ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N_ P172247 - CARE INTERNATIONAL IN BENIN AND TOGO Social Accountability for Nutrition and Early Childhood Services Project (SA4N) (P172247) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) June 2021 1 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N_ P172247 - Benin/CARE International in Bénin Project of Social Accountability for Nutrition and Early Childhood Services in Benin ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 1. CARE International in Benin (hereinafter referred to as the Recipient) will implement the Project of Social Accountability for Nutrition and Early Childhood Services in Benin (SA4N) (the Project). The International Development Association (hereinafter referred to as the Bank) has agreed to provide funding for the Project. 2. The Recipient will implement the material measures and actions so that the Project is carried out 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, and their implementation schedule. 3. The Recipient will also comply with the provisions of all other environmental and social documents required under the Environmental and Social Framework (ESF) and referred to in this ESCP, such as the Environmental and Social Management Plans (ESMPs), the Stakeholder Engagement Plans (SEPs), the Labor Management Procedures (LMP) and the timelines specified in those E&S documents as well as the schedules indicated in these documents. As the SEA/SH risk assessed at the time of project preparation is low, the project will incorporate SEA/SH mitigation measures in the above-mentioned safeguard documents. 4. The Recipient is responsible for compliance with all requirements of the ESCP. 5. The implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Bank by the Recipient as required by the ESCP and the conditions of the legal agreement, and the Bank will monitor and assess the progress and completion of the material measures and actions throughout the implementation of the Project. 6. As agreed by the Bank and the Recipient, this ESCP may be revised from time to time during the implementation of the Project, to reflect adaptive management of Project changes and unforeseen circumstances, or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, the Recipient 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 the Bank and the Recipient. The Recipient will promptly disclose the updated ESCP. 7. Were Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during the implementation of the Project, the Recipient shall provide additional funds, if necessary, to implement actions and measures to address such risks and impacts, which may include gender-based violence (sexual exploitation and abuse, sexual harassment in the workplace - SEA/SH), inclusion of vulnerable groups, floods, drought, post-election violence, disruption of activities due to traditional ceremonies, pandemics and epidemics, notably COVID-19 , etc. 2 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N CARE P172247 CONCRETE MEASURES AND ACTIONS CALENDAR RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORT REGULAR REPORTS: Prepare and provide regular environmental and social Quarterly ESCP implementation reports, by Care International in Benin monitoring reports to the Bank indicating the status of the 10th of the month following the end of compliance with the measures agreed upon in the ESCP, the quarter, will be prepared throughout including the preparation and implementation of environmental the life cycle of the project, starting with and social risk management measures, stakeholder engagement the first three months of the project activities, and the operation of the complaint management mechanism. These reports will include data on the management of complaints, including the number of allegations or complaints received as well as the actions and corrective measures taken, without mentioning any personal information about the perpetrators and victims that could lead to their identification. NOTIFICATION OF INCIDENTS AND ACCIDENTS: Notify the Bank promptly of any incident or accident related to Incidents and accidents will be reported Care International in Benin the Project that may have serious consequences for the immediately to the Bank or at the latest environment, communities affected by the Project, the public, or within 48 hours of becoming aware of personnel. them throughout the project's life cycle. The notification shall include as much information and sufficient This reporting system will be in effect detail as possible about the incident or accident, and shall throughout the project. indicate the steps taken without delay to deal with it, and shall include information made available by any supplier or contractor and by the supervising entity, if any. The incident/accident report is prepared including measures to prevent recurrence. For GBV/SEA/SH, this will include measures taken in terms of assistance (care) as well as any precautionary measures taken about the alleged perpetrators. ASSESSMENT SUMMARY NES 1 : ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND EFFECTS 3 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N CARE P172247 1.1 ORGANIZATIONAL STRUCTURE : The project coordinator will be in place . The Social Specialist will see to the application of the provisions when the project start-up contract is made in the present document and all the safeguard documents signed CARE International in Benin. prepared within the framework of the project. The social specialist will be appointed no The Recipient already has a specialist in charge of GBV aspects later than 90 days after the project start within its project implementation team. date. