THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Adolescent Girls Initiative for Learning and Empowerment (AGILE) Project (P170664) ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) May 2020 1|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Federal Republic of Nigeria (the Recipient) is implementing the Adolescent Girls Initiative for Learning and Empowerment Project (the Project), with the involvement of the following ministries and bodies: The Federal Ministry of Education (FME) and the States selected to participate in the Project (Participating States). The International Development Association (the Association) has agreed to provide financing for the Project. 2. The Federal Republic of Nigeria through FME and Participating States will 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 a summary of material measures and actions and any specific documents or plans, as well as the timing for each of these. 3. The Federal Republic of Nigeria will also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as Environmental and Social Management Plans (ESMP), Resettlement Action Plans (RAP) and Stakeholder Engagement Plans (SEP), and the timelines specified in these E&S documents. 4. The Federal Republic of Nigeria is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry or Participating States, 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 Federal Republic of Nigeria 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 The Federal Republic of Nigeria, 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, The Federal Republic of Nigeria 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 Federal Republic of Nigeria. The Federal Republic of Nigeria 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 Federal Republic of Nigeria 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 3.0 – May 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Each Six (6) months throughout project FME and the Participating States. implementation Prepare and submit to the Association regular monitoring reports on the environmental, social, health and safety (ESHS) performance of the Starting December 2020 Project, including but not limited to the implementation of the ESCP, status of preparation and implementation of Environmental and Social documents required under the ESCP, stakeholder engagement activities, functioning of the grievance mechanism(s). B INCIDENTS AND ACCIDENTS Promptly and no later than 48 hours after FME and the Participating States. taking notice of the incident or accident. Promptly notify the Association of any incident or accident related to or Report to the Association. having an impact on the Project which has, or is likely to have, a significant adverse effect on the environment, the affected communities, A subsequent report would be provided the public or workers including without limitation any allegations of within a timeframe acceptable gender-based violence, Project-related occupational accidents or to the Association, as requested. fatalities, or labor unrest. Provide sufficient detail regarding the incident or accident, indicating immediate measures taken to address it, and include 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. C CONTRACTORS MONTHLY REPORTS Monthly FME and the Participating States. Contractors are required to provide monthly monitoring reports to the FME and the Participating States. The monthly reports would be submitted to the Association by the Federal Republic of Nigeria upon request. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 3|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – May 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 1.1 ORGANIZATIONAL STRUCTURE An organizational structure including the FME and the Participating States. Establish and maintain throughout project implementation an hiring of one (1) Environmental Specialist organizational structure with qualified staff and resources to support and one (1) Social Specialist will be management of Environmental & Social risks in sufficient numbers established within one month after project including at least one Environmental Specialist and one Social Specialist effectiveness in the State and Federal PIU. The organizational structure, including the specialists, should be maintained throughout Project implementation 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT The ESMF was disclosed on 29 January 2020 FME Adopt, disclose and implement the Environmental and Social and shall be implemented throughout Management Framework (ESMF) prepared for the Project, in a manner Project implementation. acceptable to the Association. The Recipient will prepare an ‘expanded ESMF’ within which a social assessment will be embedded. The assessment will help the Recipient understand the key social inclusion and risk issues and determine the potential impacts on different stakeholders. The ESMF, shall include a section on Labor Management Procedure and a social analysis that will identify key social inclusion and risk issues, and the impact on different stakeholders. 1.3 MANAGEMENT TOOLS AND INSTRUMENTS The ESMF, RPF, LMP and SEP were disclosed FME and the Participating States. Screen any proposed subproject in accordance with the ESMF prepared on 29rd January 2020 for the Project, and, thereafter, draft, adopt, and implement the subproject Environmental and Social Management Plan (ESMP), as ESMP(s) will be prepared once subproject required, in a manner acceptable to the Association. site is identified and prior to launching the bidding process. 4|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – May 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 1.4 MANAGEMENT OF CONTRACTORS Prior to launching bidding processes Participating States. Incorporate the relevant aspects of the ESCP, including the relevant E&S documents and/or plans, and the Labor Management Procedures and GBV/SEA Action Plan measures into the ESHS specifications of the procurement documents with contractors. Contractors will be evaluated based on inter alia their response to the E&S requirements. Thereafter ensure that the contractors comply with the ESHS Maintain procedures for management of specifications of their respective contracts. and ensure compliance by contractors and subcontractors throughout Project implementation 1.5 MANAGEMENT OF FEDERAL MINISTRY OF EDUCATION AND THE Before commencement of Project activities Recipient PARTICIPATING STATES. in a Participating State Incorporate the relevant aspects of the ESCP, including the relevant E&S documents and/or plans, the Labor Management Procedures, and the GBV/SEA Action Plan into the subsidiary agreement to be entered between the Recipient and the Participating States for the implantation of the Project. 