redes de Educação Básica, DARE) and Directorate of Innovation and Formation of Education professionals (Diretoria de Formação Profissional e Inovação, DIFOR) for Results areas 1, 2, 3. The Education Ecosystem and the Integrated Education Management Systems will be implemented by the Subsecretary of Information Technology and Communication (Subssecretaria de Tecnologia da Informação e comunicação, STIC). SEB’s main roles and responsibilities are as follows: (i) coordinating the M&E of the Program; (ii) technical and operational decision making; (iii) promoting a results-based orientation; (iv) supporting states and municipalities in the North and Northeast to implement the program; (v) coordinating with secretariats within and outside the Ministry of Education; and (vi) functioning as the World Bank's interlocutor for the execution of the Program activities. SEB (with support of FNDE) will be the secretariat responsible for the implementation of Component 1, which supports the implementation of programs from the Ministry of Education (MEC) in the North and Northeast Brazil using a PforR lending instrument. SEB is responsible for implementing Component 2. A Project Management Unity (PMU) for the Program will be established under SEB and will also work with the Sub-secretariat of Administrative Affairs (Subsecretaria de Assuntos Administrativos, SAA) to guarantee proper and timely implementation of activities. The PMU activities include; (a) assisting in the preparation of the Terms of Reference (TORs); (b) ensuring that the procurement follows the World Bank rules and is carried out with technical inputs provided by relevant departments; (c) supporting the monitoring of contracts under the Program; (d) presenting the Program’s progress and the financial reports, as required by the World Bank; (e) ensuring the adequate management of environmental and social risks of the Program, the implementation of stakeholder engagement activities (including the Program of a Grievance Mechanism) and labor management measures;24 and (f) supporting the World Bank’s periodical supervision missions, optimizing the Program’s results and impact. The PMU is structured taking the lessons learned from the current Upper Secondary Reform PforR (P163868). The expertise from the environmental an social risk management specialists working in this project are going to be potentialized. Component 2 will provide capacity-building activities for the PMU and participating agencies. These will include training on the World Bank Procurement, Environmental and Social Framework (ESF) for institutions working on PIM to ensure that these activities consider all the relevant aspects. 24 Carrying out its attributions with the environmental and social risk management of the Program, the PMU will follow the Action Plan for Component 1 that is presented in this document (Chapter 6) and the Environmental and social Commitment Plan and Environmental and Social Standards of the World Bank for Component 2. 17 The Program has centralized coordination at SEB and decentralized activities involving from schools and local governments to municipal and state Secretaries of Education. To mitigate the risk of decentralizing activities and integrating actors in a single objective as well as to strengthening stakeholder engagement, this Program will create a high-level commission composed by several entities. The “Commision Educa Mais Norte e Nordeste� will be established in the Ministry of Education as a consultive counsel only. This commission will be composed by: the Executive Secretary of MEC (one member), Secretariat of Basic Education (one member), Sub-Secretary of Information Technology and Communication (one member), FNDE (1 member), Subsecretary of Administrative Affairs (one member); the Union of Municipal Directors of Education (UNDIME) (5 members: 2 from the North and 3 from the Northeast Brazil), Counsel of State Secretaries of Education (5 members, 2 from the North and 3 from the Northeast Brazil) and the National Counsel of Education (one member). The committee is expected to hold semestral meetings to discuss the project's implementation. Each Results Area of Component 1 will require specific institutional arrangements that will involve external partners. 1.6. Previous Experience of the Implementing Agencies with the Program or Similar Activities The implementing agencies of Component 1 – the Secretariat of Basic Education (SEB) under the Ministry of Education and the National Education Development Fund (FNDE) – have acquired experience with the World Bank requirements for the management of environmental and social risks of Program for Results Programs during the ongoing implementation of the Upper Secondary Reform PforR (P163868). They also hold well established management systems, good track-record and technical capacity for the implementation of similar activities as those supported under the Program. 2. Description of Expected Environmental and Social Effects of the Program 2.1. Likely Environmental and Social Effects This criteria considers the likelihood of the main benefits and adverse impacts and risks that are associated with the Program activities as well as the severity or significance of these impacts. The three result areas do not have direct, neither going forward, potential significant environmental effects. The three results areas encompass, mostly, consultation services and implementation of administrative procedures and management systems, aiming to reduce school dropout, recover learning losses and strengthen local resilience in primary and lower secondary schools. Results Area 1 – Recovery from School Dropouts – aims at creating a national and State Observatories of School Dropouts in the North and Northeast to coordinate a Student Active Search Program, a School Dropout Call Center and an Early Warning System. None of these activities have direct or going forward environmental implications. Results Area 2, Recovering from Learning Losses – Offline, looks to implement personalized tutoring, organizing students in small groups with similar learning levels. Additionally, it will implement Socioemotional Discussion Groups, promoting structured group activities, aiming to rebuilt socioemotional skills of students after the pandemic. Analogous to Results Area 1, the related activities have no significant environmental implications. Finally, Results Area 3: Recovering from Learning Losses – Online, will try to reduce learning losses, through “online� or hybrid activities (combining online and face- to-face learning). This Result Area aims to ensure that schools in the North and Northeast Regions have 18 proper connectivity, as defined in the Connected Education Innovation Program (Programa Inovação Educação Conectada, PIEC) – expanding internet coverage in schools. The planned activities in this area include: Providing tablets for students and computers for teachers, supplying kits of internet connectivity for schools and supporting infrastructure to internet connectivity, withing the school facilities25. This infrastructure includes, mainly, acquisition and installation of modems, routers, wireless access points, etc., demanding quite limited interventions in existing school facilities. In sum, none of the result areas include development of physical infrastructure, or preparation of future investments in infrastructure or other sectors. The Project has no type of activity that could cause significant environmental effects. The expected social effects of activities included under the supported Results Areas would be (a) the enhancement of the learning performance, (b) the reduction of dropout rates, (c) the reduction of learning inequalities among public schools’ students and (d) their increased access to and use of the internet for leaning. These positive outcomes are expected to benefit the most children and adolescents from poor and vulnerable social groups as (i) the activities will be focused in the most vulnerable North and Northeast regions and (ii) public schools’ students are mostly recruited from low-income families. No adverse social effects are expected from the activities supported by the Program. The remote location of some vulnerable communities (Indigenous Peoples, quilombola, riverine, forest-dwellers and other traditional communities) in the North and Northeast regions is a challenge as their populations might not have access to information on the governmental policies that are being supported or might not have access to the infrastructure needed to benefit from activities that heavily rely on digital technologies and access to internet.26 Therefore, they might be excluded from benefiting from these interventions. The preventive and outreaching strategies to avoid or reduce school dropout included in the Recovery from School Dropout are expected to contribute to reduce social inequalities and contribute to social inclusion as school dropout hurts the most the poor, disadvantage, vulnerable and often discriminated students as they give priority to schools located in vulnerable municipalities, schools attending a majority of students receiving conditional cash transfers, students registered in Cadastro Único (CadÚnico) or enrolled at indigenous or quilombola schools. They are also expected to reduce gender gaps in education. Considering that, in the North and Northeast region, girls less likely to return to school after dropping out,27 the Program includes some actions 25 The Project will not include development of internet infrastructure outside the school facilities, as the Federal Government, through the Ministry of Communication and Ministry of Science and Technology has specific programs to expand internet coverage, such as the Internet for All (“Internet para Todos�). Most, if not all, municipalities in the Northeast Region have wide band internet services, and 88% of the North Region cities have wide band internet (https://www.gov.br/mcom/pt- br/noticias/2021/setembro/wi-fi-brasil-88-das-cidades-do-norte-ja-contam-com-internet-banda-larga) including 3.9 points connected by satellite, aiming to promote education and economic development in remote areas. 26 As it will be addressed later (when considering Core Principle 5), this is the case of most of the indigenous schools, countryside and quilombola schools. For example, 73 percent of indigenous schools have proper school buildings, 67 percent have access to energy, but only 21 percent have access to internet. Schools’ access to internet drops to 8 percent in the North region and raises to 27% in the Northeast [2020 National School Census - INEP]. 27 There is scattered evidence that, in the North and Northeast regions of Brazil, among 9th graders, girls have a slightly higher chance of dropping out of school than boys: 3.2 percent against 3.0 percent for boys, whereas there are more boys than girls are found amongst students in 6th grade that dropout during the school year (Censo Escolar, 2019.). Thus, for example, a recent UNICEF report on the underlying drivers of school dropout, shows that they apparently vary by gender. “Pregnancy�, “household chores� or “care for a family member� are pointed out by 22.6 percent of the girls interviewed as the underlying reasons for not attending school, whereas boys never did [UNICEF (2020), Out-of-School Children in Brazil (available at 19 (financed under Component 2) to address this issue: (a) the National Observatory of School Dropout is going to have a gender specialist to analyze gender-sensitive data and guide local governments; (b) as data on sex-related dropouts is relatively unexplored in Brazil, a longitudinal study will map the causes of school dropout per sex in the North and Northeast; (c) protocols will be developed to (i) guide local teams approaching households, families or students that dropped out because of gender-based violence and teenage pregnancy and (ii) guide community agents, school staff, municipalities and state secretaries of education on how to deal with cases of student dropout related to homelessness;28 (d) during its mapping stage, the Early Warning System will apply two questionnaires: one answered by students on issues highly correlated to the risk of dropping out and the other answered by school coordinators on gender-based violence and risk of teenage pregnancy; and, finally (e) the social workers and agents working in the School Active Search program will also support the work of the National Observatory of School Dropout by collect socioeconomic information and identify causes of dropout. The Offline Recovering Learning Losses strategies – Personalized Tutoring and Socioemotional Discussion Groups – are expected to improve learning performance and reduce learning inequalities, contributing to keep children in school. As largely attested by international research, the Socioemotional Discussion Groups are critical to achieve these objectives insofar as unmotivated students rarely return to school or learn properly and, during school closures and social distancing measures, children were further deprived of social and cognitive stimuli (because of stresses originating from situations such as losing a relative, food insecurity, and economic hardship). The envisaged Socioemotional Discussion Groups will develop structured activities to discuss gender-related issues (as teenage pregnancy and GBV). It is necessary that the approach taken on discussing the topic of teenage pregnancy is not hampered by potential unconscious bias, stereotypes and ethnocentric prejudices. Finally, the Online Recovering Learning Losses strategy and the use of technologies would allow a more individualized approach able to help with the Personalized Tutoring, attend the specific needs of students who have poorer performances, and reduce learning inequalities that often are a driver to dropout. These strategies may be the most adversely affected by the digital divide (a context risk factor that will be considered in the next section) as the vulnerable municipalities and remotely located communities in the North and Northeast region overwhelmingly face poor access to internet and digital technologies at schools and at homes. This digital divide may also put the achievement of the expected learning and socially inclusive objectives of the Program at some risk. The digital divide may be of particular concern for remote located communities (including indigenous, riverine, forest-dependent and quilombola communities) that may not have access to information on the Program and the programs it supports and, consequently, be excluded from its benefits (as will be dealt below, when considering Core Principle 5). In short: The Likely Environmental effects are negligible and the social effects of the Program are mostly positive and far exceed its small in scale and low in magnitude adverse impacts and risks. These risks can be mitigated in a predictable manner mostly involving: the adequate guidance of those working in the supported activities on how to approach and respectfully interact with disadvantaged and vulnerable individuals, families and social groups (including distinct social and cultural groups); the establishment of https://www.unicef.org/brazil/media/14881/file/out-of-school-children-in-brazil_a-warning-about-the-impacts-of-the-covid- 19-pandemic-on-education.pdf]. 28 The guides to be developed shall pay particular attention to ensure local teams approaching households, families and students as part of the core activities of the School Active Search Program and in their daily interactions with local communities follow an adequate Code of Conduct – based on principles of respect for distinct cultural values and norms, non-discrimination, and non- acceptance of any kind of prejudice, harassment, embarrassment or coercion. 20 an adequate code of conduct for guiding their relationships with local communities, school workers, families and students; and the compliance with the principles and guidelines of the Brazilian education policies and regulatory frameworks. 