THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Saint Lucia Human Capital Resilience Project-P170445 DRAFT ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) December 13, 2019 1|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Saint Lucia Human Capital Resilience Project-P170445 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. Saint Lucia is planning to implement the Human Capital Resilience Project, (the Project), with the involvement of the following Ministries: Ministry of Education, Innovation and Gender Relations (hereinafter Ministry of Education), Ministry of Equity, Social Justice, Empowerment and Human Services (hereinafter Ministry of Equity). The International Development Association (hereinafter the Association) has agreed to provide financing for the Project. 2. Saint Lucia will implement material measures and actions so that the Project is implemented in accordance with the World Bank Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out the material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. The ESCP will also comply with the provisions of any other environmental and social documents required under the ESSs and referred to in this ESCP, such as the Social Assessment (SA), the Stakeholder Engagement Plan (SEP) and the Labor Management Procedures (LMP) that have been developed for the Project. 4. Saint Lucia is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministries referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Association by the Saint Lucia as required by the ESCP and the conditions of the legal agreement, and the Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Association and Saint Lucia, 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, Saint Lucia, through the Minister responsible for Education will agree to the changes with the Association 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 Association and the Minister responsible for Education. The Ministry of Education 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, the Saint Lucia shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. 2|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Bi-annual (every 6 months) throughout Ministry of Education. Prepare and submit to the Association regular monitoring reports on Project implementation. the environmental, social, health and safety (ESHS) performance of the Project, including but not limited to, the implementation of the ESCP, status of preparation and implementation of E&S documents required under the ESCP, stakeholder engagement activities, functioning of the grievance mechanism(s). B INCIDENTS AND ACCIDENTS Any incident or accident shall be notified to Ministry of Education. Promptly notify the Association of any incident or accident related to the Association within 72 hours after taking the Project which has, or is likely to have, a significant adverse effect on note of the incident or accident. Timing on the environment, the affected communities, the public or workers the submission of any subsequent report Provide sufficient detail regarding the incident or accident, indicating would be specified by the Association. immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and supervising entity, as appropriate. Subsequently, as per the Association’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE The E&S Specialist(s) will be engaged within Ministry of Education The PIU to be established under the Ministry of Education will include three (3) months of the Effective Date and one (1) full time or two (2) part-time Environmental and Social maintained throughout Project Specialist(s) with qualifications and experience acceptable to the implementation. Association, to support management of the ESHS aspects of the Project. 1.2 SOCIAL ASSESSMENT A SA has been developed on October 30 Ministry of Education. Implement the measures contained in the Social Assessment (SA) and was disclosed on December 12, 2019; prepared for the Project. The SA will be updated and disclosed no Update the SA to include measures to ensure that individuals or groups later than one (1) month after the Effective who, because of their particular circumstances, are disadvantaged and Date. vulnerable, are not prevented from accessing the benefits and Identified measures contained in the SA opportunities resulting from the Project, and thereafter implement the will be maintained and implemented revised SA, in a manner acceptable to the Association. throughout the Project implementation. 3|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 1.3. TECHNICAL ASSISTANCE. Throughout Project implementation Ministry of Education Ensure that the terms of reference for studies, capacity building, training and any technical assistance activities carried out under the Project are acceptable to the Association and duly incorporate and take into consideration, the provisions of the Social Assessment, the Stakeholder Engagement Plan, the ESCP and the requirements of the ESSs, as applicable. 1.4 MANAGEMENT OF CONSULTANTS Prior to the preparation of procurement Ministry of Education Incorporate the relevant aspects of the ESCP, including the relevant E&S documents. Implement throughout Project documents and/or plans, and the Labor Management Procedures, into implementation. the ESHS specifications of the procurement documents with consultants. Thereafter ensure that the consultants comply with the ESHS specifications of their respective contracts. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES LMP was completed on October 30 and Ministry of Education Update the draft Labor Management Procedures (LMP) developed for disclosed on December 12, 2019. The the Project, which shall include a code of conduct to be provided to and revised LMP will be finalized no later than signed by all workers, detailing measures on ESHS, sexual exploitation two (2) weeks after the Effective Date and and abuse, sexual harassment and violence against children. Thereafter, implemented throughout Project implement the revised LMP, in a manner acceptable to the Association. implementation. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Grievance mechanism operational prior Ministry of Education Establish, maintain, and operate a grievance mechanism for Project engaging Project workers and maintained workers, as described in the LMP and consistent with ESS2. throughout Project implementation. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Same timeframe as 2.1 Ministry of Education Prepare, adopt, and implement occupational, health and safety (OHS) measures as described in the LMP. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT This Standard is currently not relevant ESS 4: COMMUNITY HEALTH AND SAFETY This Standard is currently not relevant ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT This Standard is currently not relevant ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES This Standard is currently not relevant ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES This Standard is not relevant 4|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 ESS 8: CULTURAL HERITAGE This Standard is currently not relevant ESS 9: FINANCIAL INTERMEDIARIES This Standard is currently not relevant ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND A SEP was completed on October 30 and Ministry of Education IMPLEMENTATION disclosed on December 12, 2019 Implement the measures contained in the Stakeholder Engagement Plan (SEP). Update and disclose the revised SEP no Update the SEP to include measures to ensure that individuals or groups later than one (1) month after the Effective who, because of their particular circumstances, are disadvantaged and Date. vulnerable, are able to participate in stakeholder engagement activities, and thereafter implement the revised SEP, in a manner acceptable to Maintained and implemented throughout the Association. Project implementation. 10.2 PROJECT GRIEVANCE MECHANISM: Establish, maintain and operate a The GRM is part of the SEP and is already in Ministry of Education grievance mechanism, as described in the SEP. place. It will be maintained and implemented throughout Project implementation. CAPACITY SUPPORT (TRAINING) CS1 Training on: Once the of PIU is established and fully Ministry of Education  Environmental and Social Standards staffed (three (3) months after the  Citizen engagement and stakeholder engagement. Effective Date) especially, Project  Monitoring and Evaluation coordinator, technical officer, procurement specialist, financial specialist, and environmental and social specialist(s), and throughout Project implementation 5|Page