REPUBLIC OF SIERRA LEONE Ministry of Basic and Secondary School Education (MBSSE) FREE EDUCATION PROJECT ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) May 2019 1|Page World Bank MBSSE/ FREE Education Project ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Ministry of Basic and Secondary School Education (MBSSE) of Sierra Leone is planning to implement the FREE Education Project (the Project). The International Development Association hereinafter the Bank/the Association] has agreed to provide financing for the Project. 2. The MBSSE 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 a summary of the material measures and actions. 3. Where the ESCP refers to specific plans or other documents, whether they have already been prepared or are to be developed, the ESCP requires compliance with all provisions of such plans or other documents. In particular, the ESCP requires compliance with the provisions set out in the Environmental and Social Management Plan and Resettlement Action Plan that have been developed for the Project. 4. The table below summarizes the material measures and actions that are required as well as the timing of the material measures and actions. MBSSE is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry, agency or unit referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Bank/Association by MBSSE as required by the ESCP and the conditions of the legal agreement, and the Bank/Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank/Association and MBSSE, 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, MBSSE will agree to the changes with the Bank/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 Bank/Association and the MBSSE. The MBSSE will promptly disclose the updated ESCP. Depending on the project, the ESCP may also specify the funding necessary for completion of a measure or action. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the MBSSE shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include environmental, health, and safety impacts, labor influx, gender-based violence. 2|Page [FREE Education Project] ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Date of Completion Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed ESCP Monitoring and Reporting REGULAR REPORTING: Quarterly throughout MBSSE, through the Throughout the Project life time. MBSSE will prepare and submit regular monitoring reports on the project FREE Education implementation of the ESCP. The report will among others implementations Project Secretariat be include (i) status of implementation of the ESCP; (ii) conditions, if responsible for any, which interfere or threaten to interfere with the funding and submitting implementation of the ESCP; and (iii) corrective and preventive updated ESCP for measures taken or required to be taken to address such conditions. review, discussion and agreement with the Bank INCIDENTS AND ACCIDENTS NOTIFICATION: Within 48 hours and Project Contractors Throughout the Project life time. project will promptly notify any incident or accident related or no later than 72 hours will be responsible for having an impact on the Project which has, or is likely to have, a after occurrence of the submitting significant adverse effect on the environment, the affected incident or accident. incident/accidents communities, the public or workers including situations of reports to the FREE fatalities or serious bodily harm and incidents of Gender Based Education Project Violence. The report will include sufficient detail regarding the Secretariat of MBSSE incident or accident, indicating immediate measures taken to address it, and include information provided by any contractor and FREE Education supervising entity, as appropriate. Incidents and accidents include Project Secretariat of kidnapping, GBV, communicable diseases, violence, fatalities, MBSSE will submit infectious, all fires, and occupational injuries. incident reports to the Bank 3|Page SUMMARY ASSESSMENT ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE: The FREE Education The MBSSE/FREE The E&S Specialists at the Free FREE Education Project Secretariat of MBSSE shall establish an Project Secretariat of Education Project are Education Project Secretariat EHS desk with qualified E&S experts (Environmental Specialist, the MBSSE with E&S responsible for will be at post until project social and Gender Specialist) Specialists will be set funding the setting up completion The FREE Education Project Secretariat E&S Specialists will be up at least 3 months and operations of the supported by Environment and Social Officers at the Regional and after project EHS Unit District levels to implement the project. This structure will be effectiveness. maintained throughout Project implementation. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT: Undertaken once site FREE Education Prior to commencing of the Subprojects will be screened per the procedures outline in the project locations are Project Secretariat of Subproject civil works ESMF as sites are identified. Based on the screening results, identified and prior to MBSSE to supervise detailed environmental and social assessments may be conducted the start of civil works the impact assessment and accompanied by the relevant ESMPs to address any risks which is part of the studies. Funding for identified during the process. The ESIA will include the second- year consultancy services assessment of GBV risks. investments. shall be covered by the FREE Education Project 1.3 MANAGEMENT TOOLS AND INSTRUMENTS: Develop, The ESMF, RPF, and MBSSE/ through Before project appraisal adopt, consult on and disclose an Environmental and Social SEP will be completed consultants / funding Framework (ESMF), Resettlement Policy Framework (RPF), prior to project from the Project Stakeholder Engagement Plan and Environmental and Social appraisal budget Commitment Plan (ESCP) satisfactory to IDA. Secure environmental permits for all new construction and prior to the start of MBSSE/ through E&S Prior to commencement of civil rehabilitation under the FREE Education Project civil works consultants works. Develop sub Subprojects Screening Forms and Impacts Checklist Prior to construction MBSSE/ through Prior to commencement of civil Forms as part of the ESMF to be used to screen all sub-project to of school consultants works determine requirement for follow ESHIA, ESMPs, RAPs etc infrastructure which is part of the second- year investments. 4|Page Environmental and Social Management Plans (ESMPs) and prior to the start of FREE Education Prior to commencement of civil Resettlement Action Plan will be prepared and disclosed. civil works Project E&S works Environmental and Social Assessment process for subprojects will specialists. be done after Subprojects screening. Draft Labor Management Procedures to be included in ESMF. Throughout project MBSSE/ consultant/ Throughout project Contractor is required to Update this into a Labor Management implementation contractor/ funding implementation Plan and ensure compliance during implementation. from project budget Implement ESMP, RPF, SEP Throughout project MBSSE/ FREE Throughout project implementation Education secretariat/ implementation funding from project budget. Detailed GBV Assessment to be carried out during ESHIA studies Prior to MBSSE/ through Prior to commencement of civil and action plan to be developed by contractor as part of contractor commencement of civil consultants/ works ESMP. works contractor. 1.4 MANAGEMENT OF CONTRACTORS: prepared together MBSSE /FREE Throughout the Project MBSSE shall develop and implement Labor management Plan for with C-ESMP before Education Project implementation managing contractors and subcontractors: commencement of civil Secretariat, E&S • environmental and social requirements will be included in works. specialist, procurement the procurement and contracting process including bidding officer. Funding from documents, for potential civil works. the project budget. • relevant requirements are included in contracts and subcontracts (reflecting ESSs and ESCP); • codes of conduct are required of contractors and subcontractors and their workers to prohibit sexual harassment and exploitation and training of workers on their obligations under the CoC. • Contractor to prepare a costed GBV Action Plan as part of the contractor ESMP. • Preparation of a detailed contractor ESMP (C-ESMP) that is costed, with sufficient budget to mitigate E&S risks • Monitor Contractor commitment and compliance 5|Page • Ensure contractors provide details on contractor’s oversight on environmental, social, health and safety (ESHS) performance • Contractor to develop a grievance redress mechanism to handle concerns of their employees • MBSSE has developed a Labor Management Procedure Which Contractors shall update into a plan and comply with during Implementation. 1.5 PERMIT, CONSENTS AND AUTHORIZATIONS: All authorization shall MBSSE is responsible Permits will be renewed as MBSSE shall facilitate the issuance of the environmental permits be obtained prior to for obtaining stipulated in the permit and all necessary authorization from ministries, departments and mobilization of Environmental condition until the end of the agencies (MDA), such as EPASL. contractors licenses. The cost of project obtaining the licenses MBSSE shall ensure that the contractor complies with the Renewal of permits shall be covered by the conditions established in these permits, consents and will be the project. Contractor authorizations throughout Project implementation. responsibility of the shall obtain any other MBSSE relevant license during implementation. 1.6 THIRD PARTY MONITORING: a third party shall be engaged Third party MBSSE to hire the Monitoring continues until to complement and verify the monitoring of environmental and monitoring will be services of a completion and social risks and impacts of the Project. done annually. consultant. Payment decommissioning of project for monitoring is to be Project will also conduct RAP completion audit following RAP completion audit covered by the project completion of RAP implementation and ESMP audit 3 months done after RAP before completion of civil works. implementation and ESMP Audit done 3 months before completion of works. 