MINISTRY OF INFORMATION AND COMMUNICATIONS REPUBLIC OF SIERRA LEONE SIERRA LEONE DIGITAL TRANSFORMATION PROJECT (P177077) ENVIRONMENTAL AND SOCIAL COMMENTMENT PLAN (ESCP) FINAL NEGOTIATED JUNE 2022 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Sierra Leone (the Recipient) will implement the Sierra Leone Digital Transformation Project (the Project), with the involvement of the Ministry of Information and Communications (MIC) working with other ministries, as set out in the Financing Agreement. The International Development Association (hereafter the “Association�) has agreed to provide financing (P177077) for the Project, as set out in the referred agreement. 2. The Recipient shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Association. The ESCP is a part of the Financing Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Recipient shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted and implemented under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESS, and in form and substance, and in a manner acceptable to the Association. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the Association. 4. As agreed by the Association and the Recipient, this ESCP will be revised from time to time if necessary, during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to Project performance. In such circumstances, the Recipient through the Ministry of Information and Communications and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient. The Ministry of Information and Communications shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sierra Leone Digital Transformation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit semi-annual reports to the Project Coordination Association throughout Project Unit (PCU)/Ministry of Prepare and submit to the Association regular monitoring reports on the implementation, commencing after the Information and environmental, social, health and safety (ESHS) performance of the Project, Effective Date. Each report shall be Communications including but not limited to the implementation of the ESCP, status of preparation submitted to the Association no later than (MIC) and implementation of E&S instruments required under the ESCP, stakeholder 7 days after the end of each reporting engagement activities, and functioning of the grievance mechanism(s). period. B INCIDENTS AND ACCIDENTS Notify the Association of any accident or PCU/MIC incident within 48 hours (2 days) after Promptly inform the Association of any incidents or accidents related to the learning about the incident or accident, Project which may have a significant adverse consequence for the environment, followed by a detailed report submitted target communities, the public, or workers, including, inter alia, construction within a timeline acceptable to the accidents that result in death, serious or multiple injury, events of acute pollution Association. due to air or noise emissions, inappropriate disposal of hazardous waste, and sexual exploitation and abuse and sexual harassment (SEA/SH). Provide sufficient detail regarding the incident or accident, indicating measures taken to address it. Where required by the Association, prepare a detailed report on the incident or accident and propose any measures to prevent its recurrence. C CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports to the PCU/MIC Association upon request as annexes to Require contractors and supervising firms to provide monthly monitoring reports the reports to be submitted under action on ESHS performance in accordance with the metrics specified in the respective A above. bidding documents and contracts and submit such reports to Association. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Establish the PCU with a full- time PCU/MIC environmental and social specialist within Establish and maintain a Project Coordinating Unit (PCU) within MIC with qualified three months of the Effective Date and staff and resources including a full time Environmental and Social Specialist to thereafter maintain the organizational support management of ESHS risks and impacts of the Project, with terms of structure including this position refence, experience, and qualifications acceptable to the Association. Specialized throughout Project implementation. external expertise/consultants for Project activities including ESHS management shall be hired as needed, with terms of refence, experience, and qualifications acceptable to the Association. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sierra Leone Digital Transformation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS 1) Prepare, consult upon, adopt and PCU/MIC disclose the ESMF prior to Project 1. Prepare, disclose, consult upon, adopt and implement an Environmental and appraisal, in a manner, form, and Social Management Framework (ESMF) for the Project that includes chance finds substance acceptable to the Association, procedure consistent with the relevant ESSs. and thereafter implement the ESMF throughout Project implementation. 2. MIC shall cause Contractors and private service providers to screen the proposed sub-projects in accordance with the screening tools in the ESMF and 2) Screen sub-projects as per the ESMF thereafter adopt and implement an Environmental and Social Impact Assessment and prepare, consult upon, adopt and (ESIA) and corresponding Environmental and Social Management Plan (ESMP), as disclose the ESIA/ESMP before launching set out in the ESMF and consistent with the relevant ESSs. the bidding process for the respective Project activity prior to carrying out any 3. The proposed [subprojects] [activities] described in the exclusion list set out in activity requiring the adoption of such the ESMF shall be ineligible to receive financing under the Project. ESIA/ESMP. Once adopted, implement the respective ESIAs/ ESMPs throughout Project implementation. 1.3 MANAGEMENT OF CONTRACTORS Incorporate environmental and social PCU/MIC instruments into procurement Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S documents and respective contracts and instruments, the Labor Management Procedures, and code of conduct, and ensure contractors comply with them SEA/SH Action Plan into the ESHS specifications of the procurement documents throughout Project implementation. and contracts with contractors and supervising firms. Thereafter ensure that the contractors and supervising firms comply and cause subcontractors to comply with the ESHS specifications of their respective contracts. 