2.2. Contextual Risk Factors This criteria takes into account the E&S conditions in the Program area that may have significance for Program design and implementation. Contextual risk factors include potential risks to Program sustainability, with emphasis on identifying risk factors that may impede achieving successful Program outcomes over time and whose future outcomes are unknown. Recent or ongoing social conflict or social fragility are also included. The main contextual risk factors to the achievement of successful and sustainable Program outcomes over time are related with the digital divide and the disparity of institutional capacity among the municipalities in the Northeast and North regions (this second risk factor is dealt with in the next section). The available data shows that the digital divide has contributed to marginalize poor students from public schools (particularly in the North and Northeast regions) – reducing their educational opportunities (particularly under the pandemic). Brazil has made large progress in terms of digital transformation. For example, 20 years ago, there were 14 cell phones for every 100 inhabitants; now, the rate of penetration of cell phones reaches 105%. Furthermore and nowadays, the internet has 134 million users in the country reaching 74% of the population aged 10 or over). Nevertheless, huge gaps remain according to the area of the country and/or the economic conditions of the population. In 2019, the difference between users of internet in urban and rural areas remained large: while 77% of households in urban areas had access to internet, only 53% of rural households used this service. In the North and Northeast regions, internet was available to 72% and 65% of the households. The percentage of users of internet by social class also remained largely unequal: 95% of class A households were connected with the internet, whereas in classes D and E this percentage was 57%. The elderly and the people with lower school achievements used far less the internet than other social groups. Among the Internet users, only 41% carried out school activities or researches, 40% used the Internet to study for their own account (60% of the class A users and only 26% of the class D and E) and only 12% took classes.29 The available information shows the impact the pandemic had on education because of the lack of adequate access to connectivity faced by schools and students, the impact that the digital gap may have on learning achievements and learning inequality and how they varied regionally. During the pandemic, the group of students (ages 6 to 17 years old) without school activities (10.8% in total) showed an uneven distribution according to some characteristics related to the educational network and the territory of residence. Notably, the percentage of students in the public network that remained without school activities was 4.3 times higher than in the private network (12.4% and 2.9%, respectively). The percentage of students without receiving activities who lived in the rural area was 15.9%, compared to 9.7% in the urban area. The highest rates were registered in the North (25.4%) and Northeast (15.8%) regions. Conducting live classes mediated by the internet and with the possibility of direct interaction between 29 TIC Domicílios 2019, available at https://cetic.br/media/analises/tic_domicilios_2019_coletiva_imprensa.pdf and Costin, C. et all. (2021), Escola Conectada: Como o uso de tecnologias aplicadas à educação revoluciona a experiência de aprendizado . Cisco/Logicalis, e-book, available at https://ebooks.cisco.com/story/ebook-escola-conectada/] 21 teacher and students was one of the strategies adopted by the schools of elementary education that remained closed to offer pedagogical content to students. The available information shows that this strategy was carried out throughout 2020 by 42.6% of all schools with a huge difference between the public and the private networks (35.5% and 69.8%, respectively).30 In the public education sector, digital gaps are mostly prominent in the North and Northeast region and have adversely affected mostly poor students from public schools – reducing their educational opportunities (particularly under the pandemic). Access to digital technologies vary widely by school networks and regions of the country as shown by the graphs below drawn from data of INEP’s 2020 School Census. As shown in Graph 1, students from public schools have far less access to digital technologies at school and at home than their counterpart in private schools. Municipal schools – which concentrate most of the students – fare worse than all other schools. 25.8% Tablets for students 6.0% 12.0% 37.0% 46.6% Notebook for students 23.8% 32.9% 56.5% 65.5% Desktop computers for students 38.3% 76.7% 91.3% 71.6% Multimedia projector 54.4% 78.3% 95.7% Digital whiteboard 9.9%14.2% 27.0% 54.3% 65.3% Internet for learning uses 33.7% 71.5% 84.8% 93.7% Internet only for managerial use 61.6% 90.8% 100.0% 49.6% Internet accessible to students 23.8% 61.3% 89.1% 88.4% Broad band Internet 52.0% 74.7% 100.0% 97.6% Internet 64.7% 92.1% 100.0% 0.0% 20.0% 40.0% 60.0% 80.0% 100.0% 120.0% Private Municipal State Federal Graph 1 – Digital Technology Available at Elementary Education Schools by Network – 2020 Source: Brasil. Instituto Nacional de Estudos e Pesquisas Educacionais Anísio Teixeira. Censo da educação básica 2020 : resumo técnico [recurso eletrônico] – Brasília : Inep, 2021. This disadvantage is further faced by students from public schools located in rural areas and in the North and Northeast regions, which fare worse than schools in all other regions with regards to the availability of these digital technologies. As pictured in Graph 2 and Figures 2 and 3, based on data collected through the 2020 Elementary Education Census, schools’ access to technological resources vary widely by region 30As a further evidence of the digital divide and illustrating the challenge presented to the Brazilian education system to ensure quality education for all, the data shows that for the students on the age group 15 to 17 years old attending the private schools, there was practically universal access to the internet at home (98.9%); 91.0% of them had home computer or notebook; and 90.5% of them had simultaneous access to internet and a computer or notebook at home. In comparison, for those attending public schools, while internet access at home was high (85.3%), there was a relatively low percentage of students with a computer or notebook at home (50.4%) and a still lower percentage of students with simultaneous access to internet and computer or notebook (48.6%). Thus only 3.6 out of 6.8 million students in this age group (54.0%) had access to internet, computers or notebooks in home before the outbreak of COVID-19. This ratio was still lower in the North and Northeast regions (37.1% and 38.5%, respectively), worse among students from schools located in rural areas than in urban ones (23.3% and 56.0%, respectively) and worse among Afro-Brazilian students than among white students (46.8% and 67.3%, respectively). IBGE, Síntese de Indicadores Sociais: Uma análise das condições de vida da população brasileira – 2021, available at https://biblioteca.ibge.gov.br/visualizacao/livros/liv101892.pdf) 22 and show a huge disparity between the North and the rest of the country. In all ten technologies analyzed, the North region presented percentages below 50%. It is noteworthy that only 31.4% of elementary schools in the North region have broadband internet access. In the Northeast, the percentages of internet (66.6%) and broadband internet (54.7%) are also lower than in the South, Southeast and West Central regions. The South region has the highest percentage (48.8%) of laptops for students. 13.1% 17.4% Tablets for students 8.1% 14.8% 5.4% 39.2% 48.8% Notebook for students 25.9% 33.8% 14.3% 66.4% 76.9% Desktop computers for students 34.2% 71.6% 25.5% 85.5% 87.5% Multimedia projector 54.8% 68.9% 38.7% 22.4% 29.2% Digital whiteboard 6.8% 19.8% 4.7% 66.7% Internet for learning uses 29.3% 68.7% 76.3% 18.5% 93.5% 94.4% Internet only for managerial use 62.8% 91.0% 41.2% 48.3% 65.4% Internet accessible to students 51.8% 15.0%20.5% 83.4% 78.7% Broad band Internet 54.7% 81.2% 31.4% 96.6% 96.9% Internet 66.6% 93.4% 43.2% 0.0% 20.0% 40.0% 60.0% 80.0% 100.0% 120.0% West Central South Southeast Northeast North Graph 2 - Digital Technology Available at Elementary Education Schools by Region - 2020 Source: Brasil/Inep: 2021. Figure 2: Parcel of public elementary schools with access Figure 3: Parcel of public elementary schools with access to to internet – 2020 broadband internet – 2020 Source: Brasil/Inep: 2021. Source: Brasil/Inep: 2021. Digital gaps also adversely affect the most some disadvantaged and vulnerable social groups that are attended by the school modalities of the countryside education, quilombola education and Indigenous Peoples Education.31 Poor access to digital technologies is more oftenly found among students from the 31These special modalities of education have been guaranteed by the Brazilian regulatory framework of the public education sector. Their principles and guidelines will be considered in further detail when considering the Core Principle 5, below. 23 countryside, Afro-Brazilian students and Indigenous Peoples.32 As shown in Graph 3, below, the available data show that countryside, indigenous and quilombola schools in the North and Northeast regions face the highest barriers in access to connectivity and for the use of digital technologies for learning amongst all schools of the public elementary education network. Countrysyde Schools - - Infrastructure Available by Region - 2020 Without Internet 56.1% 76.7% Without Water and Sanitation 6.2% 9.0% Without Energy 1.6% 20.3% Appropriate Building 92.2% 88.9% 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0% Northeast North Indigenous Schools - Infrastructure Available by Region - 2020 Without Internet 92.2% 91.0% Without Water and Sanitation 7.8% 10.8% Without Energy 7.8% 53.9% Appropriate Building 76.0% 65.3% 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0% Northeast North 32As previously shown, indigenous schools have very poor access to digital technologies and the internet. In the country, 79 percent of the indigenous schools have no access to internet. This rate raises to 92 percent in the North region and drops to 73 percent in the Northeast. Addressing this digital divide is critical to allow that indigenous students get their fair share of the program’s expected benefits. 24 Quilombola Schools - Infrastructure Available by Region - 2020 Without Internet 65.1% 77.6% Without Water and Sanitation 11.4% 8.3% Without Energy 0.9% 10.8% Appropriate Building 94.2% 87.8% 0.0% 10.0% 20.0% 30.0% 40.0% 50.0% 60.0% 70.0% 80.0% 90.0% 100.0% Northeast North Graph 3: Infrastructure Gaps on Countryside, Indigenous and Quilombola Schools in the North and Northeast Regions - 2020 Source: SEMESP communication based on INEP – 2020 Elementary Education Census The digital divide is a key context risk factor that could hamper the achievement of the expected social benefits of the Program. Nevertheless, having the goal of supporting the universalization of access to broadband internet at public schools and promote the use of digital technology in basic education, PIEC is expected to contribute to reduce this digital gap. And prioritizing students registered in CadÚnico or enrolled at indigenous and quilombola schools as a criteria of eligibility to receive tablets and SIM cards, the Program is also expected to promote digital inclusion. Therefore, good targeting of the supported interventions would contribute to reduce marginalization of disadvantaged and vulnerable students. In short: The context risk-factor represented by the digital divide on the achievement of Project Development Objectives is not irrelevant. The strategy of the Program – focusing on expanding access of schools to broadband internet and providing SIM cards to students from vulnerable social groups and/or enrolled in indigenous and quilombola schools is adequate to promote social inclusion, but must be closely monitored in its implementation. 2.3. Institutional Capacity and Complexity Risks This criteria refers to the borrower’s organizational, administrative, and regulatory structures and practices as they relate to E&S assessment, planning, and management of the Program. The implementation of Program would involve agencies at the three levels of government (federal, state and municipal) in the 16 states of the two most backward regions of the country (North and Northeast) adding to the complexity of the institutional arrangements for its implementation. Brazil has a comprehensive regulatory framework dealing with: (a) environmental issues, which addresses environmental impact assessment, protection of environmental habitats and conservation of biodiversity, and punishment of environmental crimes; (b) citizen rights and social inclusion issues, which addresses protection of cultural heritage, respect to sociocultural distinct identities and traditional knowledge, rights of access to information and rights of users of public services, recognition of property and possession land 25 rights, protection of data privacy and Program of Ombudsman Offices in all governmental agencies; and (c) labor terms and working conditions, which addresses appropriate terms and conditions of employment, rules of nondiscrimination and equal opportunity, recognition of worker’s rights to form and to join workers organizations of their choosing and collective bargain, banishment of child and forced labor, and occupational health and safety standards. However, the capacity of the regulatory agencies and the enforcement of this comprehensive regulatory framework are not homogenous throughout the country. The Federal agencies involved in the Program – namely: (i) the Executive Secretariat of the Ministry of Education, with support from the Secretariat for Planning and Budget (SPO) and the Secretariat for Administrative Affairs (SAA); (ii) the Secretariat of Basic Education (SEB); and the (iii) National Education Development Fund (FNDE) – have well established management systems and technical capacity. Nevertheless, not only the capacity of the State and Municipal Secretariats of Education, but also the regulation’s enforcement under state and municipal authorities vary significantly across the country. In many places of the targeted regions – and often due to their remote locations – the institutional capacity of the state and local agencies is weaker than the capacity of the federal agencies and some have a weak track record. It is worth to highlight that labor relationships, work place conditions and Occupational Health and Safety aspects are under direct supervision of the federal agencies (the Federal Secretariat of Labor and the Ministry of Labor). In this case, the enforcement is adequate throughout the country and the risk of non- conformities is low. It is also worth to highlight two other aspects of the regulatory and institutional framework under which the Program will be implemented. They refer to: (a) the inclusive principles and highly participatory procedures ruling school education in Brazil and (b) citizen rights of access to information and adequate resolution of complaints with regards to the provision of public services. Thus, on the one hand, it shall be considered that school education is legally ruled33 by the principles of (a) equality of conditions for access and permanence in school; (b) freedom to learn, teach, research and disseminate culture, thought, art and knowledge; (c) pluralism of ideas and pedagogical concepts; (d) respect for freedom and appreciation for tolerance; (e) coexistence of public and private educational institutions; (f) gratuitousness of public education in official establishments; (g) appreciation of professionals of school education; (h) democratic management of public education, in the form of this Law and the legislation on education systems; (i) guarantee of quality standards; (j) valorization of out-of- school experiences; (k) linkage between school education, work and social practices; (l) consideration for ethnic-racial diversity; (m) guarantee of the right to education and lifelong learning; and (n) respect for the human, linguistic, cultural and identity diversity of hearing-impaired people. It also requires that, respecting the common standards and those of their education system, schools will be responsible for: developing and executing their pedagogical proposals; managing their staff, materials and financial resources; ensuring compliance with established school days and class hours as well as with 33The key legal instruments ruling school education are Law 9,394/1996 (Law of Education Guidelines and Bases – LDB) – with the changes made by Law 11,645/2008, Law 12,796/2013, Law 12,960/2014, Law 13,632/2018, Law 13,663/ 2018, Law 13,803/2019, Law 13,840/2019, Law 14,164/2021 and Law 14,191/2021) and The Common National Curriculum Base (http://basenacionalcomum.mec.gov.br/images/BNCC_EI_EF_110518_versaofinal_site.pdf). 26 the work plan of each teacher; providing the means for the recovery of students with low learning achievements; articulating with the families and the community, creating processes of integration between society and schools; notifying the Municipal Guardianship Councils of the list of students who present a number of absences above 30% (thirty percent) of the percentage allowed by law; promoting awareness, prevention and combat measures against all types of violence, especially systematic intimidation (bullying) within the scope of schools; establishing actions aimed at promoting a culture of peace within the schools; and promoting a safe school environment, adopting strategies for preventing and coping with drug use or dependence. This legislation also established that school education would be organized in two levels: Basic Education – formed by early childhood education, elementary school and high school – and Superior Education. The curricula of early childhood education, elementary education and secondary education must have a common national basis, to be complemented, in each education system and in each school establishment, by a diversified part, required by the regional and local characteristics of the society, culture, economy and students. The teaching of the History of Brazil shall take into account the contributions of different cultures and ethnicities to the formation of the Brazilian people, especially the indigenous, African and European matrices and the study of Afro-Brazilian and Indigenous history and culture are mandatory in public and private elementary and secondary schools. Contents related to human rights and the prevention of all forms of violence against children, adolescents and women shall be included, as cross- cutting themes, in the curricula mentioned, observing the guidelines of the corresponding legislation and the production and distribution of didactic material suitable for each level of education. Furthermore, this legislation requires that the offering basic education to the rural population shall promote the necessary curricular adaptations to adapt school education to the peculiarities of the rural life and of each region as well as proper school organization (including adaptation of the school calendar to the phases of the agricultural cycle and to climatic conditions). On the other hand, Brazil has recently strengthened its legislation on the participation, protection and defense of the rights of users of public services offered directly and indirectly by public administration at all levels. The new measures are in accordance with what is provided for in the Federal Constitution of 1988 (Art. 37 and Art. 74) and Constitutional Amendment 19/1988 on the participation of users in the provision of public services and the creation of Ombudsmen Offices at all levels of government. Thus, Law 13,460/2017 lays down the rights of users of public services, including, among others: (i) participation in the supervision and evaluation of service provision, (ii) access and use of services without discrimination and with freedom of choice between the different means they are offered, (iii) the access to personal information in public records and databases, (iv) the protection of personal information, (v) access to accessible and correct information in the places where services are provided and through the Internet, and (vi) access to the public agent or the agency in charge of receiving manifestations. In order to