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT: The project activities are mostly capacity building and no The mitigation measures included in this CARE International in Benin and infrastructure construction or renovation activities are planned. ESCP as well as the SEP and the LMP prior Social Specialist. On this basis, no specific environmental risk and impact to project appraisal and maintained assessments are expected to be conducted later. An assessment executed throughout the project life cycle. of CARE's institutional capacity including an analysis of CARE International's social risk management framework in Benin, in line with the requirements of the World Bank's Environmental and Social Framework, has been carried out by the Bank and mitigation measures including the designation/appointment of a dedicated social specialist and capacity building actions for the effective management of social risks, are included in this ESCP as well as the SEP and HRMP developed. The SEA/SH risk assessment is done, and the risk level is low. Mitigation measures will be integrated into the above-mentioned safeguard documents and will include: the preparation and signing of codes of conduct for workers associated with the project implementation, the consideration of cases and allegations of SEA/SH in the complaint management mechanisms, the conduct of separate focus groups with women and girls, the consideration of GBV in the tender documents, the mapping of service providers, etc. These measures will be adequately developed before the start of the project and implemented throughout the project's life. 4 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N CARE P172247 1.3 MANAGEMENT TOOLS AND INSTRUMENTS: Develop and implement the following management tools and The ESCP, SEP, and LMP are developed and CARE International in Benin and instruments : will be disclosed prior to appraisal. The Social Specialist.  Environmental and Social Commitment Plan (ESCP) mitigation measures included in each of  Labor Management Procedures (LMP) the documents will be implemented prior  Stakeholder Engagement Plan including a grievance to the start of activities and maintained mechanism (GM), all these documents should include throughout the life cycle of the project. measures related to the prevention of GBV/SEA/SH  The project implementation manual (PIM) with a The Project Implementation Manual will be section entitled "Environmental and social measures" developed no later than six (6) months which will describe in detail the role and after the project start date and responsibilities of the social specialist in the drafting of implemented throughout the project life the sections on environmental and social safeguards, cycle. to be included in the terms of reference of the missions and studies 1.4 MANAGEMENT OF SUPPLIERS AND PROVIDERS The Beneficiary will ensure that all contracts and agreements During the preparation of contracts and CARE International in Benin, the impose on any service provider the obligation to comply with agreements and throughout the life cycle Procurement and Finance Managers the management tools and instruments referred to in point 1.3 of the project. and the Social Specialist. above. Respect the minimum environmental and social clauses included in the tender documents and work contracts. NES 2 LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES: Develop, adopt, and implement Labor Management Procedures The LMP is developed and will be publish (LMP) in accordance with national law, CARE International's disclosed prior appraisal, updated nine (9) CARE International in Benin and the Benin Human Resource Procedure Manual, and ESS2. The LMP months after project effectiveness date, Social Specialist will include a description of the Project's recruitment and and implemented during the project life employment management process, transparency of recruitment cycle. and dismissal, medical care, social security and insurance for workers, minimum working age, etc. These procedures will contain a component related to the prevention of SEA/SH as well as risk mitigation measures. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: 5 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N CARE P172247 Prepare and maintain a Grievance Mechanism (GM) related to The GM for workers, available in the LMP, CARE International in Benin. any labor or employment issues under the Project, which will be will have to be operational from the date Monitoring and Evaluation easily accessible to Project workers and other service providers of entry into force of the Project and Specialist; under the Project and, consistent with the ESS2 and Benin's labor implemented throughout the duration of Social Specialist. laws and CARE International Benin's policies in this regard. the project. Project NGOs and subcontractors. The LMP for project workers will be based on a survivor-centered approach that prioritizes confidentiality and safety. This LMP will include procedures for reporting allegations of GBV/SEA/SH and a framework for accountability and response to complaints. The project will ensure that the complaint mechanism is known to all workers in the project's partner structures and to project workers. The GM will be gender sensitive and must be secure to allow for whistleblowing by all staff regardless of their gender and age. Workers will be made aware of how the mechanism works, the protection of sources of denunciation, the treatment of and responses to complaints and the sanctions incurred by the respondents. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES : Integrate workplace health and safety (OHS) measures contained These measures will be in place prior to CARE International in Benin; in the labor code and social security code in force in the Republic the start of the execution of the Social Specialist; of Benin and in CARE International's human resources contracts/agreements and protocols and CARE International HR in Benin. management manual in Benin, in the project implementation maintained throughout the manual, and in all contracts signed, including by SA4N project implementation of the Project. workers. These measures will be consistent with the health measures put in place by the Government of Benin regarding the prevention of diseases such as COVID-19, HIV/AIDS, etc. 2.4 EMERGENCY PREPAREDNESS AND RESPONSE : Develop with stakeholders, an Emergency Preparedness and These measures are maintained CARE International in Benin; Response plan and ensure coordination of related measures. throughout the implementation of the Social Specialist. Project. 