1.7 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES: MBSSE/ E&S Effective throughout the project Labor management procedures (LMP) has been developed by the Prior to the specialists shall ensure life, and reviewed on a quarterly MBSSE. The LMP set out the way in which project workers will preparation of that the selected basis be managed, in accordance with the requirements of Sierra Leone procurement contractor meets these national law and ESS 2. The plan will address the way in which documents. requirements ESS2 will apply to different categories of project workers, 6|Page including direct workers, and the way in which the Borrower will Maintain procedures require third parties to manage their workers. The contractor will throughout Project be required to update the Labor Management Procedure into a implementation. Plan during implementation and comply with its requirement. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: prior to recruitment of MBSSE shall ensure Effective throughout the project The contractor shall develop and implement a GRM for their staff, staff or workers and that the mechanism is life, and reviewed as and when and this shall be approved by the FREE Education Project Secretariat implemented in place before necessary of MBSSE and the Bank. throughout Project recruitment of staff is implementation. conducted by contractor; 2.3 OHS MEASURES: Prior to initiating MBSSE/ FREE Effective throughout the project Contractors working on the Project shall develop and implement construction, and Education Project life, and reviewed as and when approved occupational, health and safety (OHS) plan/measures. implemented Secretariat / E&S necessary throughout Project life Specialists/ Contractor’s Health and safety officer and MBSSE E&S specialists Contractors shall train/orient employees of Project Contractors on various aspects of OHS relevant to the project 2.4 EMERGENCY PREPAREDNESS AND RESPONSE: Prior to initiating MBSSE/ FREE Effective throughout the project Emergency Preparedness and Response measures incorporated in construction. Education Project life, and reviewed as and when OHS measures guideline as part of subproject screening Maintained Secretariat / E&S necessary ESIAs/ESMPs prior to commencement of works. throughout Project Specialists/ implementation. Contractors. This is covered by the project 2.5 PROJECT WORKERS TRAINING: Prior to initiating MBSSE/ FREE Periodically throughout the Health and Safety training shall be provided to employees of construction, with Education Project project life, and revisited as and Project Contractors by the contractor Health and Safety officer. quarterly refresher Secretariat / E&S when necessary and task-specific Specialists/ are training sessions responsible for during the entire providing oversight of construction phase compliance with Health and Safety Requirements 7|Page 2.6 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 MANAGEMENT OF WASTE AND HAZARDOUS Waste management Contractor/ MBSSE Effective throughout the project MATERIALS: plan as part of ESMP FREE Education life, and reviewed as and when Project Contractors shall develop and implement a general waste and applied Project Secretariat/ necessary management plan including hazardous materials and chemicals. throughout Project Project Environmental The plan would be annexed to the ESMP. implementation. specialist. funding covered by the project 3.2 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Prior to initiating MBSSE/ FREE Effective throughout the project Project Contractors shall be required to develop and implement construction. Education Project life, and reviewed as and when measures and actions in the sub project ESMPs to assess and Maintained Secretariat / E&S necessary manage traffic and road safety risks. throughout Project Specialists/ implementation. 4.2 COMMUNITY HEALTH AND SAFETY: Prior to initiating MBSSE/ FREE Effective throughout the project The Project ESMF shall guide the Contractors to develop and construction and Education Project life, and reviewed as and when implement adequate measures and actions to assess and manage employee recruitment. Secretariat / E&S necessary specific risks and impacts to the community and beneficiary Maintained Specialists/ shall schools arising from project activities. throughout Project ensure that the Contractors measures, and work methods shall be validated by the implementation. document is approved local authorities and SMCs and approved by the FREE Education and available prior to Project Secretariat MBSSE commencement of construction activities as well as supervise implementation of the CHS by the contractor. 