UNION OF THE COMOROS ------------------- Ministry of Maritime and Air Transport -------------------- Comoros Inter-Island Connectivity Project (PICMC) P173114 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Février 23, 2022 Draft for Negotiation ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Union of Comoros (the Recipient) plans to implement the Comoros Inter-Island Connectivity Project (PICMC or the Project) with the involvement of the Ministry of Transport (Ministère des Transports Maritime et Aérien). The International Development Association (IDA or the Association) has agreed to provide financing for the Project. 2. The Recipient shall implement measures and actions to ensure that the Project is implemented in compliance with the World Bank's Environment and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out measures and actions, any specific documents or plans, and the timing of each of these. 3. The Recipient 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, as well as the timetables indicated in these E&S documents. These documents include: ▪ Environment and Social Management Framework (ESMF) of Component 1.2. “Improvement of secondary ports� and Component 2.2. « Vessel renewal program »; ▪ Resettlement Framework Policy for Component 1.1. “Infrastructure improvement of Port Fomboni (Boingoma), Component 1.2. “Improvement of secondary ports� and Component 2.2. « Vessel renewal program »; ▪ Risk Assessment and Action Plan concerning Gender-Based Violence (GBV), Sexual Exploitation and Abuse (SEA), Sexual Harassment (SH) for all components; ▪ Stakeholder Engagement Plan (SEP) including the Grievance Redress Mechanism (GRM) for all components, ▪ Labor Management Procedures (LMP) for all components. Other documents will be developed as needed during the implementation of the project: Environment and Social Impact Assessment including Environmental and Social Management Plans (ESMP) for Component 1.2. “Improvement of secondary ports� and Resettlement Action Plan including Livelihoods Improvement Plans for Component 1.1. “Infrastructure improvement of Port Fomboni (Boingoma), Component 1.2. “Improvement of secondary ports� and Component 2.2. « Vessel renewal program ». 4. The Recipient will be responsible for ensuring compliance with all the requirements of the ESCP, even where the implementation of certain measures and actions is conducted by the Ministry mentioned in paragraph 1 above in collaboration with the Ministry of Environment and Forestry. In addition, the Beneficiary is required to ensure coherence between the requirements of the ESCP and the activities planned in Component 3 "Implementation support and capacity building" which aims at financing technical assistance to improve the institutional framework and capacity of the Government to implement inter-island maritime policies properly, including port management. 5. The implementation of the measures and actions set out in this ESCP shall be monitored and reported to the Association by the Recipient as required by the ESCP and the conditions of the legal agreement, and the Association will monitor and assess progress and completion of the measures and concrete actions throughout implementation of the Project. Page 2 of 13 6. As agreed by the Association and the Recipient, this ESCP may be revised from time to time during the implementation of the Project, to reflect the adaptive management of changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such situations, the Recipient, through the Project Implementation Unit (PIU), will agree on these changes with the Association and revise the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through an exchange of letters signed between the Association and the Recipient. The Recipient shall promptly disclose the revised ESCP.Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the Recipient shall provide additional funds, if necessary, to implement actions and measures to address such risks and impacts, which may include those related to health, safety, influx of labour, degradation of natural resources and pollution of the physical environment (soil, air, surface and underground water, noise on construction sites), disruption of free movement of people and goods, social conflicts and health and safety of the population (outbreak of diseases among the population and workers, accidents related to site activities, health risks related to poor management of shipyard waste, loss of land and resettlement, Gender-Based Violence and risks related to child labour. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the Recipient shall provide additional funds, if necessary, to implement actions and measures to address such risks and impacts which may include those related to health, safety, influx of labor, degradation of natural resources and pollution of the physical environment (soil, air, surface and underground water, noise on construction sites), disruption of free movement of people and goods, social conflicts and health and safety of the population (outbreak of diseases among the population and workers, accidents related to site activities, health risks related to poor management of shipyard waste, loss of land and resettlement, Gender-Based Violence and risks related to child labor). Page 3 of 13 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A PERIODIC REPORTS Prepare and submit to the Association regular monitoring reports on the Each quarter, at the latest on the 5th of the PIU PICMC environmental, social, health and safety (ESHS) performance of the Project, month following the quarter in question, including but not limited to the implementation of the ESCP, the preparation throughout the implementation of the and implementation of environmental and social documents required under the Project and in coordination with the report ESCP, stakeholder engagement activities and the functioning of the Grievance on the status and results of the Project. Redress Mechanism(s) including those related to resettlement and cases of Sexual Exploitation and Abuse/Gender Based Violence/Sexual Health Compilation shall be sent to the (SEA/GBV/SH),Violence Against Children (VAW/CV). Association no later than the 10th of January following the year in question B INCIDENTS AND ACCIDENTS 1. Notify the Association of all incidents or accidents, related to the 1. Notifications of incidents and PIU PICMC Project, which have, or are likely to have, a significant adverse effect accidents shall be made within 48 on the environment, the affected communities, the public or workers, hours of first becoming aware of the including those related to occupational exclusion or discrimination incident or accident. against certain individuals or groups of individuals and any Project- related allegation of SEA/GBV/SH in relation to the Project. 2. The notification shall provide sufficient detail regarding the incident(s) 2. A detailed report on specific or accident(s) in question, including the immediate and root causes, information, including causes, and shall indicate immediate measures taken or that are planned to consequences, measures taken, etc., be taken to address the incident(s) or accident(s); it shall also include shall be submitted to the Association information provided by any supplier/provider or oversight entity, as within a maximum of one week after appropriate. Subsequently, as per the Bank’s request, prepare a first becoming aware of the incident or report on the incident or accident and propose any measures to accident. prevent its recurrence. 3. The Recipient shall require suppliers and service providers to notify it 3. These notification and reporting of accidents and incidents in accordance with this ESCP, including requirements apply throughout project through a model incident or accident notification form. implementation. C MONTHLY REPORTS FROM SUPPLIERS AND PROVIDERS In the framework of civil works contracts or other awarded on the basis of the Monthly and throughout the PIU PICMC Association’s standard procurement files, require suppliers and service implementation of the Project. providers to provide monthly monitoring/tracking reports to the PIU. These reports shall be transmitted to the Association by the Recipient, upon request. ESS1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS Page 4 of 13 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 1.1 ORGANIZATIONAL STRUCTURE 1. Establish and maintain an organizational structure with qualified staff 1. An organizational structure comprising PMU PICMC and appropriate resources to support environmental and social risk three (3) specialists (one management. To this end, the PIU shall mobilize qualified environmental, one social and one environmental, social and gender/GBV/SEA/SH specialists to manage gender/GBV/SEA/SH) shall be environmental and social risks, including Environmental and Social established within a maximum of 90 Specialists who will ensure the implementation and monitoring of days after the Project Effective Date. measures included in the instruments. 2. Rely on the Authority of Environment and Forests (DGEF) and its 2. The organizational structure, including island entities, NGOs, companies and engineering and control offices, the environmental, social and gender and municipalities for the monitoring and evaluation of environmental SEA/GBV/SH specialists shall be and social measures. maintained throughout the implementation of the Project. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT Adopt, disclose and implement the Environmental and Social Management ESMF for Component 2 "Maritime Safety PIU PICMC Framework (ESMF) specific to �Vessel Renewal Program" prepared for the and Vessel Renewal Program" disclosed Project, in a manner acceptable to the Association. before the appraisal of the Project ESMF shall be implemented throughout the duration of the Project. Page 5 of 13 1.3 MANAGEMENT TOOLS AND INSTRUMENTS The Borrower shall develop, adopt, disclose and implement the following tools PIU PICMC and instruments: 1. Environmental and Social Management Framework (ESMF) for 1. The final versions of the GBV Plan, Contractors (C- Component 1.2. “Improvement of secondary ports� and Component SEP, RPF, and LMP shall be finalized, ESMP) 2.2. “Vessel renewal program�; Action Plan for the Prevention, consulted upon and disclosed prior to Mitigation and Response to gender-based violence (GBV), Sexual Appraisal. The and the ESIA for the Exploitation and Abuse (SEA), and Sexual Harassment (SH) ; infrastructure improvement of Port Stakeholder Engagement Plan (SEP) including the project's Boingoma and ESMF haved been Grievance Redress Mechanism (GRM); Labor Management disclosed in the Country on January 8, Procedures (LMP); Resettlement Policy Framework; These 2022 and to WB external website on documents shall be prepared in parallel of technical studies and January 20, 2022. approved by the Association These instruments shall be implemented throughout Project implementation. 2. A Final Environmental and Social Impact Assessment (ESIA) including 2. Final version of the ESIA shall be Environmental and Social Management System for the infrastructure PIU PICMC approved and disclosed prior to improvement of Port Fomboni (Boingoma), Component 1.1 issuing the bidding documents for “Infrastructure improvement of Port Fomboni “ shall be prepared and procurement of Construction approved by the Association Contractor(s), and thereafter implemented throughout Project implementation. 3. The Final Environmental and Social Impact Assessments (ESIAs) 3. Final versions of the ESIAs shall be including Environmental and Social Management Systems (ESMPs) approved and disclosed prior to PIU PICMC for the three secondary ports (Chindini, Hoani and Vassy) shall be issuing the bidding documents for prepared and approved by the Association; procurement of Construction Contractor(s), and thereafter implemented throughout Project implementation Approval of ESIAs for the secondary ports will be considered condition of disbursement 4. Resettlement Action Plans (RAPs) and Livelihood Restoration Plans 4. RAPs and Livelihood Restoration PIU PICMC (LRPs) for the Component 1.1 “Infrastructure improvement of Port Plans shall be prepared, approved and Fomboni “and the Component 1.2. “Improvement of secondary ports� implemented prior to commencement and Component 2.2. “Vessel renewal program� shall be prepared by of any physical works. the Project, approved by the Association and implemented by the Preparation, approval and Project implementation of RAPs and Livelihood Restoration Plans of Port Boingoma, the secondary ports and Page 6 of 13 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY the “Vessel renewal program� will be considered conditions before the physical start of works. 5. Final of the C-ESMP and ESIA for the 5. the C-ESCP and the environmental and social management selected quarry sites shall be plan for the selected quarry sites shall be approved by the PIU PICMC approved and disclosed prior to Association implemented by the project . Contractor issuing the civil works and thereafter implemented throughout Project implementation. 6. The technical Assistance activities (operationalization of the Port 6. ToR for the TA activities shall be Authority, Enhancement of Maritime Safety, implementation Support) prepared by the project and approved shall be consistent with the ESSs. by the Association before launching PIU PICMC the Request of Proposal (RP) PORT AUTORITY 1.4 MANAGEMENT OF CONTRACTORS, SUPPLIERS AND SERVICE PROVIDERS During the preparation of the tender PIU PICMC Incorporate relevant aspects of the ESCP, including management tools and documents and before the instruments referred to in Section 1.3 above, into the ESHS specifications of commencement of works. the tender documents issued to Contractors. Ensure that these measures are applied Ensure that providers comply with the EHSS specifications of their respective during the entire period of the Project. contracts. Before the contract is signed and the physical start of works. 1.5 EMERGENCY RESPONSE COMPONENT (CERC) Prepare necessary instruments to cover CERC activities in case of emergency During the preparation of the CERC PIU PICMC to ensure compliance with the E&S provisions of the Project. Manual. The ESMF shall be updated and include the CERC activities. This ESMF shall Before the beginning of the emergency be approved by the Association intervention activities. CERC-specific E&S instruments shall be complied with throughout implementation of CERC activities. ESS2: LABOR AND WORKING CONDITIONS Page 7 of 13 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 2.1 LABOR MANAGEMENT PROCEDURES Develop and implement Labor Management Procedures (LMP) consistent with LMP shall be finalized prior to the PIU PICMC ESS2 and in a manner satisfactory to the Association. appraisal of the Project Contractors Prepare and approve site-specific LMPs as part of the Contractors’ ESMP (C- Before the commencement of the civil ESMP) and based on the LMP prepared for the project. works 2.2 PROJECT WORKER GRIEVANCE REDRESS MECHANISM (GRM) Establish and maintain GRM for any Project-related labor and employment Establish a PIU-based labor GRM within PIU PICMC matters (including SEA/SH), easily accessible to Project workers, in line with three (3) months of Project Effective Date ESS2 and national labor laws. and maintain it throughout project Contractors implementation. Establish GRM as part of the C-ESMP prior to the commencement of civil works and maintain it throughout duration of the works. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Adopt OHS measures consistent with ESS2 as part of LMPs under action 2.1 On timeframe specified in 2.1. PIU PICMC of this ESCP. Contractors Ensure Contractors develop and implement Occupational Health & Safety Develop and approve OHSPs before the Plans (OHSPs) following the WBG Environment, Health and Safety (EHS) commencement of works and implement Guidelines (for construction activities) and Industry Sector Guidelines for them throughout project implementation. Construction Materials Extraction. The OHSP will also include procedures on incident investigation and reporting, recording and reporting of non- conformance, emergency preparedness and response procedures and on- going worker training/awareness. ESS3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Page 8 of 13 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 3.1 WASTE AND HAZARDOUS MATERIALS MANAGEMENT 1. Develop and implement a Non-Hazardous and Hazardous Waste 1. The Waste Management Plan PIU PICMC Management Plan for the project, including the management of the shall be developed within three waste resulting from vessel decommissioning. Ensure that this plan is (3) months of Effective Date and consistent with the Recipient’s obligations under international treaties implemented throughout the and ESS1. physical works period 2. Identify waste management procedures prior to the start of activities and ensure compliance with the agreements established between 2. Before the commencement of the Contractors these managers and the project contractors physical works. 3. Ensure Contractors develop and implement site/specific Non- Hazardous and Hazardous Waste Management Plans. 3. Before the commencement of the physical works and implemented throughout the physical works period 3.2. RATIONAL USE OF RESOURCES AND POLLUTION PREVENTION AND MANAGEMENT Ensure resource efficiency and pollution prevention and management Same timetable as for the implementation PIU PICMC measures are adopted and implemented by contractors working on the of the ESMPs. Project. . ESS4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY PIU PICMC The contractor’s health and safety plan shall include traffic management To be developed as part of ESMPs. Contractors plan. To be implemented throughout the project 4.2 RISKS TO PUBLIC HEALTH AND SAFETY 1. Ensure Contractors develop and implement ESIA/ESMP measures 1. Measures to be included in site PIU PICMC and actions to assess and manage the risks and impacts associated specific ESMPs. Implemented Contractors with the implementation of Project activities to local populations, throughout the project including those related to the presence of Project workers and labor influx. 2. Before the start of the work, the contractors will have to prepare a 2. HSP and Security Risk Assessment to Health and Safety Plan (HSP) with a detailed analysis of the safety be prepared before the beginning of risks (including the risks related the use of security forces at the physical works construction sites). Specific safety measures such as access to site facilities will have to be addressed in these documents Page 9 of 13 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 4.3 RISKS OF SEXUAL EXPLOITATION AND ABUSE, GENDER-BASED VIOLENCE, AND SEXUAL HARASSMENT DURING PROJECT PIU PICMC IMPLEMENTATION Assess and manage the risks of SEA/GBV/SH related to the Project, including Action Plan for the Prevention, Mitigation on children, and develop an Action Plan accordingly. Conduct a mapping of and Response to SEA/GBV/SH to be the referral services available in the area and an assessment of their level of available prior to the appraisal of the functioning. The project will implement a specific mechanism for managing Project. cases of gender-based violence in terms of referral and prevention Measures to be included in site specific ESMPs. Implemented throughout the project ESS5: LAND ACQUISITION, LAND USE RESTRICTIONS AND INVOLUNTARY RELOCATION 5.1 RESETTLEMENT ACTION PLANS 1. Prepare and implement a Resettlement Policy Framework (RPF) for 1. RPF to be available prior to the PIU PICMC the project consistent with ESS5 and in a manner satisfactory to the appraisal of the Project Association. 2. Prepare Resettlement Action Plans (RAPs), in accordance with the 2. The final version of each RAP requirements of ESS 5 and national legislation for Biongoma and 3 shall be submitted to the secondary ports (Chindini, Hoani and Bimbini). Association for review and approval and shall be disclosed at the country level and on the WB 3. Prepare a Livelihood Restauration Plan (as required) for kwassa website. RAPs shall be kwassa operators. implemented before the start of civil works. 