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. PCU/MIC Ensure that the consultancies, studies (including feasibility studies), capacity building, training, and any other technical assistance activities under the Project including, inter alia, national digital skills gap assessment and Information and Communication Technologies (ICT) skills survey, digital skills training, feasibility study to strengthen data hosting and storage capacity, are carried out in accordance with terms of reference acceptable to the Association, that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. 1.5 CONTINGENT EMERGENCY RESPONSE COMPONENT a) Prepare, disclose, consult upon and PCU/MIC adopt the CERC-ESMF Addendum in a 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sierra Leone Digital Transformation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY a) Ensure that the CERC Manual includes a description of the ESHS assessment and form and substance acceptable to the management arrangements, including a reference to the CERC Addendum to be Association before CERC activation. included in the ESMF, for the implementation of the CERC component, in accordance with the ESSs. b) Prepare, disclose, consult upon, and adopt any required E&S instrument and b) Prepare, disclose, consult upon, adopt and implement any other environmental include it as part of the respective bidding and social (E&S) instruments which may be required for activities under CERC process, if applicable, and in any case, component of the Project, in accordance with the CERC-ESMF Addendum and the before implementing the relevant Project ESSs, and thereafter implement the measures and actions required under said E&S activities for which the E&S instrument is instruments, within the timeframes specified in said E&S instruments. required. Implement the E&S instruments in accordance with their terms, throughout Project implementation. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Prepare, consult upon, adopt and disclose PCU/MIC LMP prior to the Effective Date, and Prepare, disclose, consult upon, adopt and implement Labor Management thereafter implement it throughout Procedures (LMP) for the Project, including, inter alia, provisions on working Project implementation. conditions, management of workers’ relationships, occupational health and safety (including personal protective equipment, and emergency preparedness and response), code of conduct (including relating to SEA and SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish a grievance mechanism prior to PCU/MIC/ Contractors engaging project workers and thereafter Establish and operate a grievance mechanism for Project workers, as described in maintain and operate it throughout the LMP and consistent with ESS2. Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Before commencing of any work, and PCU/MIC Prepare, disclose, consult upon, adopt and implement Waste Management Plan during preparation of site-specific C- (WMP), to manage the waste that may be generated from the Project and e-Waste ESMPs, and thereafter implement the Management Plan (eWMP) as described in the ESMF and subsequent sub-project WMP/eWMP through Project ESMPs, all consistent with ESS3. The WMP will specify procedures for collecting, implementation. transporting, recycling and final disposal of these wastes. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sierra Leone Digital Transformation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY The Recipient shall ensure that all equipment and infrastructure deployed and procured, including fiber optics, follow resource efficiency standards, consistent with ESS3. The Recipient shall also ensure waste minimization through techniques such as buying in bulk and buying only required items. Only licensed personnel and well-equipped recycling companies shall be allowed to manage electronic and hazardous wastes. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Prior to the commencement of any civil PCU/MIC Resource efficiency and pollution prevention and management measures covered works. under the ESMF or any subsequent tool to be occasioned by it shall be complied with. Specific measures will be included in the ESIA/ESMP prepared under 1.2 before commencement of any civil works. Furthermore, all contractor contracts . shall include requirements for proper disposal of all liquid and solid waste (including plastic trash), sanitation management, including management of any associated air and noise emissions, and the potential pollution of water sources during construction and operation. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY Prior to the commencement of any civil PCU/MIC Incorporate measures to manage traffic and road safety risks as required in the works ESIA/ESMP to be prepared under action [1.2] above and in the site-specific traffic management plans (to be prepared as part of the C-ESMP). 4.2 COMMUNITY HEALTH AND SAFETY Throughout Sub-project Implementation Assess and manage specific risks and impacts to the community arising from and prior to funds been disbursed for PCU/MIC Project activities, including the behavior of Project workers, COVID-19 infection, specific project activities. SEA/SH and, response to emergency situations, and include mitigation measures in the ESMPs to be prepared in accordance with the ESMF and consistent with ESS4. 4.3 SEA AND SH RISKS Prepare, disclose, consult upon, and PCU/MIC adopt the SEA/SH Action Plan prior to the Prepare, disclose, consult upon, adopt and implement an SEA/SH Action Plan to Effective Date, and thereafter implement assess and manage the risks of SEA and SH under the Project. it throughout Project implementation. Contractors shall be required to assess site-specific SEA/SH risks as part of the Contractor ESMP (including site specific ESMP and adopt material measures for addressing such risks, to be costed and SEA/SH action Plan) shall be prepared included in ESMPs consistent with the Project SEA/SH Action Plan and consistent before commencement of civil works. with ESS4. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sierra Leone Digital Transformation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 4.4 SECURITY MANAGEMENT PCU/MIC/ contractors Before involvement of public or private Assess and implement measures to manage the security risks of the Project, security personnel and thereafter including the risks of engaging security personnel to safeguard Project workers, throughout Project implementation. sites, assets, and activities and implement measures to manage security risk of the Project as needed, in relation to hiring, rules of conduct, training, equipping, and monitoring of such personnel. Contractors shall be required to include these measures in Contractor’s ESMP and implement them consistent with ESS4. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK Prepare, disclose, consult upon, and PCU/MIC adopt the RPF prior to the Effective Date Prepare, disclose, consult upon, adopt and implement a Resettlement Policy and thereafter implement the RPF Framework (RPF) for the Project, consistent with ESS5. throughout Project implementation. 5.2 RESETTLEMENT PLANS Prepare, disclose, consult upon, and PCU/MIC adopt and implement the respective RAPs Prepare, disclose, consult upon, adopt and implement a Resettlement Action Plan including ensuring that before taking (RAP) for sub-projects under the Project for which the RPF requires such RAPs and possession of the land and related assets, consistent with ESS5. full compensation has been provided and as applicable, displaced people have been resettled and moving allowances have been provided. Prepare and submit regular monitoring reports on the implementation of RAPs, including issues related to land acquisition, assessment/census of PAPs and Submit resettlement monitoring reports compensation, and functioning of resettlement-related grievance redress semi-annually throughout the mechanism. implementation of RAPs. 5.3 GRIEVANCE MECHANISM Establish a resettlement and project GM PCU/MIC The Grievance Mechanism (GM) to address resettlement and Project related prior to engagement of workers. complaints is described in the ESMF, RPF, and SEP. The established GM shall provide anonymous reporting & recording channels that are accessible to all, Submit reports quarterly throughout focusing not only on receiving and recording complaints, but also on their project implementation, with the first resolution and feedback collection. report submitted three months after the mechanism is established. 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sierra Leone Digital Transformation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Provide regular reports to the Association on the overall performance of the Project GM in managing resettlement-related complaints. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS Screen the subprojects and prepare PCU/MIC subproject- specific ESIAs/ESMPs prior to Screen Project activities (including civil works) to avoid any significant loss or the commencement of subproject works degradation of natural habitats, including protected areas and other biomes, in and thereafter implemented throughout accordance with the Project’s ESMF and ESS6. Subprojects that will Project implementation. have any substantial impacts on biodiversity and sensitive ecological areas shall be excluded from the Project scope and be ineligible for Project financing. Biodiversity-related risks and impacts shall be comprehensively assessed and managed as part of the ESIAs/ESMPs to be conducted/implemented in sub-Project sites. Work shall not be carried out in sensitive ecosystems/habitats/species such as protected and designated areas, forests, wetlands, and IUCN listed species to avoid elaborate offsets and project delays. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES There are no actions under the Project preparation related to Indigenous People, therefore there are no mitigation measures to be undertaken under ESS7 for the Project. ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS Adopt chance find procedures in the PCU/MIC Prepare, disclose, consult upon a chance find procedure as part of the project ESMF prior to appraisal and implement ESMF consistent with ESS8. them throughout Project implementation. Work shall not be done in areas with cultural heritage (including landscapes and visuals) of significance to targeted communities to avoid elaborate offsets and delay in Project implementation. ESS 9: FINANCIAL INTERMEDIARIES Not relevant. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sierra Leone Digital Transformation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Prepare, disclose, consult upon, adopt PCU/MIC Prepare, disclose, consult upon, adopt and implement a Stakeholder Engagement and implement the SEP prior to appraisal, Plan (SEP) for the Project, consistent with ESS10, which shall include measures to, and thereafter implement the SEP inter alia, provide stakeholders with timely, relevant, understandable and throughout Project implementation. accessible information (with safeguards for vulnerable groups, particularly women, persons with disability and youth), and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM Establish and operationalize the PCU/MIC grievance mechanism prior to Establish, publicize, maintain, and operate an accessible grievance mechanism, to engagement of project workers and receive and facilitate resolution of concerns and grievances in relation to the thereafter maintain and operate the Project, promptly and effectively, in a transparent manner that is culturally mechanism throughout Project appropriate and readily accessible to all Project-affected parties, at no cost and implementation. without retribution, including concerns and grievances filed anonymously, in a manner consistent with ESS10. The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 The MIC shall ensure that there is relevant training for community facilitators, This shall be done before commencement PCU/MIC Recipient’s preparation team, PCU staff, stakeholders, communities, contractors, of civil works, and periodically (as needed) implementing agencies, project workers, etc., in the following areas: during Project implementation • Stakeholder engagement and project awareness raising • World Bank ESF • Project GM • Emergency preparedness and response • Community health and safety • Implementation of ESMF, RPF, SEP • E&S screening for sub-projects • Environmental and Social Risk Management procedures • COVID 19 transmission, prevention, preparedness and response 9|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sierra Leone Digital Transformation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY • Occupational Health and Safety • SEA/SH Risk Mitigation • Disability inclusion training • E&S Documentation and reporting • Information disclosure CS2 Conduct training for Project workers on occupational health and safety including This shall be done before commencement PCU/MIC on risk analysis and communication, prevention and preparedness and response of civil works, and periodically (as needed) arrangements to emergency situations, SEA/SH Risk Mitigation, COVID 19 - during Project implementation transmission, prevention, preparedness and response 10 | P a g e