4.3 GBV AND SEA RISKS: Services of a MBSSE/ FREE Effective throughout the project GBV and SEA risks to be assessed as part of social assessment GBV/SEA service Education Project life, and reviewed as and when and ESHIA. Project to hire a local NGO to assist in GBV provider NGO will be Secretariat / project necessary response including supporting the design of GBV sensitive GRM, recruited prior to E&S Specialists/ training and awareness raising on GBV for the local communities contractor Contractors. Funding and MBSSE, ensure that care seeking behaviors and knowledge of mobilization and as part of project cost. how and where to report GBV cases are known and support Maintained 8|Page survivors to receive appropriate support services throughout Project (medical/physical-social counseling and legal aid as agreed with implementation. the survivor). While the services of a gender-based NGO working in the project area is solicited to handle GBV and SEA, the contractor shall develop a well costed GBV action Plan and strictly abide by the measures provided. 4.4 GBV AND SEA RISKS DURING PROJECT Monitoring of MBSSE/ FREE Effective throughout the project IMPLEMENTATION: GBV action plan will be required by the compliance to Education Project life contractor as part of C-ESMP with adequate funding for contractor GBV Secretariat / project implementation. Action Plan E&S Specialists/ throughout the Contractors/ GBV implementation period service provider. of the project Funding as part of contractor cost for ESMP implementation 4.5 EMERGENCY RESPONSE MEASURES: ESMPs will be MBSSE/ FREE Effective throughout the project The contractor shall implement emergency preparedness and available prior to Education Project life, and reviewed as and when response plan in project ESMPs. initiating construction. Secretariat / project necessary Maintained E&S Specialists/ throughout Project Contractors. implementation. 4.6 SECURITY PERSONNEL: Not relevant for this The project and its contractors will not use military or paid project security forces for site security. 4.7 TRAINING FOR THE COMMUNITY: Prior to initiating MBSSE/ FREE Periodically throughout the MBSSE through the consultant shall conduct training for the construction, with Education Project project life, and revisited as and community designed to heighten awareness of risks and to regular refresher Secretariat / project when necessary mitigate impacts specified including: training sessions E&S Specialists/ • communicable diseases/HIV-AIDS/STI awareness and Contractors. cost prevention covered by the project • community grievance redress mechanism as described in the Stakeholder Engagement Plan/ ESMF/RPF • process for resolving conflicts between workers and community members • GBV and SEA and Child protection. 9|Page 4.8 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 LAND ACQUISITION AND RESETTLEMENT: Prior to the MBSSE/ FREE Before commencement of The Project has prepared a Resettlement Policy Framework construction of school Education Project construction works (RPF) which will be disclosed prior to appraisal. The RAP will be physical infrastructure Secretariat / project prepared as required when subproject locations are identified which is part of the E&S Specialists/ will second- year ensure that the RAP investments has been done consistent with ESS 5 before mobilization of contractor 5.2 RESETTLEMENT PLANS: RAPS will be MBSSE/ FREE Before commencement of A RAP shall be developed by a consultant, appointed by MBSSE implemented Prior to Education Project construction works or consultancy firm as appropriate and implemented by MBSSSE the construction of Secretariat / E&S and the consultant, when subproject locations are identified, and it school physical Specialists/. Cost is determined that activities will involve involuntary resettlement. infrastructure which is internalized as part of part of the second- project cost year investments. 5.3 MONITORING AND REPORTING: part of project MBSSE through the Throughout project life MBSSE shall ensure that monitoring and reporting on land quarterly reports project E&S acquisition and resettlement activities are conducted throughout specialists and the project as part of project regular reporting channels and independent third- separately as requested by the World Bank. party monitors shall ensure that the RAP has been implemented, monitored and documented according to ESS5 before mobilization of contractor 5.4 GRIEVANCE MECHANISM: In place and MBSSE shall ensure a Throughout project life A Grievance Redress Mechanism (GRM) is being developed as functional 3 months GRM has been set up part of the ESMF and RPF will be completed before after project and is being commencement of project activities. The GRM will incorporate effectiveness and prior implemented before existing GRM systems in place at the MBSSE and the local level. to mobilization of 10 | P a g e contractor for civil mobilization of works. contractor 5.5 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: Prior to commencing MBSSE/ FREE prior to commencement of civil The project will screen subproject activities using the screening sub-project civil Education Project works tool developed under the ESMF to determine potential works. Secretariat, E&S biodiversity risks and impacts and make recommendations. specialist. funding from project budget Sites within one (1) kilometre radius of natural and critical habitats or environmentally sensitive areas shall be declared ineligible for construction during the screening and