guarantee the fulfillment of these rights, the law establishes that users of public administration services can address service providers and present their manifestations (including complaints, grievances, suggestions and compliments about the provision of public services and the conduct of public servants). According to this law all requests of information and compliances made by public service users must be treated (received, acknowledged, analyzed, deliberated and answered) in a quick and effective manner by the ombudsman offices of government agencies (at all levels of public administration). The Ombudsman must: (a) promote the participation of users in public administration; supervise the provision 27 of services and propose improvements, (b) receive, analyze and forward the request to the competent authorities; (c) supervise the resolution of the cases; (d) propose the adoption of measures to defend the user's rights; and (e) promote the adoption of mediation and conciliation measures between users and public bodies or entities, without damage to other relevant bodies. Ombudsman Offices are obliged to publicly release annual management reports, covering the number of requests and compliances received, a description of their content, an analysis of recurring issues and a description of the measures adopted by the public administration to solve them. The law requires that user’s councils are instituted as consultative bodies with the tasks of monitoring the provision of public services, participating in their assessment and proposing improvements, and monitoring and evaluating the performance of the Ombudsmen. The composition of these boards must observe criteria of representativeness and plurality of stakeholders, whose representatives must be chosen in a process open to the public and differentiated by type of user to be represented. Furthermore, Normative Instruction 5/2018 of the Ministry of Transparency, the Union Controller General and the Union General Ombudsman34 has established guidelines for the performance of the ombudsman offices of the federal Executive Branch and determines that they shall act in accordance with the following guidelines: (i) acting promptly and impartially; (ii) collaborating with the integration of ombudsmen; (iii) ensuring the autonomy of the ombudsmen; (iv) promoting social participation as a method of government; and (v) contributing to the effectiveness of public policies and services. According to the instruction, the Ombudsman's duties include: (i) proposing actions and suggesting priorities in the ombudsman activities of the respective area of activity, monitoring and evaluating the Programs and activities and organizing and disseminating information about ombudsman activities and operational procedures; (ii) promoting the adoption of mediation and conciliation between users of public bodies and entities, with the purpose of expanding and perfecting the spaces of relationship and participation of society with the public administration; (iii) processing the information obtained through the comments received and satisfaction surveys carried out with the purpose of evaluating the services provided, especially regarding the fulfillment of the commitments and the quality standards of service in the User Service Letter; (iv) producing and analyzing data and information on the activities of the ombudsman, supporting recommendations and proposals for improving the provision of services and correct flaws; (v) promoting articulation, on a permanent basis, with instances and mechanisms of social participation, in particular, public policy councils and commissions, national conferences, discussions, forums, hearings, public consultations and virtual environments for social participation; (vi) exercising the duties of Citizen Information Service,35 when so designated; and (vii) receiving treatment and responding to requests submitted through the ‘Simplify! form.36 Federal Government’s Ombudsman Offices cannot, under any circumstances, refuse to receive the requests of information or compliances made under the terms of this Normative Instruction. The procedures are free of charge, and the collection of any amount from the user is prohibited. Any requirements related to the reasons that determined the presentation of manifestations before the ombudsman are also prohibited. The request for certification of the user's identity can only be required when the response to the statement implies access to personal information of the user or third parties. 34 http://www.in.gov.br/materia/-/asset_publisher/Kujrw0TZC2Mb/content/id/27128217/do1-2018-06-25-instrucao- normativa-n-5-de-18-de-junho-de-2018-27128190. 35 Law nº 12,527, of November 18, 2011 (https://www.gov.br/acessoainformacao/pt-br). 36 Joint Normative Instruction MPDG/CGU nº 1, of January 12, 2018 (http://www.simplifique.gov.br/). 28 Access to the system is available on the main page of the Ministry of Economy portal. Among the Ombudsman's obligations, it should be noted that it must: (i) respond to statements in clear, objective, simple and understandable language; (ii) prepare and submit a conclusive response to the statements received within thirty days of receipt (extendable for an equal period upon express justification); (iii) proceed to the prior analysis of the statement as soon as it is received and, if necessary, forward it to the areas responsible for adopting the necessary measures; (iv) request the user to provide information whenever the information that has been presented is insufficient for the analysis of the statement and not make successive requests for complementation, except if referring to the situation that arose with the new documentation or information presented; (v) request information from the areas responsible for taking action, which must respond within twenty days from the receipt of the request in the competent sector, which can be justified once for an equal period; (vi) ensure the protection of the identity and elements that allow the identification of the user or the author of the event;37 and (vii) receive and collect information from users of public services in order to evaluate the provision of such services and to assist in the detection and correction of irregularities. No request of information or compliance must be closed without producing a conclusive answer, unless the author fails to comply with the duties of: (a) exposing the facts according to the truth; (b) acting with loyalty, good manners and good faith; (c) acting in a reckless manner; or (d) failing to provide the information requested to clarify the facts. The Federal Ombudsman's Office may be reached in the event of non-compliance with the established deadlines and procedures. The Federal Ombudsman's Office, which maintains a computerized system on the receipt and treatment of complaints received by all ombudsmen from the federal executive branch and an electronic website that promotes interaction between society and the federal public administration, as well as the dissemination of information and statistics on services provided by federal public ombudsmen. In short: The risks of the Program related with the institutional complexity and borrower implementation capacity and track-record are classified as Moderate. 2.4. Reputational and Political Risks This criteria addresses E&S issues, trends, or other factors that may cause the Borrower, the Program, or the World Bank to be exposed to significant reputational or political risk, because of public perception, concerns over the Borrower’s historical failure to implement its E&S policies, or inclusion of programs and activities that are known to be controversial. The Program does not include activities that are considered controversial. On the contrary, stakeholders have shown support to initiatives to recover from school dropouts and learning losses related to the COVID-19 pandemic, to face learning inequalities and to improve learning achievements, to expand schools connectivity to the internet and the pedagogical use of digital technologies, and to strengthen local resilience in primary and lower secondary schools. An screening of news and opinions expressed in websites of relevant stakeholders shows that there is a strong level of consensus – within and outside the federal government – on the relevance of the proposed activities supported by the Program. These activities are intrinsically associated with the goals set in the 37If essential to the verification of the facts, the name of the user can be forwarded to the investigating body, which will be responsible for restricting access to the identity of the demonstrator to third parties. 29 2014/2024 National Education Plan (PNE). Thus, the Brazil in School Program and its activities supported by the Program contribute to: • PNE’s Goal 2 aiming the universalization of 9 (nine) years of primary education for the entire population from 6 (six) to 14 (fourteen) years and ensure that at least 95% (ninety-five percent) of students complete this stage at the recommended age, until the last year of validity of this PNE; and • PNE’s Goal 7 aiming the promotion of the quality of basic education in all stages and modalities, with improvement in the school flow and learning in order to reach the following national averages for IDEB. And the Innovation and Connected Education Program also contributes to PNE’s Goal 7, particularly the strategies 7.15 (“to universalize, by the fifth year of this PNE, access to the world wide web of high-speed broadband computers and triple, by the end of the decade, the computer/student ratio in public primary education schools, promoting the pedagogical use of information and communication technologies�) and 7.20 (to provide equipment and digital technological resources for pedagogical use in the school environment to all public schools in basic education, including creating mechanisms to implement the necessary conditions for the universalization of libraries in educational institutions, with access to digital computer networks , including the internet). The institutional arrangements envisaged for implementation of Program encompasses a Monitoring Commission that would be appointed by the Executive Secretariat of the Ministry of Education and initially formed by members of SEB, FNDE and the municipal and state education councils (UNDIME and CONSED). Additionally and reducing the reputational and political risks, it is worth mentioning that: • Law 13,005/2014 reiterates the principle of federative cooperation in educational policy, already present in the Federal Constitution and in the Law of the Guidelines and Bases for National Education (LDB – Law 9,394/1996), establishing that the Union, the States, the Federal District and the Municipalities shall act in collaboration to achieve the goals and implementing the strategies object of the PNE and providing for the creation of the Permanent Instance of Negotiation and Cooperation between the Union, the States, the Federal District and the Municipalities (§ 5 of Art. 7). • This Permanent Instance of Negotiation and Cooperation was established by MEC Ordinance No. 1,716/2019 and aims to contribute to the achievement of the goals and the implementation of the strategies defined in the PNE, to strengthen the articulation mechanisms between the education systems, through the development of joint actions. Its composition (MEC Ordinance No. 2,010/2019) contemplates the three federative spheres on an equal basis and also considers the regional representation. It meets every semester. Activities under the proposed Results Areas have been discussed during these meetings. Indeed, the Brazil in School Program responds to requests on the need to develop a program aimed at the final years of elementary school made at the meetings of PNE’s Permanent Instance of Negotiation and Cooperation. • The law also states that the execution of the PNE and the fulfillment of its goals are subject to continuous monitoring and periodic evaluations, carried out by the Ministry of Education, the Education Committee of the Chamber of Deputies and Education, Culture and Sports Committee of the Federal Senate, the National Education Council (CNE) and the National Education Forum. 30 In addition, since 2013, the execution of PNE has been monitored according to a set of indicators selected by the Ministry of Education and INEP for monitoring the 2014-2024 PNE based on information from various official sources. These indicators were published in the document entitled National Education Plan PNE 2014-2024: Baseline (INEP, 2015). These indicators have been monitored by the PNE Observatory (OPNE).38 Social oversight of the implementation of PNE has also remained very strong. In short: The Program’s reputational and political risks are Low. 3. Assessment of the Borrower’s Environmental and Social Management System This section describes the main elements of applicable Borrower systems (including its practices and performance record), makes an assessment of these systems against core principles and planning elements) and provides an analysis of the acceptability of these systems that takes in consideration the level of environmental and social risks of the Program and the extent to which Borrower systems and practices are aligned with World Bank core principles The assessment of the expected environmental and social effects of activities included in a Program for Results considers the six core principles (and their key planning elements) set by The Bank Guidance. The conclusions of the Environmental and Social System Assessment are presented below according to each core principle. Core Principle 1 Key planning elements: According to this Core Principle, the Program’s E&S management systems (ESMS) shall be designed to (a) promote E&S sustainability in the Program design; (b) avoid, minimize, or mitigate adverse impacts; and (c) promote informed decision-making relating to a Program’s E&S effects. The assessment of the Program’s ESMS shall address questions related with the capacity, commitment and track record of the Borrower’s system to: (a) operate within an adequate legal and regulatory framework to guide Environmental and Social impact assessments, mitigation, management and monitoring at the PforR Program level; and (b) incorporate recognized elements of good practice in Environmental and Social assessment and management, including: (i) early screening of potential impacts, (ii) consideration of strategic, technical, and site alternatives (including the “no action� alternative), (iii) explicit assessment of potential induced, cumulative, and transboundary impacts, (iv) identification of measures to mitigate adverse E&S risks and impacts that cannot be otherwise avoided or minimized, (v) clear articulation of institutional responsibilities and resources to support implementation of plans, and (vi) responsiveness and accountability (through stakeholder consultation, timely dissemination of the PforR information, and responsive GRMs). As noted above, the Program does not entail activities with direct, neither going forward, potentially significant environmental effects. The Program is limited to consultation services, implementation of 38OPNE (https://www.observatoriodopne.org.br/) is an initiative coordinated by Todos Pela Educação, in partnership with 28 organizations linked to Education and specialized in the different stages and modalities of teaching. Todos pela Educação is a non- profit, non-governmental and unconnected with political parties civil society organization financed by private resources, with the mission of contributing to improve Basic Education in Brazil (https://todospelaeducacao.org.br/).Based on public data, OPNE monitors the progress of indicators linked to each one of the PNE’s goal and compliance with the PNE. 31 administrative procedures and management systems, aiming to reduce school dropout, recover learning losses and strengthen local resilience in primary and lower secondary schools. Despite of that, it is important to observe that any activity funded by the Ministry of Education (including joint activities with states and municipalities) have to comply with the environmental and social regulatory framework (besides the complementary local legislation), including the need of environmental and social studies and permitting, in case of activities with potential significant environmental impacts. The Brazilian environmental legislation determines the environmental and social screening and assessment of all activities that may have significant environmental and social impacts.39 The procedures in place follow a proportionality principle, so the requirements vary according to the anticipated risks and significance of impacts. The type, depth, breadth and scope of the environmental and social impact studies that are required in each situation vary according to the anticipated risks and expected impacts. While licensing may not be required for low impact activities, those with significant anticipated risks and impacts require an Environmental Impact Assessment (EIA) and an Environmental Impact Report (RIMA) to guide environmental agencies in authorizing (or not) the proposed development initiatives. The licensing of these type of activities have to undergo public hearings engaging key stakeholders. None of the activities to be funded by the Program pose potential environmental impacts and risks, demanding environmental licensing procedures. Core Principle 2 Key planning elements: According to this Core Principle, the Program’s ESMS shall be designed to avoid, minimize, or mitigate adverse impacts on natural habitats and physical cultural resources resulting from the Program. Program activities that involve the significant conversion or degradation of critical natural habitats or critical physical cultural heritage are not eligible for PforR financing. The assessment of the Program’s ESMS shall address questions related with the capacity, commitment and track record of the Borrower’s system to: (a) identify, and screen for adverse effects on potentially important biodiversity and cultural resource areas and provide adequate measures to avoid, minimize, or mitigate adverse effects; (b) support and promote the protection, conservation, maintenance, and rehabilitation of natural habitats; (c) avoid significant conversion or degradation of critical natural habitats and, if avoidance is not technically feasible, include measures to mitigate or offset the adverse impacts of the PforR Program activities; and (d) take into account potential adverse effects on physical cultural property and provide adequate measures to avoid, minimize, or mitigate such effects. As noted, the Program is limited to implementation of administrative procedures and management systems and small works to provide connectivity to public schools in the North and Northeast region. None of the supported activities are expected to have direct, indirect or induced impacts leading to conversion or degradation of critical natural habitats. No supported activity is expected to promote changes in land use or access to land and/or natural resources that can have significant adverse impacts on the environment too. 39 The main pieces of the regulatory framework are summarily described in Annex 2. 