TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ILBANK Turkey Climate and Disaster Resilient Cities Project (P173025) [Draft] ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) February 2022 1|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. İller Bankasi Anonim Şirketi (hereafter known as ILBANK), with the guarantee of the Ministry of Treasury and Finance (MoTF) of the Republic of Turkey, will implement the Turkey Urban Resilience Project (P173025) (the Project) with the involvement of the cities of Izmir, Istanbul, Manisa, Tekirdağ and Kahramanmaraş. The World Bank (hereinafter the Bank) has agreed to provide financing for the Project. 2. ILBANK will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. ILBANK will also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as Environmental and Social Management Framework (ESMF), Environmental and Social Impact Assessments (ESIAs), Environmental and Social Management Plans (ESMPs), Resettlement Framework (RF), Resettlement Plans (RPs), Stakeholder Engagement Plans (SEPs), Labor Management Procedures (LMP) and the timelines specified in those E&S documents. 4. ILBANK is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the cities referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Bank by ILBANK as required by the ESCP and the conditions of the legal agreement, and the Bank will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank and ILBANK, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, ILBANK will agree to the changes with the Bank and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between ILBANK and the Bank. ILBANK will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, ILBANK will provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include risks and impacts on vulnerable groups and communities, environment, livelihoods, community and occupational health and safety, labor conditions and gender-based violence. 2|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY MONITORING AND REPORTING REGULAR REPORTING Prepare and submit to the Bank regular monitoring reports on the environmental, social, health and safety (ESHS) performance of the Project, including but not Semi-annually (every 6 months) throughout limited to the implementation of the ESCP, status of preparation and the Project implementation. implementation of environmental and social (E&S) documents required under the ESCP, stakeholder engagement activities, performance of the grievance ILBANK Project Management Unit A mechanism(s). (PMU) Ensure frequency and content of monitoring reports is detailed in Project Preparation of POM will be considered as Operations Manual (POM) and implemented accordingly. an effectiveness condition. INCIDENTS AND ACCIDENTS Promptly notify the Bank of any incident or accident related to the Project which has, a significant adverse effect on the environment, the affected communities, the ILBANK shall obligate municipalities and public or workers such as Occupational Health and Safety (OHS) accidents or that utilities to report details of any significant result in threatening community health and safety, including health and safety environmental or social incidents (e.g. serious injuries and road accidents and sexual exploitation and abuse/sexual fatalities, lost time incidents, harassment (SEA/SH). environmental spills, etc.) within 3 business days. Subsequently, as per the Bank’s request and in line with the Bank’s Environmental ILBANK PMU in coordination with and Social Incidence Response Toolkit (ESIRT), prepare a report providing sufficient ILBANK shall obligate municipalities and B the Project Implementation Units detail regarding the incident or accident, finding of the Root Cause Analysis (RCA), utilities to submit an incident report, (PIUs), as relevant. indicating immediate measures taken or that are planned to be taken to address it, including RCA, precautions and compensation paid, and any information provided by any contractor and compensation measures taken within 30 supervising entity/consultant, as appropriate. Propose any measures to prevent its business days. recurrence. ILBANK shall forward the incident report to Include in bidding documents of contractors that prompt notification accident and the Bank immediately upon receipt from incidents remain inclusive under contractor’s ESMP. Ensure and monitor that an municipalities and utilities. incident register at all construction sites are kept by the contractors throughout the Project life. 3|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY CONTRACTORS QUARTERLY REPORTS Obligate contractors to provide to Municipalities’/Utilities’ PIUs quarterly progress C reports for all sub-project sites and monitor quality of reporting throughout the Throughout Project implementation. ILBANK PMU; PIUs duration of works. Include reporting requirements in bidding documents of contractors. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS ORGANIZATIONAL STRUCTURE Establish and maintain an organizational structure with qualified staff and resources to support management and monitoring of E&S risks, acceptable to the Bank, as follows: o ILBANK shall establish and maintain a Project Management Unit (PMU) under the International Relations Department of ILBANK to manage and coordinate the entire Project with qualified and experienced personnel and resources to An organizational structure of PMU shall be support the management of ESHS risks by assigning: established prior to Loan Effectiveness. All o one Environmental Specialist to address environmental risks and impacts designated ILBANK staff will serve for the identified under the Environmental and Social Impact Assessment (ESIA) duration of the Project. reports, Environmental and Social Management Plans (ESMPs) and sub- Any additional staff for key functions shall 1.1 management plans; be employed 2 months before ILBANK PMU; PIUs o one Social Expert to address social risks and impacts under the commencement of any sub-project (if Environmental and Social Impact Assessment (ESIA) reports, needed). Environmental and Social Management Plans (ESMPs), land acquisition, Municipalities to establish their PIUs no and labor issues, including stakeholder engagement and grievance redress; later than 30 days after the sub-loan and agreement is signed. o one Occupational Health and Safety (OHS) specialist to address OHS risks and impacts under the Environmental and Social Impact Assessment (ESIA) reports, Environmental and Social Management Plans (ESMPs) and sub- management plans. Ensure that above-mentioned staff remain on assigned duty until the end of Project implementation. 4|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY The municipalities shall each establish and maintain Project Implementation Units (PIUs). The PIU staff will be responsible for full compliance with the ESF and relevant instruments. All PIUs which will have civil works will include qualified staff and resources to support the management of E&S risks by appointing one social specialist, one environmental specialist and one OHS specialist. Obligate municipalities/utilities to assign E&S, ESHS and SE/Grievance Mechanism (GM) focal points for management of sub-projects’ E&S risks. This obligation to be included as condition of the subloan agreements with municipalities/utilities. Obligate contractors to assign E&S, ESHS and SE/GM focal points for sub-projects’ E&S risk management by including this requirement in the bidding documents for works. Maintain the structure of the complete PIUs throughout Project implementation. ENVIRONMENTAL AND SOCIAL ASSESSMENT Screen any proposed sub-project in accordance with the ESMF prepared for the Project and thereafter prepare, disclose, adopt, and implement sub-project specific Environmental and Social Impact Assessments (ESIAs), Environmental and Social Sub-project site specific ESIA and/or ESMPs, Management Plans (ESMPs), ESMP Checklists, Stakeholder Engagement Plans RPs and SEPs shall be prepared and (SEPs), Resettlement Plans (RPs), and other instruments as necessary, including disclosed before the commencement of ILBANK PMU to supervise and Waste Management Plans (WMP), Hazardous Waste Management Plan, tendering works for the relevant activities. monitor preparation, disclosure Community Health and Safety Plan (CHSP), Traffic Management Plans (TMP), ESMPs shall be included in bidding and implementation of ESIAs, Occupational Health and Safety Management Plans (OHSMP), Chance Find documents, and thereafter shall be ESMPs, SEPs, and RPs. 1.2 Procedure, and any other instruments required in a manner acceptable to the Bank, implemented throughout the respective as relevant. sub-project implementation. PIUs to be responsible for preparation, disclosure and Include provisions for safeguards tasks and instruments in tender documents and High risk sub-projects are excluded from implementation of site specific E&S contract requirements so that detailed design tasks reflect phasing for activities project financing. instruments. such as the ESMPs, ESIAs, SEPs and RPs. ESMS will be established by Loan Ensure that the requirements of the ESF are integrated into ToRs to be prepared for Effectiveness. each feasibility study. ILBANK will adopt Environmental and Social Management System (ESMS) for its overall IFI financed portfolio (per item 9.1 below). 