3. Prior to the start of work on Subcomponent 2.2 on “Vessel renewal program� ESS6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES Page 10 of 13 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 6.1 RISKS AND IMPACTS ON BIODIVERSITY 1. Implement biodiversity management measures, in line with the ESIAs 1. Application of measures throughout PIU PICMC guidelines of Component 1.1 “Infrastructure improvement of Port the implementation of components Fomboni “and the Component 1.2. “Improvement of secondary ports�. 1.1 and 1.2 These E&S measures shall be consistent with ESS6 and the obligations of the Recipient under relevant international treaties and agreements. The ESIAs for the three secondary port shall be submitted to the Association for approval prior to the issuance of the tender documents to suppliers/contractors. 2. Develop and implement a coral reef restoration plan in 2. Prior to the commencement of any collaboration with the forestry services before launching of physical works of Component 1.1 works. “Infrastructure improvement of Port Fomboni “and the Component 1.2. “Improvement of secondary ports�. ESS7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not relevant ESS8: CULTURAL HERITAGE 8.1 CHANCE FINDS 1. Consistent with ESS8 and to the satisfaction of the Association, prepare, PIU PICMC 1. Prior to the appraisal of the Project adopt and implement the incidental finding procedure described in the ESMP of Component 1.1 “Infrastructure improvement of Port Fomboni “and the Component 1.2. “Improvement of secondary ports�. 2. During preparation and prior to 2. Ensure that future specific E&S studies include an assessment of cultural implementation of sub-projects heritage sites in the area of influence of the sub-projects 3. During preparation of the bidding 3. Include the incidental finding procedure of cultural heritage in company documents for procurement of contracts Construction Contractor(s) Page 11 of 13 ESS9: FINANCIAL INTERMEDIARIES Not relevant ESS10: STAKEHOLDER MOBILIZATION AND INFORMATION 10.1 PREPARATION AND IMPLEMENTATION OF THE STAKEHOLDER ENGAGEMENT PLAN SEP to be prepared and approved by the PIU PICMC Prepare, adopt and disseminate a Stakeholder Engagement Plan Association by project appraisal (SEP). Implement the SMP Implemented the SEP throughout the Update and reissue the SMP as required. Project Implementation 10.2 GRIEVANCE REDRESS MECHANISM AT THE PROJECT LEVEL PIU PICMC Implement a Grievance Redress Mechanism for the entire project, GRM to be operationalized no later than as described in the SEP. This mechanism shall be structured to three months after the Project Effective report SEA/GBV/SH related complaints in a timely (within 72 hours) Date and thereafter maintained in a confidential, ethical, non-discriminatory and survivor-centered throughout Project implementation. manner. CAPACITY BUILDING (TRAINING) Type of training to be offered Schedule of training sessions Target groups RC1 TRAINING ON ENVIRONMENTAL AND SOCIAL STANDARDS APPLICABLE TO THE PROJECT Commencement of the project for the PIU PICMC • NES No. 1: Environmental and Social Assessment, PIU staff Island entities of PICMC • NES No. 2: Working and employment conditions, Involved Sate´s Technical • NES No. 3: Rational use of resources and pollution prevention Six (6) months after the Project begins services involved and management implementation for other stakeholders DGEF and its island entities • NES No. 4: Population Health and Safety ANAM • NES No. 5: Land acquisition, land use restrictions and Contractor and Supervision involuntary resettlement (ESS2, ESS4 and ESS8) • NES No. 6: Preservation of biodiversity and sustainable management of natural biological resources • NES No. 8: Cultural Heritage • NES No. 10: Stakeholder engagement and information. Page 12 of 13 RC2 TRAINING ON HEALTH AND SAFETY AT WORK Training of Project workers in occupational health and safety, Before the start of the work of the sub- PIU PICMC including emergency prevention, preparedness and response. projects. Island entities of PICMC Health and safety rules Solid and liquid waste management Public Suppliers/Contractors safety and security Navigation operators ANAM RC3 EMPLOYMENT AND WORKING CONDITIONS Before commencement of sub-projects Contractors Conditions of employment under national labour legislation ‘works Navigation operators Codes of conduct for suppliers, service providers and ANAM subcontractors Workers' organizations and trade unions Rules on child labour and the minimum age of admission to employment for children. RC4 SEA/GBV/SH Six (6) months after commencement of PIU PICMC Procedures for recording and handling complaints, archiving the Project. Island entities of PICMC Complaint Resolution Procedures Suppliers/Contractors Documentation and complaint handling Communities close to intervention Use of procedure by the different partners sites Raising public awareness Navigation operators SEA/SH awareness, prevention and mitigation measures Page 13 of 13