32 The Program will not have potential adverse effects on physical cultural heritage (legally protected cultural heritage areas, archaeological sites and materials, built heritage, natural features with cultural significance or movable cultural heritage. However, it is important to note that Brazil has strict rules and clear procedures with respect to the identification of adverse effects on potentially important biodiversity and cultural resource areas. In both areas, adequate measures to avoid, minimize or mitigate adverse effects are well known and broadly applied. In matters related with biodiversity areas, critical and natural habitats, the Brazilian environmental framework is modern, comprehensive, and innovative in technical terms. Additionally, the Brazilian Federal Constitution of 1988 (FC 1988, Art. 216) recognizes the existence of material and immaterial cultural heritage and establishes three ways for its preservation. Part of the environmental licensing process is supervised by the National Historic and Artistic Heritage Institute (IPHAN), which is responsible for the protection of cultural heritage. IPHAN is always preventively consulted in environmental licensing processes conducted by federal, state or municipal agencies. In sum, the Borrower’s environmental and social system comprises a well-developed regulatory framework and robust institutional capacity with respect to the protection of natural habitats and cultural heritage, supporting the implementation of adequate measures to avoid, minimize or mitigate adverse effects. These would not be so relevant to the Program because the supported activities do not pose potential impacts to natural habitats and/or cultural heritage. Core Principle 3 Key planning elements: According to this Core Principle, the Program’s ESMS shall be designed to protect public and worker safety against the potential risks associated with (a) the construction and/or Program of facilities or other operational practices under the Program; (b) exposure to toxic chemicals, hazardous wastes, and otherwise dangerous materials under the Program; and (c) reconstruction or rehabilitation of infrastructure located in areas prone to natural hazards. Hence the assessment of the Program’s ESMS shall address questions related with the capacity, commitment and track record of the Borrower’s system to: (a) promote adequate community, individual, and worker health, safety, and security through the safe design, construction, Program, and maintenance of Program activities; or, in carrying out activities that may be dependent on existing infrastructure, incorporate safety measures, inspections, or remedial works as appropriate, (b) promote measures to address child and forced labor; (c) promote the use of recognized good practice in the production, management, storage, transport, and disposal of hazardous materials generated under the PforR; (d) promote the use of integrated pest management practices to manage or reduce the adverse impacts of pests or disease vectors, (e) provide training for workers involved in the production, procurement, storage, transport, use, and disposal of hazardous chemicals in accordance with the relevant international guidelines and conventions; and (f) include adequate measures to avoid, minimize, or mitigate community, individual, and worker risks when the PforR Program activities are located in areas prone to natural hazards such as floods, hurricanes, earthquakes, or other severe weather or affected by climate events. The Program will demand civil servants (from the Ministry of Education, state and municipal secretariats) and consultants, who would be directly engaged in its implementation and management. Additionally, the Program will demand consultants to carry out the development and roll-out of Educational 33 Management Systems for State and Municipal Networks (including the provision of training to state and municipal teams) and the preparation of technical studies and events. Results Area 1, 2 and 3 encompass, mostly, technical advice and consultancy services, which shall be conducted, primarily, in regular offices, with no significant risks to health and personal safety. The Program does not include workplace conditions that may expose workers to significant risks to health and personal safety. The Program does not include, either, production, management, storage, transport, and disposal of hazardous and does not promote the use of integrated pest management practices to manage or reduce the adverse impacts of pests or disease vectors. Regulatory Framework Despite of that, it is important to note that Brazil has a comprehensive and mature labor legislation Labor Terms and Working Conditions The Federal Constitution and the Consolidation of Labor Laws (Consolidação das Leis Trabalhistas – CLT) are the main labor and employment rights frameworks and reflect the International Labor Organization core labor and employment standards. CLT sets minimum employment rights related with: (a) Salary - In Brazil, salaries are paid per month or hour. Each year the law or collective bargaining agreement establishes a salary readjustment index usually based on the inflation and monetary restatement calculated for the previous year. The law requires the payment of a 13th salary, which corresponds to one extra monthly salary per year; (b) Working hours - the working hours cannot exceed eight hours per day and 44 hours per week and overtime pay is at least 50% of the employee's regular wage; (c) Resting periods and vacation - Employees are entitled to: (i) a minimum one-hour break for a meal and rest during working hours lasting more than six hours, or a 15-minute break for working hours lasting between four to six hours; (ii) a minimum rest of 11 hours between two working days and a weekly paid rest of 24 hours; (iii) 30 calendar days of vacation (paid on the basis of the employee’s monthly salary plus one-third of the employee's monthly salary as a vacation bonus after working 12 months for the employer.; (d) Severance fund entitlement – The law requires employers to deposit 8% of the employee's salary compensation in the employee's severance fund and if the employee is terminated without cause, the employer must pay a penalty of 40% over the total amount of severance fund deposited during the employment relationship; (e) Leave – There are several types of leave under the law, including paternity leave (five days, extendable to 20 days), maternity leave (120 days, extendable to 180 days), adoption leave, funeral leave, and sick leave, among others. Regarding the sick leave, all employees are entitled to a sick benefit paid by the social security agency if the required absence is longer than 15 days. (f) Worker’s representation and collective bargaining. CLT also set rules against discrimination (providing for the equal treatment of all employees with regards to hiring opportunities, promotions, seniority plans, and equal pay, etc.) and against harassment whether sexual-related or 34 not, or performed by a superior or co-worker. The law also rules with regards to positive discrimination as, in the public sector, the Government is required to reserve part of the public positions to Afro- Brazilians and persons with disabilities and, in the private sector, the law requires the employers to meet a specific quota for young people (to be hired as apprentices – Law 10,097/2000), persons with disabilities and interns (Law 11,788/2008). Occupational Health and Safety All work places in Brazil, despite the size and activity, have to comply with the National OHS Standards (known in Brazil as NRs – Normas Reguladoras). The most important for the activities related to the Program are transcribed below: • NR 4 – Defines the need of Specialized Services in Safety Engineering and Occupational Medicine, aiming to promote the health and protect the integrity of the worker in the place where he/she performs their activities. One of the requirements of this standard is registration of professionals responsible for OHS services (e.g. Occupational Physicians, Engineers and Architects, Occupational Nurses, Occupational Safety Technicians and Occupational Nursing Assistants). • NR 5 -Defines the need of Internal Commission for Accident Prevention (CIPA in Portuguese), which aims to prevent accidents and illnesses arising from work, ensuring life and promoting the health of workers. • NR 6 – Specifies the personal protective equipment (PPE) for different activities, and determines that companies are required to provide the PPEs to their employees. • NR 9 – Defines the requirements for elaboration and implementation of the Environmental Risk Prevention Program (PPRA). • NR 17 – Addresses ergonomics aspects, aiming to mitigate various occupational diseases developed from the exposure of employees to ergonomic risks. Additionally, the national legislation includes bio-safety protocols for protection against COVID-19 transmission, as issued by the Ministry of Health, Secretariat of Labor and Employment Inspection (under the Ministry of Economy). In sum, the nature of the activities related to the Program and the mandatory OHS standards permits to conclude that the Program does not include workplace conditions that expose workers to significant risks to health and personal safety. Forced or Child Labor No activities under any of these results areas is expected to involve the use of forced or child labor. However it is worth to highlight that one of the key aspects of the labor regulatory system in Brazil is the banishment of forced labor and child labor. Furthermore, Brazil has a robust legislation and good track record on the enforcement of the regulatory framework prohibiting forced or child labor. The country has also made relevant progress on combating both forced and child labor in the last decades. The Federal Constitution and the Labor Code prohibit child labor and the minimum age for work is 16 years. Under the Brazilian legislation, the minimum age for work in Brazil is 16 (art. 403 of Labor Code) Minimum age for hazardous work is 18 (art. 2 of the Hazardous Work List, the TIP List instituted by Federal Decree 6481/2008). From the age of 14, the teenager can be an apprentice. An apprentice is the 35 adolescent who studies and works, receiving, at the same time, professional training. The apprentices must attend regular school and be enrolled and attending a professional technical education institution in partnership with the company. The Law of Apprenticeship (Law No. 10097/2000, Federal Decree 5598/2005) determines that all medium and large companies in the country hire a number of apprentices equivalent to a minimum of 5% and a maximum of 15% of their staff. Between 16 and 18 years old, the adolescent cannot work at night, or in dangerous and unhealthy activities as identified in the TIP List, which is divided into work harmful to health and work harmful to morality and list 93 activities as the worst forms of work.40 According to data from the National Household Sample Survey (PNAD-Contínua) on Child and Adolescent Work, in 2019, there were nearly 1.8 million children and adolescents aged five to 17 years in a situation of child labor. Between 2004 and 2019, the number of children and adolescents in this situation felt 66.0 percent. They still represented 4.5 % of the population (40.1 million) in this age group. The greatest concentration of child labor was in the age group between 14 and 17 years old, representing 78.7% of the total. The age group from five to 13 years represented 21.3% of children exploited by child labor. The North region counted for 17.6% of these children and adolescent and the Northeast region for 48.2% of them. However, it shall be highlighted that agriculture and domestic work were the main activities involving child labor, whereas the public services and administration (the sectors involved in this Program) have no registers of the presence of child labor (https://livredetrabalhoinfantil.org.br/conteudos- formativos/mapa-do-trabalho-infantil/). Forced labor is penalized by the Penal Code, art. 149 (penalties of 2 to 8 years in prison). According to data from the Radar of the Sub-secretariat of Labor Inspection (SIT), linked to the Special Secretariat for Welfare and Labor (SEPRT) of the Ministry of Economy, between 1995 and 2020, more than 55 thousand people were freed from working conditions similar to slavery. Freed workers were mostly internal or external migrants, who have left their homes for the region of agricultural expansion or for large urban centers, in search of new opportunities or attracted by false promises. The majority of released workers were men, between 18 and 44 years of age and 33% illiterate. Cattle raising, civil construction and clothing are the sectors with the most cases of forced labor in the country (https://www.ilo.org/brasilia/temas/trabalho-escravo/lang--pt/index.htm). Sexual Harassment, Abuse and Exploitation The Brazilian legislation (Law 8,429/92 – the Administrative Misconduct Law) includes prohibitions against sexual harassment, sexual exploitation and sexual abuse. The penalties in such situations involve the loss of the position, the dismissal and the loss of retirement benefits. Furthermore, the Penal Code (Art 215-A and 216-A) define sexual abuse (i.e., the act of practicing against someone and without their consent a libidinous act with the objective of satisfying their own lust or that of a third party) and sexual harassment (i.e., the act of embarrassing someone with the intention of obtaining sexual advantage or favor, the agent prevailing in his hierarchical superior condition or ancestry 40 The TIP List includes – among others – works in: spraying, handling and application of pesticides; þ In excavations, underground, quarries, mines, underground and open pit mines; direction and operation of large electrical machines and equipment; with contact with spoiled animal waste, glands, viscera, blood, bones, hides, animal hair or waste; ceramic industries; furniture industries; garbage collection, selection and processing; services provided in any way in brothels, nightclubs, bars, cabarets, nightclubs, massage parlors, saunas, motels, obscene showrooms or venues, gambling rooms and similar establishments; retail sale of alcoholic beverages; civil and heavy construction, including construction, restoration, renovation and demolition; and in mangroves and mudflats. 36 inherent to the exercise of a job, position or function) as felonies. The penalty imposed to sexual harassment is of imprisonment from 1 (one) to 2 (two) years and is increased by up to a third if the victim is under 18 (eighteen) years of age. The penalty ruled for sexual abuse is of imprisonment from 1 (one) to 5 (five) years, if the act does not constitute a more serious crime. Enforcement Capacity In addition to its robust legislation, Brazil has sound institutional capacity to ensure its enforcement throughout the country. Enforcement of labor rules and OHS standards is conducted by the Labor Regional Offices (Delegacias Regionais do Trabalho - DRT), responding to the Ministry of Labor and Social Security (Provisional Measure 1,058/2021).41 The enforcement of labor and employment rules (as well as the social security legislation) is usually made through: a) the inspection of labor and social security authorities at companies; and/or b) the analysis of documents submitted via the internet (by means of a virtual platform referred to as "eSocial"). These inspections carried out by the labor agency can be executed randomly or result from a complaint (by employees, former employees, or third parties). Lawsuits may also become a source for potential investigations. If any irregularities are found, the authorities may apply fines and administrative sanctions against the employer. The structure of the Labor Courts encompasses: a) federal courts at the local level (normally, at a municipality level – Varas do Trabalho); b) federal courts at the state level (Brazil currently has 24 appeal labor courts – Tribunais Regionais do Trabalho); and c) the Superior Labor Court (Tribunal Superior do Trabalho), which is the high court for labor and employment disputes. Under the terms of Complementary Law 75/1993,42 the Labor Prosecutor Office (Ministério Público do Trabalho - MPT) is also responsible for overseeing compliance with labor legislation when there is public interest, seeking to regularize and mediate relations between employees and employers. which has powers to protect the collective rights of employees. As a rule, the MPT may: a) negotiate a Term of Conduct Adjustment (Termo de Ajustamento de Conduta or "TAC") by which the employer agrees to comply with certain obligations, being subjected to penalties; b) file a public civil action to have the enforcement of such obligations; or c) act as an arbitrator or mediator in collective bargaining agreements, or supervise the rights of employers and employees (custos legis) in labor and employment claims, and strike actions. The MPT is centered in Brasília-DF and divided into 24 Regional Attorneys, including Municipal Labor Attorneys’ Offices.43 Core Principle 4 Key planning elements: According to this Core Principle, the Program’s ESMS shall manage land acquisition and loss of access to natural resources in a way that avoids or minimizes displacement and assists affected people in improving, or at the minimum restoring, their livelihoods and living standards. Whenever land acquisition or loss of access to natural resources is required under a Program for Results, the assessment of the Program’s ESMS shall address questions related with the capacity, commitment and track record of the Borrower’s system to: (a) avoid or minimize land acquisition and related adverse impacts; (b) 41 http://www.planalto.gov.br/ccivil_03/_Ato2019-2022/2021/Mpv/mpv1058.htm. 42 http://www.planalto.gov.br/ccivil_03/leis/lcp/lcp75.htm. 43 https://mpt.mp.br/pgt/mpt-nos-estados. 