ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Palestinian Heritage Trail: Increased Economic Opportunities and Improved Livelihood for Fragile Communities (P170706) ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) June 1,2021 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Palestinian Heritage Trail (PHT), the Project Implementation Agency (PIA) (hereinafter the recipient) shall implement the Palestinian Heritage Trail: Increased Economic Opportunities and Improved Livelihood for Fragile Communities (P170706) (the Project). The JSDF has agreed to finance the Project through the International Bank for Reconstruction and Development (hereinafter the Bank). 2. PHT shall 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. PHT shall also comply with the provisions of any other Environmental and Social (E&S) documents required under the Environmental and Social Framework (ESF) and referred to in this ESCP, Environmental and Social Management Framework (ESMF), Labor Management Procedures (LMP), Stakeholder Engagement Plan (SEP), and the timelines specified in those E&S documents. 4. Implementation of the material measures and actions set out in this ESCP shall be monitored and reported to the Bank by PHT as required by the ESCP and the conditions of the legal agreement, and the Bank shall monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 5. By agreement between the Bank and PHT, 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, PHT shall agree to the changes with the Bank and shall update the ESCP to reflect such changes. Agreement on changes to the ESCP shall be documented through the exchange of letters signed between PHT and the Bank. The Borrower shall promptly disclose the updated ESCP. 6. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, PHT shall assess these risks and shall ensure that additional funds are provided, if needed, to implement actions and measures to address such risks and impacts, which may include risks and impacts on labor and working conditions, occupational and community health and safety, and environment. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Prepare and submit to the Bank regular monitoring reports on the environmental Starting ninety (90) days after the PHT and social performance of the Project, including but not limited to the Effective Date of the Project and then implementation of the ESCP, status of preparation and implementation of E&S quarterly (every three (3) months) documents required under the ESCP, stakeholder engagement activities, throughout the Project implementation. performance of the grievance mechanism(s). Submit to the Bank the Environmental and Social Due Diligence (ESDD) conducted On a continuous basis, submit to the for the selected beneficiaries for financing. Bank for review the ESDDs after the Effective Date and throughout the Project implementation. B INCIDENTS AND ACCIDENTS Notify the Bank of any incident or accident related to the Project which has, or is Notify within 48 hours from the PHT likely to have, a significant adverse effect on the environment, the affected occurrence of the incident. communities, the public or workers including but not limited to; incidents and accidents encountered during implementation of the Project. Require the selected beneficiaries for financing to provide sufficient details Submit an incident report, within 30 regarding the incident or accident, findings of the Root Cause Analysis (RCA), business days from date of notification. indicating immediate measures or corrective actions taken or that are planned to be taken to address it, compensation paid, and any information provided by the involved beneficiary, as appropriate. Subsequently, as per the Bank’s request, prepare and submit an incident report, including RCA, precautions and compensation measures taken and propose any measures to prevent its recurrence. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 1.1 ORGANIZATIONAL STRUCTURE Enhance and maintain the capacity of the PHT with full-time qualified staff and One recruited M&E/ ES O, shall be PHT resources for the management and monitoring of E&S risks and impacts, by assigned to the Project by PHT one appointing: one Monitoring and Evaluation Officer (M&E O) who will be month after the Effective Date of the responsible for environmental and social management and he will be supported Project. by an E&S consultant with ESF experience that should be available on a part-time All designated PHT staff for the Project basis. shall be retained for the duration of the Project. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT a. PHT shall assess the E&S risks and impacts of proposed Project activities a. The Final ESMF to be prepared and PHT in accordance with ESS1. A draft ESMF, which was prepared by PHT, disclosed one month after the needs to incorporate the Bank’s comments and the final ESMF to be Effective Date of the Project. disclosed and adopted for the Project. b. Before the carrying out of the b. PHT shall conduct Environmental and Social Due Diligence (ESDD) for the relevant Project activities, and different sub-projects, in line with ESS1 and the ESMF. PHT shall follow thereafter throughout the carrying the clearance process for sub-projects as described in the Project out of such activities. Operation Manual (POM) and thereafter during project implementation c. Before launching the procurement conduct supervision spot checks of the selected beneficiaries. c. Prepare site-specific E&S instruments per the requirements of the process for the relevant Project ESMF, if and as needed, and incorporate the relevant aspects of this activities, and thereafter ESCP, including, inter alia, any environmental and social management throughout the carrying out of plans or other instruments, ESS2 requirements, and any other required such activities. ESHS measures, into the ESHS specifications of the procurement documents and contracts with beneficiaries and contractors. Thereafter, ensure that the beneficiaries and contractors comply with the ESHS specifications of their respective contracts. ESS 2: LABOR AND WORKING CONDITIONS 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 2.1 LABOR MANAGEMENT PROCEDURES Final Labor Management Procedures (LMP), in accordance with ESS2, shall Prepare and disclose Final LMP one PHT be prepared (incorporating the Bank’s comments), consulted upon, month after the Effective Date of disclosed and implemented throughout the life of the Project. The Project the Project. shall be carried out in accordance with the applicable requirements of ESS2, in a manner acceptable to the Association, including through, inter Implement and monitor the LMP alia, implementing adequate occupational health and safety measures starting on the Effective Date of the (including emergency preparedness and response measures), adequate Project and throughout the Project. measures for child labor, GBV, sexual harassment and Violence Against Children (VAC), setting out grievance arrangements for Project workers, and incorporating labor requirements including Occupational Health and Safety into the ESHS specifications of the procurement documents and contracts with third party service providers. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Maintain, and operate an accessible grievance mechanism (GM) for Project Grievance mechanism operational PHT workers as described in the LMP, consistent with requirements under prior to engaging Project workers relevant national law as confirmed by the Bank and ESS2. and maintained throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Included as part of action 1.2 PHT To be included in the site-specific E&S instruments and shall be part of the ESDD to be conducted for each sub-project as indicated in action 1.2 above. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY To be included in the site specific E&S instruments and shall be as part of PHT the E&S due diligence (ESDD) to be conducted by PHT for each sub-project Included as part of action 1.2. as indicated in action 1.2 above, ESS4 shall be applied within the scope of PHT’s environmental and social management procedures as relevant. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 Not Relevant to the Project N/A ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 PHT shall develop environmental guidelines for beneficiaries to prevent Not later than 90 days after the Effective PHT degrading natural and physical integrity, damage the natural habitat and Date of the Project and maintained wildlife. throughout Project implementation. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 Not Relevant to the Project N/A ESS 8: CULTURAL HERITAGE 8.1 PHT shall develop guidelines for beneficiaries to prevent degrading Not later than 90 days after the Effective physical cultural resources and adopt chance find procedures for any Date of the Project and maintained trail upgrading activities. throughout Project implementation. ESS 9: FINANCIAL INTERMEDIARIES 9.1. Not Relevant to the Project N/A ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Maintain and update, if and as Maintain and implement SEP in a manner acceptable to the Bank. required, throughout project PHT implementation 10.2 PROJECT GRIEVANCE MECHANISM Establish, maintain and operate a grievance mechanism (GM), including GM should be operational not later PHT with requisite staff, as described in the SEP. The GM shall integrate GBV than 30 days after the Effective Date sensitive measures, including multiple channels to initiate a complaint of the Project and maintained and specific procedures for SEA/SH, such as confidential and/or throughout Project implementation. anonymous reporting with safe and ethical documentation of SEA/SH cases. CAPACITY SUPPORT (TRAINING) 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) CS1 PHT staff to train the beneficiaries as needed on the Bank’s E&S Throughput the project PHT requirements on: implementation 1. Environmental and Social Management Framework 2. Environmental, Health and Safety Guidelines 3. SEP 4. LMP 5. GRM including SEA/SH 7|Page