5|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY MANAGEMENT TOOLS AND INSTRUMENTS ESMF – implemented throughout Project ILBANK PMU, to be responsible for Implement the ESMF for the Project, in a manner acceptable to the Bank. implementation. the preparation of Project-level instruments (ESMF, SEP, RF, LMP) Screen any proposed subproject in accordance with the ESMF prepared for the ESIAs and ESMPs – delivered and disclosed and for supervising and monitoring Project, and, thereafter, draft, adopt, and implement the subproject ESMPs, and prior to tendering of works for each sub- the preparation, disclosure, and ESIAs as required, in a manner acceptable to the Bank. project. implementation of subproject Implement Resettlement Framework (RF), Stakeholder Engagement Plan (SEP), and SEPs– delivered and disclosed before specific instruments. Labor Management Procedure (LMP) for the Project, as required, in a manner commencement of any civil works.RP and The PIUs to be responsible for the 1.3 Ex-Post Social Audit – after Loan acceptable to the Bank. development, disclosure, and Effectiveness and before commencement of implementation of sub-project Prepare, disclose and implement site-specific ESIAs/ESMPs, SEPs, Resettlement any civil works. specific environmental and social Plan (RP) for the sub-projects, as required, in a manner acceptable to the Bank. plans and instruments for the subprojects. Ensure ILBANK ESMS, approved by the Bank, is fully operational and implemented ILBANK will implement the Bank throughout the life cycle of the project. ESMS – implemented throughout Project approved ESMS for its financing implementation operations. MANAGEMENT OF CONTRACTORS Incorporate the requirements of the approved ESMPs, LMP, and other relevant E&S documents and/or plans into the environmental, social, health and safety Prior to signing of contract with contractors. specifications of works. Thereafter, ensure that the contractors and supervising firms comply with the ESHS specifications of their respective contracts. 1.4 Supervise and monitor contractors’ ESHS ILBANK PMU; PIUs performance throughout Project Obligate contractors and supervision consultants that E&S, ESHS and SE/GM focal implementation. points are assigned for managing E&S risks of sub-projects through including this Supervision consultants should monitor obligation into bidding documents. Ensure contractors maintain these staff regularly on behalf of the PIUs. throughout the life of their contracts. PIUs to monitor monthly, and ILBANK PMU to monitor semi-annually. ESS 2: LABOR AND WORKING CONDITIONS 6|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY LABOR MANAGEMENT PROCEDURES Maintain and implement Project LMP consistent with national legislation and ESS2, and ensure that Project workers are aware of it and it is accessible to them. Include Project LMP into bidding documents of contractors. Obligate awarded ILBANK PMU shall be responsible contractors to adopt Project LMP (including Code of Conduct). Implement and monitor implementation of 2.1 and shall cause the PIUs and their LMPs throughout Project implementation. Obligate contractors to take responsibility for adherence to LMP by their contractors to carry out. subcontractors. Obligate contractors to carry out due diligence procedure to identify if there are significant risks that the suppliers are exploiting child or forced labor or exposing worker to serious safety issues GRIEVANCE MECHANISM FOR PROJECT WORKERS Grievance mechanism operational within Adjust, maintain, and operate an accessible GM for Project workers as described in 60 days following Loan Effectiveness and the LMP, in line with national labour law and consistent with ESS2. ILBANK PMU shall be responsible maintained throughout Project 2.2 The ILBANK PMU and the PIUs shall ensure that Project Workers using this GM shall implementation. and shall cause the PIUs and their not be subject to any form of discrimination or repression by employers and that it contractors to carry out. Report semi-annually through Project includes measures to deal with SEA/SH complaints. Progress Reports OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES After Loan effectiveness, and before ILBANK PMU shall be responsible commencement of any civil works, 2.3 Prepare, adopt, and implement OHS measures specified in ESIAs, ESMPs and LMP. and shall cause the PIUs and their maintained throughout Project contractors to carry out. implementation ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT WASTE MANAGEMENT PLAN Preparation and disclosure of sub-project Develop, adopt, and implement Waste Management Plans, if required, under the specific Environmental and Social ILBANK PMU, to be responsible for sub-project-specific ESIAs and ESMPs to be prepared under action 1.2 above. Assessment (ESA) documents (ESIAs and supervising and monitoring the 3.1 ESMPs) prior to tendering of works for each preparation, disclosure, and sub-project, and implementation implementation of subproject throughout the period of Project specific instruments. implementation. 