37 identify and address economic or social impacts caused by land acquisition or loss of access to natural resources, including those affecting people who may lack full legal rights to resources they use or occupy, (c) provide compensation sufficient to purchase replacement assets of equivalent value and to meet any necessary transitional expenses, paid before taking land or restricting access; (d) provide supplemental livelihood improvement or restoration measures if taking of land causes loss of income-generating opportunity (e.g., loss of crop production or employment); and (e) restore or replace public infrastructure and community services that may be adversely affected by the Program. Include measures in order for land acquisition and related activities to be planned and implemented with appropriate disclosure of information, consultation, and informed participation of those affected. Brazil does not have specific legislation on involuntary displacement and the country’s legislation on land expropriation through the exercise of the State’s power of eminent domain44 and restrictions on land uses are: • The Brazilian law recognizes both land ownership rights and rights and claims of adverse possession. Adverse possession is recognized under different legal timeframes according to the location (urban or rural areas) and purpose of the occupation of the land as well as the socioeconomic profile of the occupant and it is not be recognized for the same person more than once.45 • In the expropriation process, Brazil acknowledges the rights of people who (i) have formal legal rights (property); (ii) can gain ownership of property by adverse possession of it beyond the lapse of a certain period of time (“usucapione�), with the exception of claims over public lands; and (iii) have made improvements in public lands they encroached (they are entitled for compensation of these improvements, but not for the land). • The legislation requires fair and prior compensation of expropriated physical and economic assets.46 The amount of compensation for physical assets is not based on replacement costs. This value is determined based on technical standards set by the Brazilian Association of Technical Standards (Associação Brasileira de Normas Técnicas, ABNT), which follows international standards and methodologies.47 • With regards to economic assets, all productive inputs and facilities required by different types of economic activities in the primary, secondary and tertiary sectors are assessed and compensated. The compensation also covers for foregone profits, intangible economic assets (“fundo de comércio�)48 and transitional assistance for both business owners and workers. For rural 44 Essentially, the Brazilian Federal Constitution (Art 22, III), Civil Code (Federal Law 10406/2002), Federal Decree 3365/1941 and Federal Laws 4132/1962 and 13867/2019. 45 Civil Code (Federal Law 10406/2002), articles 1,237-1,243. 46 Civil Code (Law 4,132/1962) and Federal Decree-law 3,365/1941 47 ABNT has issued and updated a series of norms ruling the process of asset valuation and covering land and economic assets in both urban and rural areas. These norms also define the most adequate methodologies according to the type of asset and its location. The most commonly used methodology for reaching the amount of fair compensation is the Direct Comparative Market Data Method, which aims to find out the potential "market value" of the expropriated land. This methodology takes into consideration several factors (location, type of construction, state of conservation) relies on real estate market researches and applies a depreciation factor. Nevertheless, according to the Brazilian norms, the depreciation factor ranges from zero to 1. Arithmetically, when the evaluator applies a depreciation factor equal to 1, this factor does not depreciate the value reached for the compensation at market value. 48 These intangible assets comprise, among others, the expenses necessary to remove the goods, acquire new commercial points, remodeling and adapting the new location for the activity; disassembly, transport, and installation of equipment at the new location; deactivation of the original location; eventual performance of compromised contracts (fines, inconvenience costs, and 38 productive activities, compensation is based on the characteristics of the land and its location, the improvements on the land, the productive uses of the land, the machinery, and technology available. • The Brazilian regulatory framework related with restriction of access to natural resources within legally designated parks and protected areas has been set by the Brazilian System of Protected Areas (Sistema Nacional de Unidades de Conservação – SNUC, established by Law 9985/2000).49 Under Integral Protection Protected Areas, the law rules that traditional communities inside the areas shall be compensated for the existing improvements and duly reallocated by the Government. However, until resettlement of traditional communities is possible (for which preference is given to land-based resettlement strategies for displaced persons whose livelihoods are land-based), specific rules and actions shall be established to make the presence of traditionally resident populations compatible with the objectives of the protected area, without prejudice to ways of life, sources of subsistence and places of residence of these populations. It is ensured their participation in the elaboration of the referred norms and actions and in the definition of the length of their stay and its conditions (Law 9985/2000, art. 47). • Furthermore, traditional communities – whose existence is based on sustainable systems of exploitation of natural resources, developed over generations and adapted to local ecological conditions – do not need to be relocated when Sustainable Use Protected Areas are created. Indeed, these Sustainable Use Protected Areas are created with the primary objectives of protecting the livelihoods and culture of these populations while ensuring the sustainable use of the areas’ natural resources. Land and natural resource use within these protected areas are decided with the participation of the involved traditional communities.50 • Preventative resettlement from areas at-risk of disaster is ruled by federal legislation (Law 10,257/2001, Law 12,340/2010, Law 12,608/2012 and Law 12,983/2014). It is based on the guideline of broad community participation and the key role of municipalities. Municipal attributions include: (i) identification and mapping of areas at-risk of disaster; (ii) monitoring and control of these areas preventing new occupations; (iii) inspection of buildings located in these areas and, whenever needed, carry out the evacuation of the population from areas of high risk or endangered buildings; (iv) provide adequate temporary shelter for the displaced population; and (v) prepare and implement the Civil Protection and Defense Municipal Contingency Plan. • The legislation requires that municipalities adopt measures to reduce the risk of disaster among settlements located in areas susceptible to the occurrence of high impact landslides, sudden floods or related geological or hydrological processes. These measures include the execution of a contingency plan and safety works and, when necessary, the removal of buildings and the resettlement of occupants in a safe place. Removal can only take place upon on-site surveys and technical reports evidencing the risks of the occupation for the physical integrity of the occupants others) and maintenance of activities during the reallocation of assets (rent of additional spaces, outsourcing of processes and others). 49 SNUC encompasses two types of protected areas: (i) integral protection protected areas and (ii) sustainable-use protected areas (National Forests, Extractive Reserves, and Sustainable Development Reserves). The primary objective of the former is to preserve nature, being allowed only the indirect use of their natural resources; whereas the basic objective of the latter is to make nature conservation compatible with the sustainable use of part of their natural resources by human populations. 50 Resettling traditional and vulnerable populations entails a number of additional precautions. The territories traditionally occupied by indigenous peoples and quilombolas are basically protected by the Brazilian Federal Constitution (article 129, V; article 216; article 231; and article 68 of the Act of the Temporary Constitutional Provisions). Resettlement of indigenous peoples requires the involvement of the Indigenous National Foundation (FUNAI). 39 or third parties, prior notification to the occupants including information on the alternatives offered by the government to ensure their housing rights, and adoption of measures to prevent reoccupation of the area. The regulatory framework of the country on these issues presents a few shortcomings when compared to the World Bank’s principles on land acquisition, restrictions on land use and involuntary resettlement. These gaps are: (a) Compensation of adverse possession under conditions in which usucapione rights are recognizable because there are different understandings in the Brazilian jurisprudence about the amount of compensation that must be paid for land. Although there is no provision under the legislation, the jurisprudence has ordinarily set the compensation of the land under this condition at 60 percent of the value of land under full ownership rights. This jurisprudence is not fully aligned with the entitlements envisaged by the Environmental and Social Standard 5 – Land Acquisition, Restrictions on Land Use and Involuntary Resettlement for those who do not have formal legal rights to land at the time the census begins but have a claim to such land or assets-- provided that such claims are recognized under the laws of the country). (b) The Brazilian legislation has no provision with regards to resettlement assistance for tenants and co-inhabitant families. (c) The Brazilian legislation does not make a difference on entitlements to compensation between persons who encroach on the area before or after a cut-off date. (d) There is no provision for the establishment of a grievance mechanism to deal exclusively with claims on involuntary resettlement in the Brazilian legislation. (e) Transaction costs are not included in the value of the compensation paid for land and actual profit gains from expropriation processes are subject to taxation, although this can be deferred under certain circumstances.51 Meanwhile, it has to be highlighted that this core principle has no relevance for the proposed Program as its results areas do not involve construction works, do not require land acquisition and do not impose restrictions on land use. Core Principle 5 Key planning elements: According to this Core Principle, the Program’s ESMS shall give due consideration to the cultural appropriateness of, and equitable access to, Program benefits, giving special attention to the rights and interests of Indigenous Peoples, and to the needs or concerns of vulnerable groups. The assessment shall address questions related with the capacity, commitment and track record of the Borrower’s system to: (a) undertake (as needed) meaningful consultations if the Indigenous Peoples are potentially affected (positively or negatively), to determine whether there is broad community support for the PforR Program activities; (b) ensure that Indigenous Peoples can participate in devising opportunities to benefit from exploitation of customary resources and indigenous knowledge, the latter (indigenous knowledge) to include the consent of Indigenous Peoples; and (c) give attention to groups vulnerable to hardship or discrimination, including, as relevant, the poor, the disabled, women and 51 Federal Decree 9,580/2018, art 504. 40 children, the elderly, ethnic minorities or other marginalized groups; and if necessary, take special measures to promote equitable access to PforR Program benefits. Overall, in Brazil, School Education for students from distinct and vulnerable social and cultural groups is governed in its political-pedagogical practices and actions by the principles of: (a) the right to equality, freedom, diversity and plurality; (b) the respect and recognition of history and culture; (c) the protection and appreciation of manifestations of cultural, ethnic and racial diversity without prejudice of origin, race, sex, color, creed, age and any other forms of discrimination; and (d) the social participation of local communities in school management and decision-making processes. Indigenous Peoples The activities supported under the selected Results Areas are not expected to have adverse impacts on land and natural resources subject to traditional ownership or under customary use or occupation, or to cause relocation of Indigenous Peoples from land and natural resources that are subject to traditional ownership or under customary use or occupation, or to have significant impacts on Indigenous Peoples cultural heritage that is material to the identity and/or cultural, ceremonial or spiritual aspects of the affected communities. The last Brazilian Demographic Census (2010) counted 896,917 Indigenous Peoples in the country. Some estimations consider the current Indigenous Peoples population may reach 1.3 million people. The Program will be focused on the North and Northeast regions of Brazil, where in 2010 lived most of the Indigenous Peoples of the country: 38.2% in the North region and 25.9% the Northeast region. As previously shown (Graph 3, above), indigenous schools face huge infrastructure challenges in the North and Northeast regions as well as across the country. According to the 2019 Basic Education School Census, 906 indigenous schools (27.1 percent of the indigenous schools in the country) did not operate in school buildings; 1,320 (39.5 percent) schools did not have drinkable water; 1,090 (32.6%) schools did not have electricity; 1,695 (50.7 percent) schools did not have sanitary sewage; and 2,651 (79.3 percent) schools did not have access to internet. Indigenous schools in the North and Northeast regions faced the worst conditions of Program in the country. 100% 90% 94% 91% 91% 90% 80% 70% 73% 71% 69% 67% 60% 59% 50% 53% 49% 40% 37% 30% 20% 27% 21% 10% 8% 0% proper school with electricity with drinkable with sanitary with internet buildings water sewage North Northeast Brazil Graph 4 - Indigenous Schools according with Available Infrastructure 41 Source: First Indigenous Peoples School Education Nacional Plan (PNEEI 1) INEP 2019 Elementary Education Census The Brazilian Federal Constitution of 1988 (FC 1988) recognizes the social organization, customs, languages, beliefs and traditions of indigenous peoples and their rights to occupy their traditional territories. Indigenous Lands are owned by the federal government and the right of Indigenous Peoples to lands of traditional occupation is an original right.52 It states that indigenous lands are to be permanently occupied by indigenous peoples and provides for the exclusive enjoyment of indigenous peoples in relation to their lands and their economic exploitation, the existing soils, rivers and lakes situated therein and safeguarding the right to their traditional social organization and culture. FC 1988 also establishes that the exploitation of water resources (including energy potentials), research and mining of mineral wealth within Indigenous Lands can only be carried out with the authorization of the National Congress, after hearing the affected communities.53 Brazil has also signed all major international agreements and treaties regarding the rights of indigenous peoples, including “The International Labor Organization (ILO) Convention No.169 on Indigenous Peoples and Tribal Populations� and “The United Nations Declaration of Indigenous Peoples’ Rights�.54 The Brazilian legislation stipulates that – for all on-the-ground interventions, legislative and administrative measures that may directly affect Indigenous Peoples – federal, state and municipal governments shall ensure that studies are carried out in consultation with Indigenous Peoples to identify environmental, social, cultural and spiritual impacts on them. The National Indigenous Foundation (FUNAI) is responsible for all technical referrals related with Indigenous Peoples in the Term of References for the elaboration of Environmental Impact Assessments (EIA), has to be heard on impacts and interventions within Indigenous Lands and is required to hold public hearings with potentially affected Indigenous Peoples during the licensing process.55 FUNAI analyzes the EIA and issues technical opinions evaluating whether the enterprise is viable or not and recommending actions that must be performed to mitigate negative impacts and optimize positive impacts on indigenous communities. When there are impacts on indigenous communities and their lands, a Basic Environmental Plan (PBA) for indigenous communities – detailing the programs for each identified impact – has to be developed in consultation with the affected indigenous communities and technically analyzed by FUNAI.56 Indigenous Peoples school education is under the responsibility of the Ministry of Education (in partnership with state and municipal secretariats) and is based on the right of indigenous peoples to differentiated school education. The current regulatory framework57 requires the offer of bilingual and 52 Therefore, the administrative procedure for the demarcation of indigenous lands is of a merely declaratory nature as indigenous lands are not created by a constitutive act, but simply recognized based on technical and legal requirements, according to FC 1988 (Art. 231). 53 FC 1988, Art 231, paragraph 3. 