site selection Work shall not be carried out in sensitive ecosystems/habitats/species, such as protected areas, forests, wetlands and IUCN listed species to avoid elaborate offsets and project delays. The Project will also consider the views, roles, and rights of groups, including local non-governmental organizations (NGOs) and local stakeholder communities, and involve such in planning, designing, implementing, monitoring, and evaluating the project. Involvement may include identifying appropriate conservation measures, managing protected areas and other natural habitats, and monitoring and evaluating specific actions 6.2 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.3 GRIEVANCE MECHANISM: N/A NA 7.4 Add other measures and actions that have been agreed, as per the specific risks and impacts of the Project N/A ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS: Prior to the MBSSE/ FREE Throughout project life The contractor shall implement a Chance Find procedure in line Commencement of Education Project with the ESMF/ESMP in preparation for any ‘chance’ or civil Works as part of Secretariat / E&S accidental finds during the project. the sub project specialists 11 | P a g e In the event of a find, the Monuments and Relics Commission screening and Site (MRC) that is entrusted with the protection of cultural heritage in Selection Sierra Leone shall be contacted. 8.2 CULTURAL HERITAGE: Prior to the FREE Education Throughout project life The project will take cognizance of tangible and intangible Commencement of Project Secretariat cultural heritage sites and items, including potential archaeological civil Works as part of MBSSE/ Contractors heritage within the project’s area of influence. The Project will the sub project adopt measures such as undertaking meaningful consultations with screening and Site stakeholders regarding cultural heritage and implementing basic Selection mitigation measures at the construction phase, such as a chance find procedure. 8.3 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 9: FINANCIAL INTERMEDIARIES 9.1 ESMS: Not relevant Not relevant to this project since there are no FIs involved in this project. However, the project will be guided by this standard when applicable. 9.2 FI ORGANIZATIONAL CAPACITY: Not relevant Not relevant 9.3 SENIOR MANAGEMENT REPRESENTATIVE: Not relevant Not relevant 9.4 Add other measures and actions that have been agreed, as per the None specific risks and impacts of the Project ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 SEP PREPARATION: Prior to appraisal MBSSE/ FREE SEP was ready by appraisal but MBSSE has prepared and shall disclose a Stakeholder Education Project will be reviewed and updated Engagement Plan (SEP) for the design and implementation of the Secretariat. Cost is quarterly project prior to appraisal. covered by the project 10.2 SEP IMPLEMENTATION: Implement the SEP. Throughout Project MBSSE/ FREE Throughout project life MBSSE resources, such as the communications office and the implementation Education Project control room shall be leveraged in engaging stakeholders. 12 | P a g e Stakeholder engagement has commenced and shall continue Secretariat. Cost is throughout the life of the project covered by the project 10.3 PROJECT GRIEVANCE MECHANISM: Develop and Grievance Mechanism MBSSE/ FREE Continuously throughout project implement the arrangements for the grievance mechanism. in place prior to Education Project duration See sections 2.2 and 5.4 appraisal, to be Secretariat and updated and grievance committee. maintained Cost is covered by the throughout the Project project implementation. 10.4 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project Capacity Support Specify Training to be provided Specify Targeted Groups and Specify Training Completed Timeframe for Delivery Contractor Training may be required in: MBSSE, District Engineers and World Bank ESF • Stakeholder engagement Environmental Health Officers, Community Entry and Mobilization • Subproject Environmental and Social screening SMCs, Project Consultants, Handling Grievances • Specific aspects of environmental and social Contractors and workers. this will be Basic Health and Safety Procedures assessment done before commencement of civil Environmental and Social Reporting • Occupational Health and Safety works. • Emergency preparedness and response • Community health and safety • Monitoring and Reporting • Gender-Based Violence Risk Mitigation • Disability inclusion training • GRM • Waste management (domestic solid wastes and sewage) • Documentation and reporting • Labor management procedures Training for community people shall include: Regional and district representatives, Training shall commence at project implementation • Traffic safety and Road signage a cross section of chiefdom and • Grievance redress and conflict resolution community people • Environmental, social and safety impacts of the project and their mitigation • Community Health and Safety • GBV and child protection 13 | P a g e • All trainings cost will be costed as part of project and contractor costs as appropriate. 14 | P a g e