7|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY The PIUs to be responsible for the development, disclosure, and implementation of sub-project specific environmental and social plans and instruments for the subprojects. RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT ILBANK PMU, shall be responsible Resource efficiency and pollution prevention and management shall be covered for supervising and monitoring the under the ESMPs to be prepared under action 1.2 above and might include the Preparation and disclosure of sub-project preparation, disclosure, and development of site-specific sub-management plans, such as Resource specific ESA documents (ESIAs and ESMPs) implementation of subproject Management Plan, as relevant. prior to tendering of works for each sub- specific instruments. 3.2 project The PIUs to be responsible for the Application of mitigation measures development, disclosure, and contained in the ESIAs and ESMPs implementation of sub-project throughout Project implementation. specific environmental and social plans and instruments for the subprojects ESS 4: COMMUNITY HEALTH AND SAFETY TRAFFIC AND ROAD SAFETY Preparation and disclosure, of sub-project Adopt and implement measures and actions to assess and manage traffic and road specific ESIAs and ESMPs prior to tendering ILBANK PMU shall be responsible 4.1 safety risks through Traffic Management Plans as required in the sub-project of works for each sub-project. and shall cause the PIUs to carry specific ESIAs and ESMPs to be developed under action 1.2 above. out. Ensuring adherence to ESIAs and ESMPs throughout Project implementation. COMMUNITY HEALTH AND SAFETY As part of the ESMF specified in 1.2 above, prepare, adopt, and implement measures to assess and manage specific risks and impacts to the community arising Preparation ESIAs/ ESMPs prior to tendering ILBANK PMU shall be responsible from Project activities that may generate from behaviour of Project workers; risk of 4.2 of works for each sub-project, and and shall cause the PIUs to carry labor influx, Gender Based Violence (GBV)/ Sexual Exploitation and Abuse-Sexual implementation throughout the period of out. Harassment (SEA-SH) risks , emergency situations, limitations on land, potential for Project implementation. community exposure to communicable diseases, dust and noise; and include these measures in the ESIAs and ESMPs to be prepared in accordance with the ESMF, in a manner acceptable to the Bank. 8|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY Include these measures in the ESIAs, ESMPs/ESMP checklists to be prepared in accordance with the ESMF, in form and substance acceptable to the Bank. SECURITY PERSONNEL Assess, develop and implement measures and actions in ESIAs and ESMPs to Prior to commencement of civil works and ILBANK PMU shall be responsible 4.3 manage any risks of human security in Project-affected communities and to Project implemented throughout Project and shall cause the PIUs to carry workers that could arise from the use of security personnel. Measures to be implementation. out. consistent with the requirements of ESS4, in a manner acceptable to the Bank. COMMUNITY TRAINING AND SENSITIZATION The ILBANK shall develop awareness activities as part of the ESMF and the ESIA ILBANK PMU shall be responsible 4.4 Prior to the commencement of civil works and shall cause the PIUs and their reports, ESMP/ESMP checklists for the local populations surrounding the work sites and throughout Project implementation contractors to carry out. in order to raise their awareness of the risks and mitigate the impacts of the Project activities. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT RESETTLEMENT PLANS Implement, the Resettlement Framework (RF) for the Project, in a manner acceptable to the Bank. RPs and Ex-Post Social Audit shall be Prepare, adopt, and implement Resettlement Plans (RPs) or, where necessary and submitted to the Bank for approval and with agreement by the Bank, Ex-Post Social Audits in accordance with ESS 5 and ILBANK PMU shall be responsible once approved, the RPs shall be 5.1 consistent with the requirements of the RF that has been prepared for the Project, and shall cause the PIUs to carry implemented before commencement of and thereafter adopt and implement the RPs if needed, in a manner acceptable to out. any civil works for the Project activities that the Bank. involve land acquisition and resettlement. Ensure that no civil works commence unless relevant compensation for the affected assets has been delivered to project-affected persons and RP provisions are implemented accordingly. GRIEVANCE MECHANISM (GM) ILBANK PMU shall be responsible Prior to implementation of any 5.2 Ensure sub-project RPs describe GM for physical and economic displacement due and shall cause the PIUs, and their Resettlement Plan of sub-projects. to land acquisition, in line with GM defined in relevant SEPs. contractors, to carry out ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 9|Page TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY BIODIVERSITY RISKS AND IMPACTS Include in all site specific ESIA/ESMP with the potential impacts on natural habitats Preparation, disclosure, and approval (by ILBANK PMU shall be responsible and supporting flora and fauna species, a site biodiversity assessment and, as the Bank) of ESIAs and ESMPs and BMPs, as 6.1 and shall cause the PIUs to carry needed, and relevant mitigation and monitoring activities in the ESMP documents. required, prior to tendering of works for out Exclude from financing all activities that might have impacts on Critical Natural each sub-project. Habitats. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES [See examples of possible actions below, if determined that ESS7 is relevant] INDIGENOUS PEOPLES PLAN 7.1 Not applicable. ESS 8: CULTURAL HERITAGE CHANCE FINDS ILBANK PMU shall be responsible Prepare, adopt, and implement the chance finds procedure described in the sub- Preparation, disclosure, and approval (by and shall cause or ensure the PIUs, project-specific ESIAs and ESMPs developed for the Project under action 1.2 above. the Bank) of ESIAs and ESMPs prior to respective civilian authority, or 8.1 tendering of works for each sub-project. Museum Directorate, or Ministry Chance Finds Procedure is included into all civil works contracts and contractors are of Culture and Tourism to carry obligated to adhere. out. ESS 9: FINANCIAL INTERMEDIARIES ESMS ESMS to be established by the Loan Effective date. Once established, the ESMS is 9.1 Prepare, adopt, and maintain an environmental and social management system ILBANK maintained and operated throughout (ESMS). Project implementation. FI ORGANIZATIONAL CAPACITY Establish and maintain an organizational capacity and competency for All defined experts are appointed after 9.2 ILBANK implementing the ESMF and RF with clearly defined roles and responsibilities Loan Effectiveness date. described under action 1.1. SENIOR MANAGEMENT REPRESENTATIVE Prior to Project effectiveness and 9.3 Designate and maintain a senior management representative to have overall maintained throughout Project ILBANK accountability for environmental and social performance of FI sub-projects. implementation. 10 | P a g e TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION ILBANK’s SEP - implemented throughout Project life. Update, adopt, and implement Project’s Stakeholder Engagement Plan (SEP). ILBANK PMU shall be responsible Sub-project SEPs prepared, disclosed and 10.1 As per project’s SEP prepare, disclose, adopt, and implement sub-project specific and shall cause the PIUs to carry finalized prior to finalization of bidding SEPs. out. processes for respective sub-projects. PROJECT GRIEVANCE MECHANISM ILBANK Level - Prior to Loan effectiveness Develop, adopt, maintain and operate a grievance mechanism, as described in the Municipal Level- within 30 days from signing SEP. sub-loan agreement between ILBANK and The grievance mechanism will include a channel to receive and address grievances Municipality ILBANK PMU shall be responsible 10.2 related to sexual exploitation and abuse (SEA) and sexual harassment (SH). and shall cause the PIUs to carry Contractor Level – Within 30 days from Assign staff to manage and monitor project grievances. signing of the respective contract between out. Ensure similar GM is established at municipal and contractor level. Municipality/utility and Contractor Ensure timely resolution, response and reporting of grievances for each sub- Reporting – Semi-annually in progress project. reports. CAPACITY SUPPORT (TRAINING) Relevant Trainings shall be given throughout the project implementation at PIUs staff to be trained by ILBANK PMU on E&S requirements (including necessary steps/stages of the project CS1 activities. ILBANK PMU implementation, monitoring and reporting of ESIAs, ESMPs, SEPs, LMP) of the Bank. Refresher trainings at least once a year or as needed, during Project implementation. Training to be delivered to Project workers on occupational health and safety (OHS) including on emergency prevention and preparedness and response arrangements Contractors (responsible for to emergency situations, environmental and social requirements related to Prior to commencing works, followed by a training) CS2 procurement (bidding documents, Contractor ESMP, etc.), labor requirements for minimum one annual refresher training. primary suppliers, Covid-19 specific LMP measures, and diverse and respectful workplaces, free of sexual exploitation and abuse/ sexual harassment (SEA/SH). 11 | P a g e TURKEY URBAN RESILIENCE PROJECT (P173025) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY ILBANK PMU (responsible for confirming that training acceptable to ILBANK and the Bank has been completed) PIUs 12 | P a g e