54 ILO Convention 169 was made effective through Legislative Decree No. 143/2003 and Federal Decree 5,051/04. 55 FUNAI’s manifestation in the scope of the environmental licensing process of works that directly or indirectly affect lands and indigenous communities is required and ruled by FC 1988 (articles 225 and 231), Laws 5,371/67 and 6,001/73, CONAMA Resolution 237/97, Inter-Ministerial Ordinance 060/2015 and Normative Instruction 02/2015. FUNAI's manifestation is generally required in all three phases of the environmental licensing process. 56 Traditional knowledge associated with the genetic heritage held by indigenous peoples (as well as of traditional communities and traditional small farmers) is also legally protected. The law assures the right of these social groups to participate in national decision-making on matters related to the conservation and sustainable use of their associated traditional knowledge; access to it is conditional upon obtaining free, prior and informed consent; and Indigenous peoples are entitled to a share of the benefits from the economic exploitation of their associated traditional knowledge (Law 13.123/2015 – The Biodiversity Law). 57 LDB (Law 9,394/1996) and subsequent legislation as well as the National Curriculum Guidelines for School Education Indigenous in Basic Education (CNE/CEB Resolution nº 5/2012). 42 intercultural school education to indigenous Peoples with the goals of: (a) providing them with the opportunities of recovering their historical memories, reasserting their ethnic identities and appreciating their languages and knowledge; (b) guaranteeing their access to information, technical and scientific knowledge of the national society and other indigenous and non-indigenous societies; (c) strengthening their socio-cultural practices and the mother tongues; (d) maintaining programs for training specialized personnel, intended for school education in indigenous communities; (e) developing specific curricula and programs, including cultural content corresponding to the respective communities; and, (f) systematically preparing and publishing specific and differentiated teaching material. The regulatory framework emphasizes that indigenous school education must be planned and implemented in consultation with the indigenous communities. These provision have been consolidated through the establishment of the mandatory National Curriculum Guidelines for Indigenous School Education and is carried out through the organization of ethno- educational territories – regardless of political and administrative divisions of the country, the ethno- educational territories respect their collective attachment to geographically distinct habitats and their historically rooted networks of intersocial, political and economic relationships and have been a demand of the Brazilian Indigenous Peoples themselves. The main principles followed in the organization of the Indigenous Peoples school education refer to: (a) specificity, bilingualism and multilingualism; (b) respect for community organization and interculturality; respect for traditional knowledge, forms of knowledge production, teaching and learning processes; (c) organization of school activities in accordance respecting the flow of economic, social, cultural and religious activities; (d) community participation and free, prior and informed consultation for the definition of the political-pedagogical plan, the curriculum and content, the calendar and school hours, the organization and management model; and, (e) the need for demand, initiative or consent from the interested community (respecting its forms of representation) for the creation of any Indigenous Peoples schools. The activities supported by the PforR Component of this Program would not depart from these principles. Indigenous Peoples have been very active with regards to Indigenous Peoples’ school education and the last decade registered important advances, although some relevant challenges remain as highlighted by the Fifth National Forum of Indigenous School Education – virtually held on October 20th, 2020.58 These challenges include: (a) budget cuts for public policies for teacher training and production of differentiated teaching materials for indigenous schools; (b) failures to fully comply with the curricular guidelines, national plans and goals of Indigenous School Education, already endorsed by the indigenous movement and current legislation (for instance, the National Education Plan 2014-2024); (c) the denial of spaces of representation of Indigenous Peoples in the National Education Council and other deliberative bodies; and (d) the continued offer of Indigenous School Education in inadequate situations, with precarious and even non-existent infrastructure (numerous cases of schools without buildings, with insufficient classrooms, without libraries, laboratories and adequate furniture and no internet access, which intensifies the precariousness of indigenous school education) [http://fneei.org/2020/11/03/carta-do-v- forum-nacional-de-educacao-escolar-indigena/]. Among the advances made, it shall be emphasized: 58The Fifth Forum convened indigenous educators – from 20 Brazilian States and 50 indigenous peoples – as well as members of governmental organizations and civil society organizations [http://fneei.org/2020/11/03/carta-do-v-forum-nacional-de- educacao-escolar-indigena/]. 43 • The I National Conference on Indigenous School Education was convened in 2009. • Decree 6,861/2009 provides for Indigenous School Education and defines its organization in Ethnoeducational Territories.59 • The National Commission for Indigenous School Education was created, made up of representatives from government, civil society and indigenous peoples was created in 2010. • Law 12,416/2011 provided for the provision of higher education for indigenous peoples. • The National Curriculum Guidelines for Indigenous School Education in Basic Education were published in 2012 (Resolution CNE/CEB nº 5). • the National Program for Ethnoeducational Territories (PNTEE) was created in 2013. • The Permanence Scholarship Program was also created and the Indigenous Knowledge at School Action was instituted and regulated in the same year. • The National Forum of Indigenous School Education (FNEEI) was created by indigenous teachers in 2015. • The 1st National Conference on Indigenous Policy was held by the Federal Government, in which the most debated topic was Indigenous School Education. • The II National Conference on Indigenous School Education (II CONEEI) was convened in 2018. It was the highest instance of consultation with representatives of indigenous peoples for the construction of propositions that should guide educational policies and programs for Indigenous School Education in all governmental spheres. It was the result of the articulations carried out by the indigenous movement, the National Commission for Indigenous School Education (CNEEI) and other forums of indigenous leaders and teachers in the country. • The I National Indigenous People School Education Plan (I PNEEI 2020-2023) was formulated in 2019 in partnership with the members of CNEI with the objective of supporting and implementing the twenty-five deliberations of the II National Conference on Indigenous School Education (II CONEEI). The I PNEEI was debated during 2019 in seven public hearings across the country’s regions.60 Its premises are the advances and challenges of the Indigenous School Education policy of the last decade as debated 59 The Ethnoeducational Territories are defined by the Ministry of Education, after hearing the indigenous communities involved, the federative units involved, the National Commission for Indigenous School Education, the State Councils of Indigenous School Education and the National Commission for Indigenous Policy - CNPI. Each ethnoeducational territory comprises, regardless of the political-administrative division of the country, indigenous lands, even if discontinuous, occupied by indigenous peoples who maintain inter-society relationships characterized by common social and historical roots, political and economic relationships, linguistic affiliations, shared cultural values and practices. Each ethnoeducational territory must have an action plan for indigenous school education prepared by a commission made up of a representative of the Ministry of Education, a representative of FUNAI, a representative of each indigenous people covered by the ethnoeducational territory or its entity and a representative of each indigenist civil society organization with a notable performance in indigenous school education within the scope of the ethnoeducational territory. The Secretaries of Education of the States, the Federal District and Municipalities covered by the ethnoeducational territory will be mandatorily invited to integrate the commission. The action plan must contain: (i) assessment of the ethnoeducational territory with description of the people, population, territorial scope, cultural and linguistic aspects and other relevant information; (ii) assessment of the educational demands of indigenous peoples; (iii) planning of actions to meet educational demands; and (iv) description of the attributions and responsibilities of each participant with regard to indigenous school education, especially regarding the construction of indigenous schools, the training and hiring of indigenous teachers and other education professionals, the production of pedagogical material, and indigenous school meals [Decree 6,861/2009]. 60 The consultation process for the I PNEEI comprised: (a) a launching meeting with CNEEI members by videoconference (April 2019); (b) regional public hearings in Manaus (May 2019), Belo Horizonte (June 2019), João Pessoa (July 2019), Salvador (August 2019), Belém (September 2019), Chapecó (October 2019) and Campo Grande (November 2019); and (c) a closing meeting with CNEEI meeting in Brasília (December 2019). The public hearings counted with the participation of: (i)Indigenous Peoples teachers, 44 in the II CONEEI, as well as the 1988 Federal Constitution, ILO Convention 169 (ratified and promulgated in Brazil by Legislative Decree 143/2002, Decree 5,051/2004, and Decree 10,088/2019), the National Education Guidelines and Bases (Law 9,394/96 – LDB), the National Curriculum Guidelines for Indigenous School Education in Basic Education; the National Curricular Common Base (Resolution CNE/CEB nº 5/2012); the National Education Plan 2014-2024 (Law 13,005/2014), the State and Municipal Education Plans and other normative guidelines. The I PNEEI has the following objectives: to implement the proposals deliberated in the II CONEEI; strengthen the regime of collaboration between federated entities, social participation, transparency of actions and management by results, constituting an instrument for monitoring, evaluation and social control of the EEI. The I PNEEI establishes seven guidelines for the Indigenous Peoples School Education (EEI) – namely: (a) Organization of the EEI with the participation of Indigenous Peoples, observing their territoriality and respecting their needs and specificities; (b) valorization of Indigenous Peoples cultures and their ethnic diversities; (c) Strengthening of sociocultural practices and the mother tongue of each indigenous community; (d) provision of training programs for education professionals who work in indigenous communities; (e) development of curricula that value the Indigenous Peoples cultures; (f) elaboration, publication and distribution of specific, intercultural and bilingual pedagogical materials; and (g) support the affirmation of ethnic identities and societal projects defined autonomously by each indigenous people. The I PNEEI is organized in seven strategic axes and comprises a set of 77 actions addressing key shortcomings faced by in the implementation of the Indigenous Peoples school education. The I PNEEI shall be carried out until 2023. The strategic axes, their justification and goals are summarily described in the subsequent matrix: 1st Strategic Axis: Management of Indigenous School Education and Regulation of National Curriculum Guidelines for Indigenous School Education in Basic Education: Actions included in this axis aim to address two issues: (a) the insufficiency and inadequacy of spaces for management and representation of indigenous school education in the education systems and (b) the lack of autonomy of indigenous schools to offer a specific and differentiated education. According to the 2019 School Census, 280 indigenous schools were not regularized by their education systems and 698 had their regulatory processes in progress. They account for 29 percent of the 3,342 indigenous schools open in the country. The actions included in this axis aim at the regulation and autonomy of indigenous schools to offer a specific and differentiated education as well as at the participatory management of these schools in accordance with the National Curriculum Guidelines for Indigenous School Education in Basic Education. The expected outcome of the actions included under this strategic axis refer to the regulation of the National Guidelines in Education Councils and organized and participatory management of the EEI. It is expected to be achieved by supporting the management of Indigenous schools education in education networks and by diagnosing, monitoring and regulating the implementation of Resolution CEB/CNE 5/2012 by municipal and state students and school principals; (ii) representatives of indigenous and indigenist organizations; (iii) representatives of state and municipal education systems; (iv) representatives of Graduation Schools; (v) the National Commission for Indigenous School Education; (vi) the National Council of Education; (vii) State and Municipal Boards of Education; (vii) the Ministry of Education; (viii) the National Indigenous Peoples Foundation (Funai); (ix) the Federal Public Ministry; (x) the National Council of Secretaries of Education (CONSED); (xi) the National Union of Municipal Education Directors (UNDIME); (xii) the National Union of Municipal Education Councils (UNCME); and (xiii) the National Forum of State Education Councils (FNCEE), among other bodies that work with Indigenous School Education in the respective states of the federation. 45 Councils, especially regarding the creation of the indigenous teacher careers in education networks, the accreditation of indigenous schools and the elaboration and recognition of Pedagogical Political Projects (PPP). 2nd Strategic Axis: Ethnoeducational Territories (TEE): This axis concerns the reasons for the low pace of implementation of the TEE policy, despite the fact that 25 of the 41 projected territories have met and agreed. The main causes of this situation are: (a) MEC's difficulty in fulfilling the role of coordinator of the TEES policy; (b) difficulties in holding the semiannual meetings of the management committee in each TEE and in guaranteeing the commitment of managers in relation to the actions agreed in the action plan given the “detachment� between the planning and financing mechanisms of actions. The expected outcome of the actions included under this strategic axis refer to the Program of the intergovernmental collaboration regime in accordance with the imperative of consultation and the territoriality of Indigenous Peoples. It is expected to be achieved by: (a) supporting and holding the meetings of the TEE Committees; (b) supporting and developing Action Plans in order to guarantee the commitment of local managers; and (c) monitoring the implementation of Ethnoeducational territories. 3rd Strategic Axis: Infrastructure: Actions included in this axis address the needs to adapt the infrastructure of indigenous schools to the specificities of the EEI, considering the existence of school buildings, access to electricity, internet, sanitation, school transport, equipment, and culturally adequate meals that are necessary for the proper functioning of school units. These shortcomings are seen as a consequence of the lack of management capacity of the entities and the bureaucratic obstacles of programs that do not contemplate the specificities of the different indigenous realities, and the lack of prior consultation for the construction of schools. The expected outcome of the actions included under this strategic axis refer to the provision of adequate infrastructure for the Indigenous Schools Education, which is expected to be achieved by: mapping and overcoming the bureaucratic obstacles to infrastructure adequacy as well as by increase the capacity of the education networks for infrastructure management. 4th Strategic Axis: Pedagogical practices and teaching material: This Axis address issues related to the adequacy of pedagogical practices and materials to the specificities of Indigenous School Education. To this end, it deals with the lack and inadequacy of Political-Pedagogical Projects (PPP) in indigenous schools, the inadequacy of intercultural curriculum matrices and the faulty production, publication, distribution and dissemination of intercultural, bilingual, multilingual and specific to the different stages and teaching modalities in these schools (as required by Resolution CNE/CEB 5/2012). According to data from the 2018 School Census, 1,546 (46%) of all indigenous schools do not use specific teaching materials. The expected outcome of the actions included under this strategic axis refer to the implementation of culturally adequate pedagogical practices and the provision of specific pedagogical material for the Indigenous School education. It is expected to be achieved through the update of the Indigenous Curriculum Reference and the state curricula (according to the BNCC) and by supporting the production, publication and distribution of intercultural, bilingual, multilingual and specific teaching and learning materials for the Indigenous School Education. 5th Strategic Axis: Valuing and training indigenous teachers: Although required by Resolution CNE/CEB 5/2012 and Resolution CNE/CP 1/ 2015 that establish the National Curricular Guidelines for the Training of Indigenous Teachers in Higher Education and High School courses, there has not been established an indigenous teacher career in public education networks and the i offer of initial and continuous training of indigenous teachers remains insufficient. The lack of regulation of the above-mentioned resolutions and the low capacity of Higher Education Institutions to offer training for indigenous teachers have been pointed out as main causes of these shortcomings. 