2.5 TRAINING OF PROJECT WORKERS : Throughout the project life cycle. Conduct training for direct Project workers to increase their All employees will participate in at least Project Coordinator/CARE awareness of potential risks and impacts related to Project four training/capacity building sessions per International in Benin ; activities and their roles and responsibilities for assessing and year regarding GBV/SEA/SH prevention. Monitoring and Evaluation managing these E&S risks and impacts. Specialist; Social Specialist 6 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N CARE P172247 NES 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT: NOT APPLICABLE NES 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Raise awareness and ensure compliance with the road safety At the start of project activities and CARE International in Benin. code in force in the Republic of Benin by the project's throughout the implementation of the Monitoring and Evaluation implementation actors and the users of the means of transport project. Specialist; Social Specialist. within the framework of the project. 4.2 COMMUNITY HEALTH AND SAFETY: Ensure that the environmental and social protection measures At the start of project activities and CARE International in Benin ; set out in the project document make it possible to manage the throughout the implementation of the Monitoring and Evaluation risks and negative impacts of Project activities on the living Project. Specialist; Social Specialist. conditions of local populations. 4.3 GBV AND SEA RISKS: Communicate and build capacity to disseminate information about GBV / SEA risks. Mitigation measures proportional to the From thirty (30) days after the project CARE International in Benin ; level of low risk, including information, communication, and effectiveness date and maintained Social Specialist. capacity building activities, are defined, and will be throughout the duration of the project. implemented. Given the project's low risk of GBV/SEA, the GBV risk prevention measures should include, at the very least, a code of conduct that clearly prohibits GBV / SEA for all project staff, Training/awareness-raising on GBV/ SEA risks and mitigation measures, integration of GBV/SEA issues in the tender documents, separate focus groups for women and girls facilitated by a woman. Verify that all workers or employees have signed a code of conduct that commits them to the risks of GBV/ SEA by their employer. If this code does not exist, the project should make sure that they sign CARE International's policy against GBV in Benin. In any case, everyone (direct workers, consultants, partners, etc.) must commit to respecting the code of conduct or else face sanctions. 4.4 EMERGENCY RESPONSE MEASURES : CARE International in Benin 7 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N CARE P172247 The Emergency Preparedness and Response Plan will be Before the start of activities and developed as needed, implemented, and reported periodically throughout the implementation of the to the Bank (Section 2.4). Project. NES 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT: NOT APPLICABLE NES 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES: NOT APPLICABLE NES 7 : INDIGENOUS PEOPLES/SUB-SAHARAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES: NOT APPLICABLE NES 8: CULTURAL HERITAGE: NOT APPLICABLE NES 9: FINANCIAL INTERMEDIARIES: NOT APPLICABLE NES 10 : STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION: Develop, consult, validate, adopt, and publish the Stakeholder The SEP is developed and will be publish Engagement Plan (SEP), which will be updated as needed to disclosed prior to project approval. The SEP include more detailed information regarding information will be updated as needed during project CARE International in Benin and the 10.1 sharing methodologies, a more robust mapping of project implementation and executed throughout Social Specialist. stakeholders, and identification of existing community project implementation. platforms that can be used to facilitate effective and Quarterly implementation monitoring participatory community engagement, monitoring, and reports will be regularly shared with the evaluation. Bank Implementing the SEP. PROJECT GRIEVANCE MECHANISM: Establish and keep operational and accessible to stakeholders, mainly vulnerable groups, the grievance mechanism which will include communication actions to ensure that local populations The draft of the GRM available in the SEP in the project's area of influence as well as all stakeholders will be updated no later than six (6) concerned by the project are informed of its existence and months after the effectiveness date and know how to submit and process complaints as well as other will be operationalized throughout the CARE International in Benin and the 10.3 avenues of appeal. project's life cycle. Social Specialist. The grievance mechanism will be adapted to sensitive complaints such as GBV/SEA, which means that it will have several entry points for SEA complaints confirmed as safe and accessible by women during consultations, will offer referrals to GBV service providers (at least medical, psychosocial and legal) and will have procedures for a confidential and survivor- centered management and verification. 8 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - SA4N CARE P172247 CAPACITY BUILDING SUPPORT RC1 Organize and conduct information/sensitization and training sessions for local populations to increase their awareness of the potential environmental and social risks of the SA4N project, including SEA/SH aspects, and to engage them in determining Project Team, Strategic Partner mitigation measures and implementing effective management Throughout the project life cycle. (ASCINB, LPAA) measures for the negative environmental and social impacts associated with SA4N project implementation. Training sessions will focus on GBV/SEA, child abuse, GRM, Hygiene, Health, Safety at Work, Code of Conduct, etc. RC2 EMERGENCY PREPAREDNESS AND RESPONSE Early warning watch committees will be established. Members of these committees will be trained on emergency identification At the beginning of the project and one Project Team, Strategic Partner and reporting channels to CARE International in Benin. month after an emergency is identified. (ASCINB, LPAA) They will also be trained on adaptation and resilience measures in the face of these emergencies and will in turn train project beneficiaries. 9 | Page