46 The 2019 School Census recorded the presence of 22,542 teachers at the indigenous school education, among whom 45.1 percent had a graduation degree and only 19.4 percent had permanent tenure, evidencing that the demand for specific higher education training was still high. The expected outcome of the actions included under this strategic axis refer to the valorization and specific training of indigenous teachers, which is expected to be achieved by supporting the offer of initial and continued training for indigenous teachers as well as the creation of an indigenous teacher career in public schools. 6th Strategic Axis: Offer of Indigenous School Education and Higher Education: The diagnostic of the Indigenous School Education showed a low offer of culturally adequate early childhood education, secondary education, professional education, youth and adult education and higher education to Indigenous Peoples. This situation is due to several causes, including: the lack of reference materials and practices for indigenous early childhood education; the low supply of vocational education and youth and adult education for indigenous peoples; the insufficient number of teachers trained to teach in the final years of elementary school and high school; and the insufficiency of access and permanence policies in higher education aimed at Indigenous Peoples. The expected outcome of the actions included under this strategic axis refer to the offer of specific and culturally adequate of early childhood education, secondary education, professional education, youth and adult education, and graduate education to Indigenous Peoples. This outcome is expected to be achieved, by (a) supporting (i) the provision of Early Childhood Education in indigenous communities, (ii) the expansion of secondary education in indigenous schools, (iii) the expansion of the offer of youth and adult as well as vocational education, and (iv) policies for access and permanence of Indigenous Peoples in graduate schools as well as by monitor the supply and organization of the Indigenous School Education. 7th Strategic Axis: Indigenous School Education Assessment System: Indigenous school education lacks an evaluation system that meets the specificities of indigenous communities, guaranteeing them the recognition of their own norms and legal systems (as required by Resolution CNE/CEB 5/2012) due to the lack of intercultural indicators in the INEP School Census, the inexistence of a specific Indigenous School Census and the inexistence of criteria that consider the specificities of Indigenous School education in the Basic Education Assessment System (SAEB). The expected outcome of the actions included under this strategic axis refer to the development and implementation of an specific and intercultural evaluation system of the Indigenous School Education Countryside and Quilombola School Education Federal Decree 6,040/2007 established the National Policy for the Sustainable Development of Traditional Peoples and Communities. This policy incorporates – among others – the principles of: (i) recognition and consolidation of the rights of traditional peoples and communities; (ii) promotion of the necessary means for the effective participation of Traditional Peoples and Communities in instances of social control and in decision-making processes related to their rights and interests; (iii) eradication of all forms of discrimination, including the fight against religious intolerance; and (iv) preservation of cultural rights, the exercise of community practices, cultural memory and racial and ethnic identity. It aims to promote the sustainable development of Traditional Peoples and Communities, with emphasis on the recognition, strengthening and guarantee of their territorial, social, environmental, economic and cultural rights, with respect and appreciation for their identity, their forms organization and their institutions. Among its specific goals, it shall be highlighted the guarantees given to traditional peoples and communities with regards to: (a) the territories and natural resources that they traditionally use for their physical, cultural and economic reproduction; (b) to quality health care services that are adequate to their 47 socio-cultural characteristics, needs and demands, with an emphasis on the concepts and practices of traditional medicine; (c) access to public social policies and the participation of representatives of traditional peoples and communities in social control instances; and (d) access to productive inclusion with the promotion of sustainable technologies, respecting the social organization system of traditional peoples and communities, valuing local natural resources and traditional practices, knowledge and technologies. The National Commission for the Sustainable Development of Traditional Peoples and Communities, the Sustainable Development Plans for Traditional Peoples and Communities, the regional and local forums, and the Multiannual Plan are the main instruments of implementation of this policy. The operational guidelines, norms and principles for elementary education in countryside schools were defined by Resolution CNE/CED 1/2002 and Resolution CNE/CEB 2/2008. Countryside education serves rural populations with diverse livelihoods, comprising family farmers, extractive communities, artisanal fishery communities, riverside dwellers, settlers and campers of the Agrarian Reform, quilombolas, caiçaras, Indigenous Peoples and others. The rules of this modality of elementary education require the definition of pedagogical proposals that value cultural diversity and the processes of interaction and transformation of rural communities, democratic management, access to scientific and technological advances as well as respective contributions to the improvement of living conditions. They also prioritize the offer of pre-school and elementary school within the local communities where the children live whenever feasible. The organization and Program of rural schools shall respect the differences between the populations served in terms of their economic activity, their lifestyle, their culture and their traditions as well as the calendar of productive activities. Further operational guidelines, norms and principles for quilombola education in the elementary education were defined by CNE Resolution 8/2012. Quilombola schools are intended to serve rural and urban quilombola populations in their most varied forms of cultural, social, political and economic production.61 Quilombola education must be offered by educational establishments located in communities recognized by the responsible public agencies as quilombolas as well as by educational establishments close to these communities that receive a significant number of students from quilombola territories. It must guarantee students the right to appropriate learning about traditional knowledge and its forms of production in order to contribute to its recognition, appreciation and continuity. It is organized primarily based on: a) the collective memory; b) the reminiscent languages; c) the landmarks of civilization; d) cultural practices; e) the technologies and forms of work production; f) collections and oral repertoires; g) the festivities, uses, traditions and other elements that make up the cultural heritage of quilombola communities throughout the country; h) their territoriality. Nowadays and according to Decree 10.195/2019, the Secretary of Specialized Modalities of Education and Brazilian Cultural Traditions – SEMESP under the Ministry of Education is the department responsible for formulating and programming public policies that promote the right to education of rural populations, indigenous peoples, quilombolas, populations in a situation of itinerancy and traditional peoples and communities, in all the levels, stages and teaching modalities. It is also responsible for supporting and monitoring the implementation of national education guidelines regarding countryside education, indigenous school education, quilombola school education, education 61Quilombola population are understood as ethnic-racial groups defined by self-attribution, with their own historical trajectory and presumption of black ancestry related to resistance to historical oppression for the right to land and territory, which hold the necessary environmental resources for their maintenance and the historical reminiscences that allow them to perpetuate their memory and cultural traditions. 48 for ethnic-racial relations, school education for populations in a situation of itinerancy and traditional communities. Among its other attributions, SEMESP must (a) promote and support actions to improve school management and infrastructure, teacher training and the development of specific teaching and teaching materials for rural education, indigenous school education, quilombola school education and school education for populations in situations of roaming and traditional communities, (b) propose intersectoral actions that contribute to the access and permanence in school of children, adolescents and young people, and (c) promote and support intersectoral actions to value Brazilian cultural traditions, as a constitutive element of the educational process, in partnership with the education systems. Within SEMESP the coordination of educational polices for the modalities of Countryside Education, Indigenous School Education and Quilombola School Education is an attribution of the General Coordination of Indigenous, Countryside and Quilombola Education and Cultural Traditions. At the North and Northeast region, Indigenous School Education State Policies have been approved and are under implementation – following the national rules set by CNE Resolution – in all 16 states in the North and Northeast region. In nine of these states, the State Secretariat of Education hold in their organizational structure dedicated departments for Indigenous Peoples School Education. Indigenous Teachers organizations are found in four states, whereas Indigenous Peoples School Education Councils, Commissions or Committees or other instances for Indigenous Peoples representation are organized in the seven states. Measures to Promote Equitable Access to The Benefits of The Program Targeting mechanisms embedded in the Program aim to ensure the social groups most vulnerable to hardship or discrimination have fair and equitable access to its benefits. Thus, the Program focus on the most vulnerable and backward regions of the country, where learning outcomes are far behind national averages: the North and Northeast region. The Program will address shortcomings faced by municipal and state school networks that mostly enroll students from poor families to reduce learning inequalities and dropout. It encompasses interventions that prioritize students that receive conditional cash transfers from federal flagship programs (which have poverty as their main eligibility criteria) and students enrolled in Indigenous and quilombola schools. These students are often and mostly deprived of access to internet and other digital technologies. The Program also includes (as part of Component 2) a series of assessments of drivers of school dropout, which will embrace gender and vulnerability sensitive lenses. Last, but not least, the interventions proposed will be implemented in compliance with a regulatory framework that requires respect to cultural and social diversity and full participation of interested communities in school management. Be this as it may, the Program is expected to take into consideration the cultural appropriateness of their interventions and the equitable access to its benefits, giving special attention to the rights and interests of Indigenous Peoples and to the needs or concerns of vulnerable groups. 49 Core Principle 6 Key planning elements: According to this Core Principle, the Program’s ESMS shall contribute to avoid exacerbating social conflict, especially in fragile states, post-conflict areas, or areas subject to territorial disputes. The ESSA shall address questions related with the capacity, commitment and track record of the Borrower’s system to consider conflict risks, including distributional equity and cultural sensitivities. Considering the concerns embedded in Core Principle 6, it shall be highlighted that the activities supported under the two Results Areas are focused on the two poorest regions of the country (the North and Northeast) and initially offered to all educational facilities of the public municipal and state networks. Following this targeting strategy, these activities are expected to benefit the most children and adolescents of families from the lowest income levels in the country, indigenous and quilombola students, increasing their educational opportunities and promoting social inclusion. The focus on the North and Northeast regions is also fully justified by the challenges elementary school education face in these two regions. As mentioned, it is estimated that nearly 1.4 million children and adolescents were out of school in 2020 and about half of this group lives in the North and Northeast. In 2010, the average dropout rate in the final years of elementary school was 7.7% in the Northeast and 7.2% in the North, well above the Southeast region (4.5%). In 2017, the two regions continued to show high dropout rates: 5.7% and 5.8%, respectively. Covid-19 tends to intensify this problem as students are more disengaged with their studies because of remote education, reduced direct link with the school, increased housework load and pressures to enter the labor market. The empirical evidence shows that school dropout, poverty and marginalization are closely linked. The unavailability of quality educational services and the lack of perception of future returns also lead students to early work and low educational levels. Evidences show that school dropout rates vary according to socioeconomic characteristics and that different individuals are driven by different factors to drop out of school. The most frequent motivations to drop out school refer to the immediate need to contribute to family income, the inability to afford school attendance, early pregnancy, lack of connection of contents with the interests of students, or the predominance of curricula and pedagogical practices that do not include the perspective of historically excluded groups. Thus, the statistical data shows that the group at greatest risk of evasion is composed by low-income youth, mostly Afro-Brazilians, who are forced into the labor market at an early age or who become pregnant already in adolescence. According to PNAD 2019 data, Afro-Brazilians and indigenous students aged 4 to 17 years corresponded to 71.3% of the out-of- school children and adolescents. Discrimination is also a relevant factor often associated with the school dropout of Afro-Brazilian, ethnic minority, LGBTQIAP+ and disabled students. Properly addressing these drivers of school dropout can avoid marginalization of social groups. As it has also been shown (when accessed the context risk factors faced by the Program), digital gaps that are most prominent in the North and Northeast regions of the country mostly hamper the learning opportunities of students from the public schools network, those from families at the lower ranks of the income scale, those from Afro-Brazilian families, those from the countryside, quilombola and indigenous communities that are remotely located. The digital divide not only contribute to social exclusion of these students, but also may hamper the achievement of the expected social benefits of the Program as it may lead to social exclusion of vulnerable and disadvantaged social groups. Good targeting of the supported interventions can, therefore, contribute to reduce marginalization of disadvantaged and vulnerable students and it is aimed through (a) the focus of the Program in the North and Northeast regions of the 50 country, (b) the investments made on the expansion of the access to broadband internet at public schools and on the promotion of the use of digital technology for pedagogical purposes in elementary education and (c) the prioritization of students registered in CadÚnico or enrolled at indigenous and quilombola schools as a criteria of eligibility to receive tablets and SIM cards. Thus, the Program can contribute to reduce both (i) the digital divide and its deleterious effects on education as well as (ii) social exclusion and marginalization of disadvantaged and vulnerable social groups. Finally, it shall be highlighted that the Program will not be implemented in post-conflict zones or areas subject to territorial or jurisdictional dispute. The Program is not expect to exacerbate underlying tensions or civil strife by reinforcing inequities or grievances too. It will not in any way prejudice one party’s claims in land or territorial disputes and there is no history of unrest in the area of the Program or the sectors it embraces. The legal and regulatory framework bestows certainty about the jurisdiction of the implementing agencies and adequately addresses potential environmental and social risks and impacts of complex projects. The enforcement of this framework is strong. The Program agencies have shown to be open to discussions with the Bank and consultations with stakeholders. Therefore, marginalization of social groups or exacerbation of conflicts within or among social groups are not expected. On the contrary, Program’s activities may contribute to reduce inequalities on educational opportunities and achievements and promote social inclusion. 4. Stakeholder Consultations In preparation of this report, the task team is carrying out consultations with key stakeholders through a virtual process – using an electronic form to be filled in a digital platform – that started in February 22nd, 2022 and will end on March 11th, 2022. The link for the electronic form (https://ee.kobotoolbox.org/x/rdE2ZiiS) was sent by e-mail together with a presentation of the scope of activities under the Results Areas to representatives of CNE, CONSED, UNDIME, State and Municipal Secretariats of Education, the Academy and Civil Society Organizations working in the education sector. The electronic form addressed questions on: (i) The process of consultation of the governmental programs supported under the Results Areas and the Program itself; (ii) the environmental and social risks that can be associated to the activities supported under the Results Areas; (iii) the capacity of the Borrower’s Environmental and Social System Management to deal with the environmental and social risks that have been identified; (iv) the available channels for stakeholder engagement; (v) the potential risk that the Program would have with regards the topics addressed in the Core Principles (adverse impacts on: natural habitats and physical cultural resources; the safety of public and workers; land acquisition, loss of access to natural resources and involuntary displacement; equitable access to Program benefits of Indigenous Peoples and other vulnerable groups; and, exacerbation of social conflicts); and (vi) the recommended measures to prevent, minimize and mitigate the environmental and social risk that have been identified. 51 The final version of the ESSA will incorporate the views and recommendations expressed by these stakeholders and will be disclosed for consultation in the World Bank website as well as through the same digital platform. 5. Overall Findings of The ESSA Overall Findings on Environmental and Social Risks of the Program Overall, the environmental and social risks of the Program are rated as Moderate. The likely social effects of the Program tend to be mostly positive. Environmental effects are negligible as the Program does not include activities with direct, neither going forward, potentially significant environmental effects. The Program is limited to consultation services, implementation of administrative procedures and management systems, aiming to reduce school dropout, recover learning losses and strengthen local resilience in primary and lower secondary schools. The Program faces two main contextual risk factors: the “digital divide� and the disparity of institutional capacities found among the municipalities in the Northeast and North regions. On the one hand, the available data shows that the digital divide has contributed to marginalize poor students from public schools particularly in the North and Northeast regions – reducing their educational opportunities (particularly under the pandemic). Activities supported by the Program have been designed to reduce these digital gaps, improving the access of public schools and poor students (including those enrolled in Indigenous Peoples and quilombola schools) to connectivity and digital technologies. The digital divide also raises concerns about potential social exclusion risks as disadvantaged and vulnerable social groups could not have access to information about the Program and, consequently, could be deprived of get a fair share of its benefits. This risk will be mitigated by the adoption of a robust strategy of stakeholder engagement relying not only on virtual channels of communication, but also on the articulation of the broad stakeholders’ networks of UNDIME and CONSED, which reach all municipalities in the country. On the other, the disparity on the institutional capacities among the beneficiary municipalities in the North and Northeast regions add a critical context-risk factor to the complex institutional arrangement needed for the implementation of the Program. The implementation of activities under all Results Areas will involve agencies at the three levels of government (federal, state and municipal) in the 16 states of the two most backward regions of the country (North and Northeast). The Federal level agencies have well-established management systems and technical capacity. However, the capacity of the State Departments of Education and the Municipal Education Secretariats vary significantly and, in the North and Northeast regions, the poor institutional capacity for the management of the education system has been pointed out as one of the major reasons behind poor learning achievements. This risk will be mitigated by the implementation of many activities envisaged under Component 2: the work of the 16 decentralized technical teams that will provide training, guidelines and information for municipalities on application for resources and management of PDDE, ProInfância and PAR4 programs and the development, roll-out and implementation of an Integrated Education Management System, which aims at incorporating MEC’s current systems in a single platform, reducing inefficiencies and costs with maintenance and training. 52 The Program’s reputational and political risks are low. Brazil has a comprehensive regulatory framework on environment, labor, rights of users of public services and the organization of the public education system. Under the responsibility of federal agencies, the enforcement of the regulatory framework on labor and rights of users of public services is strong across the country. The enforcement of environmental rules vary widely under state and municipal authorities. In many places of the targeted regions – and often due to their remote locations – the institutional capacity of the state and local agencies is weaker than the capacity of the federal agencies, and some have a weak track record. Nevertheless, the Program does not include activities that are considered controversial and these activities are well-aligned with the National Education Plan. Stakeholders have mostly supported initiatives to recover from school dropouts and learning losses related to the COVID-19 as well as on the expansion and improvement of connectivity accessible to public schools and their most vulnerable students. The expected benefits of the Program for society – and its most disadvantaged and vulnerable social groups – far exceed these moderate potential risks and adverse effects. On the Adequacy of the Environmental and Social Management System The main conclusion drawn by the assessment with respect to the adequacy of the Program’s Environmental Management System (EMS) is that the legal framework is robust and adequately address potential environmental and social risks and impacts of complex projects. The assessment also founds that there is significant certainty about the authority and jurisdiction of the responsible governmental agencies, which enjoys stability, strong oversight by judicial and extra-judicial bodies (including mass media and public opinion). Taking in consideration the activities to be supported by the Program, the first conclusion is that the Program does not entail activities with direct, neither going forward, potentially significant environmental effects. Despite of that, any activity funded by the Ministry of Education (including joint activities with states and municipalities) have to comply with the robust environmental and social regulatory framework of the country. With regards to Core Principle 1, the conclusion of the assessment is that Program does not include activities with direct, neither going forward, potentially significant environmental effects. The Program is limited to consultation services, implementation of administrative procedures and management systems, among others, with negligible environmental implications. Additionally, the all activities funded by the Ministry of Education (including joint activities with states and municipalities) have to comply with the environmental and social regulatory framework, including the need of environmental and social studies and permitting, in case of activities with potential significant environmental impacts. With regards to Core Principle 2, the conclusion is that none of the supported activities are expected to: (a) have direct, indirect or induced impacts leading to conversion or degradation of critical natural habitats; (b) promote changes in land use or access to land and/or natural resources that can have significant adverse impacts on the environment too; or (c) have potential adverse effects on physical cultural heritage (legally protected cultural heritage areas, archaeological sites and materials, built heritage, natural features with cultural significance or movable cultural heritage). In addition, Brazil has strict rules and clear procedures with respect to the identification of adverse effects on potentially important biodiversity and cultural resource areas. In both areas, adequate measures to avoid, minimize or mitigate adverse effects are well known and broadly applied. In matters related with biodiversity areas, 53 critical and natural habitats, the Brazilian environmental framework is modern, comprehensive, and innovative in technical terms. With regards to Core Principle 3, the conclusion is that the Program does not include workplace conditions that may expose workers to significant risks to health and personal safety. It does not include, either, production, management, storage, transport, and disposal of hazardous and does not promote the use of integrated pest management practices to manage or reduce the adverse impacts of pests or disease vectors. In addition, Brazil’s regulatory framework on labor and working conditions as well as on Occupational Health and Safety aspects are well-aligned with international standards and best practices. The enforcement of this regulatory framework is under the responsibility of federal agencies that are well staffed and funded. In accordance with this legislation, the country made relevant progresses in the last decades in the combat against child and forced labor and in addressing SEA/SH issues in the workplace. With regards to Core Principle 4, the overall conclusion is that the supported activities are not expected to have significant direct adverse impacts related with land acquisition and involuntary resettlement, which minimizes the shortcomings found in the Brazilian regulatory framework in comparison with the principles that guide World Bank’s Programs in matters related with land acquisition through expropriation or other compulsory procedures, restriction on land use and access and involuntary resettlement. With regards to Core Principle 5, the main conclusion is that the supported activities are not expected to cause relocation of Indigenous Peoples or have adverse impacts on (a) land and natural resources subject to traditional ownership or under customary use or occupation, or (b) Indigenous Knowledge, or (c) on Indigenous Peoples cultural heritage that is material to their ethnic identity, or (d) cultural, ceremonial, or spiritual aspects of their lives. Additionally, the indigenous peoples school education system follows principles and guidelines and encompasses requirements aimed at ensuring: (i) meaningful consultation with and participation of Indigenous Peoples (as well as other disadvantaged and vulnerable social groups) in devising opportunities to benefit from the education system (overall) and Program (in particular) as well as (ii) appropriate attention to groups vulnerable to hardship or discrimination. However, it has been highlighted that due to the digital divide and the remoteness of some communities, disadvantaged and vulnerable groups (including Indigenous Peoples) may face constraints to have access to information technologies and this situation could hamper their access to the expected benefits of the Program. Some measures will be taken to mitigate this risk. Finally, with regards to Core Principle 6, the assessment concludes that the Program is not expected to lead to marginalization of social groups, the exacerbation of conflicts among social groups, or social unrest. On the contrary, the activities supported by the Program are focused on the most deprived regions of the country, have a huge social inclusiveness potential and are expected to bring positive distributive effects for children and adolescents from the bottom of the society who comprise the majority among those enrolled in the public schools – as well as students from culturally distinct groups (Indigenous Peoples and quilombolas). However, due to the context-risk factors of the “digital divide� and how it adversely affects the poorest and most disadvantaged and vulnerable social groups (including Indigenous Peoples and quilombola communities) and the potentially low capacity of many beneficiary municipalities in the North and Northeast regions, some measures will be taken to ensure the adequate management of environmental and social risks associated with the Program. These measures are presented in the next chapter. 54 6. Action Plan Considering the findings of the ESSA, this Action Plan aims to enhance the Borrower’s system of environmental and social risks management and includes two types of actions: required and recommended. it sets the actions and measures to be taken for adequate management of environmental and social risks associated with the Program. These actions are classified as required and recommended. 55 Issues addressed Actions / Measures to be taken Type of Action Institutional Timeline Verification Responsibility Methodology Overall management of Engage a Senior Environmental and Required. PMU – Within 30 days Senior Environmental environmental and social Social Specialist in the PMU, with a SEB/MEC. after Program and Social Specialist risks potentially associated social background and experience on effectiveness and hired/assigned to the with the Program. stakeholder engagement processes, maintained PMU. to oversee the implementation of throughout the Program. Program implementation. The disparity of the Develop and distribute among key Recommended. PMU – Within the first Digital Guide produced institutional capacities found stakeholders a Digital Guide on SEB/MEC. year after and disseminated among the municipalities in Environmental and Social Risk Program the North and Northeast Management Guidelines to identify effectiveness regions for management of and address associated with the environmental and social provision of educational services in risks. the North and Northeast regions. Potential lack of access to Adoption of a robust strategy of Required. PMU (with Beginning at the Information disclosure information on Program stakeholder engagement relying not support of first quarter after materials developed activities by disadvantaged, only on virtual channels of UNDIME, project and disseminated. vulnerable and remotely communication, but also on printed CONSED and effectiveness and located communities materials and, particularly, on the State and maintained (including Indigenous articulation of the broad Municipal throughout Peoples and Quilombola stakeholders’ networks of UNDIME Education project communities) due to the and CONSED, which reach all Secretariats). implementation. “digital divide� and municipalities in the country. This potentially leading to their strategy aims to spread information exclusion from the expected on the activities supported by the benefits of the Program. Program to all Municipal Education Secretariats, Municipal Education Councils, public schools and school councils located each municipality. 56 Issues addressed Actions / Measures to be taken Type of Action Institutional Timeline Verification Responsibility Methodology Include in the Terms of Reference of Recommended. PMU (with Preparation of the Terms of Reference the technical assistance activity support of Terms of addressing the drivers (Component 2) of the “Market study UNDIME, Reference of the leading to lack of access on structure and connectivity� the CONSED and above-mentioned to connectivity in need to pay special attention to State and study remotely located obstacles faced by Indigenous Municipal communities in the Peoples and other remotely located Education North and Northeast communities to have access to Secretariats). regions. internet. Include in the Terms of Reference of Recommended PMU (with Preparation of the Terms of Reference the technical assistance activity support of Terms of addressing the drivers (Component 2) of the longitudinal UNDIME, Reference of the leading to lack of access study on the reasons for dropping CONSED and above-mentioned to connectivity in out and the school dropout State and study remotely located questionnaires will help to identify Municipal communities in the and understand better the Education North and Northeast underlying causes of school dropout Secretariats). regions. that will support activities under Results Area 1 the consideration of the causal factors of digital exclusion of Indigenous Schools. Include the Terms of Reference of Recommended PMU (with Preparation of the Terms of Reference the technical assistance activities support of Terms of addressing the drivers (Component 2) to (a) define menu of UNDIME, Reference of the leading to lack of access school policies to reduce school CONSED and above-mentioned to connectivity in dropouts and (b) develop school State and study remotely located dropout protocols that are expected Municipal communities in the to guide the work of local teams Education North and Northeast approaching households, families, or Secretariats). regions. students (who dropped out because of gender-based violence and teenage pregnancy, among other drivers) the consideration of principles of non-discrimination and 57 Issues addressed Actions / Measures to be taken Type of Action Institutional Timeline Verification Responsibility Methodology respect for Indigenous Peoples’ traditions and cultural systems. Potential lack of access by Broad dissemination of information Required. PMU (with Beginning at the Operation of the some stakeholders to the on the Program’s Grievance support of first quarter after Grievance Mechanism Program’s channels to raise Mechanism. UNDIME, project semi-annually reported concerns and grievances CONSED and effectiveness and to the Bank – according related to the environmental State and maintained to key performance and social performance of Municipal throughout indicators (number of the Program Education project concerns/grievances Secretariats). implementation raised, answered and solved within the established timelines) and disaggregating for different socio- demographic characteristics of the complainers as they are informed. 58