10 STATE-LEVEL CAPACITY BUILDING Within the first year of Project FME and the Participating States. Conduct state-level institutional capacity assessment of implementing implementation agencies in selected states and implement capacity building activities to close identified gaps. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES The ESMF and LMP were disclosed on 29 FME and the Participating States. Update, adopt, and implement the Labor Management Procedure (LMP) January 2020 that have been developed for the Project and also included as a chapter in the ESMF. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Prior to engaging project workers and FME and the Participating States. Establish, maintain and operate a grievance mechanism for Project maintained throughout Project workers as described in the LMP and consistent with ESS2. implementation 5|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – May 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 2.3 CAPACITY BUILDING OF PROJECT WORKERS Within 2 months after project effectiveness FME and the Participating States. Implement capacity building of Project Workers to increase awareness of for FPCU and SPIUs and throughout Project social and environmental risks, code of conduct, mitigation measures implementation when relevant including the association's procurement processes and ESF. 2.4 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES ESMPs to be prepared once subproject site is FME and the Participating States. Prepare, adopt and implement occupational, health and safety (OHS) known and prior to launching bidding measures specified in the ESMPs. process and maintained throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT: 3.1 WASTE MANAGEMENT PLAN: This will be prepared as part of the FME and the Participating States. Prepare, adopt, and implement a Waste Management Plan, acceptable Environmental and Social Management to the Association, to manage the waste that may be generated from the Plan(s) to be prepared once subproject site minor civil works following the protocol of reduce, reuse and recycle. In is identified and prior to launching bidding addition, to encourage and promote energy efficiency, pollution process and implemented throughout prevention and management, the Recipient will use energy saving and Project implementation efficient bulbs including biodegradable materials where applicable. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: By commencement of civil works and FME and the Participating States. Adopt and implement measures and actions to assess and manage traffic maintained throughout Project and road safety risks as required in the ESMPs to be developed under implementation. action 1.3 above. 4.2 COMMUNITY HEALTH AND SAFETY: By commencement of civil works and FME and the Participating States. Prepare, adopt, and implement measures and action to assess and maintained throughout Project manage specific risks and impacts to the community arising from Project implementation. activities, and include these measures in the ESMPs to be prepared in accordance with the ESMF, in a manner acceptable to the Association. These may include, where relevant, mitigation measures to minimize/manage the risks/impacts associated with uncovered or barricaded or unfenced and/or unsigned hazardous such as excavated sites, trenches, and exposed electric cables. 6|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – May 2020 4.3 GBV AND SEA RISKS: The Recipient prepared a GBV Assessment FME and the Participating States. Prepare a Gender-Based Violence (GBV) Assessment to inform the and it was cleared by the Association on 26 development of the GBV Action Plan. February 2020. Prepare, adopt, and implement a stand-alone GBV/ SEA/SH Action Plan, Submit the GBV/ SEA/SH Action Plan for the to assess and manage the risks of GBV and sexual exploitation and abuse Association’s approval before the (SEA). The GBV/ SEA/SH Action Plan will be reviewed bi-annually and preparation of the procurement documents updated annually by the respective project implementing entities in a for works/Project activities at a school. Once manner acceptable to the Association. approved, the GBV/ SEA/SH Action Plan is maintained and implemented throughout Project implementation. 4.4 SECURITY RISKS: The SRA will be developed before the FME and the Participating States. Given the inclusion of Borno State, as well as potential security risks in carrying out of the respective Project activity other participating states, the Recipient shall prepare a Security Risk and no later than within 6 months of Project Assessment (SRA). Where relevant, as part of the ESMP, the Recipient Effectiveness. will prepare, adopt, and implement a Security Personnel Management Plan consistent with the requirements of ESS4, in a manner acceptable to The Security Personnel Management Plan the Association. In implementing the security risk prevention and shall be adopted and implemented in a mitigation measures, the Recipient will be guided by the principles of manner satisfactory to the Association, prior proportionality and Good International Industry Practice (GIIP), and by to engaging security personnel and applicable law, in relation to hiring, rules of conduct, training, equipping, thereafter implemented throughout Project and monitoring of security personnel. implementation. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT: 5.1 RESETTLEMENT PLANS: The project is not planning to finance activities The RPF was disclosed and adopted on 29 FME and the Participating States. that will involve land acquisition, restrictions on land use, or involuntary January, 2020 and shall be maintained resettlement. Nonetheless, risks remain as a result of the possibility of throughout Project implementation. displaced people occupying abandoned schools that are identified for refurbishment. Prior to any refurbishment or renovation of schools, the recipient will prepare, adopt, and implement resettlement plans (RAPs) RAPs to be prepared once subproject site is in accordance with ESS 5 and consistent with the requirements of the known and prior to launching bidding Resettlement Policy Framework (RPF) that has been prepared for the process Project, and thereafter adopt and implement the respective RAPs before carrying out the associated activities, in a manner acceptable to the Association. 5.2 GRIEVANCE MECHANISM Prior to commencement of resettlement FME and the Participating States. Prepare, adopt, maintain and operate a grievance mechanism to address activities. resettlement related complaints, as described in the SEP. 7|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – May 2020 ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES: 6.1 BIODIVERSITY RISKS AND IMPACTS: Prior to construction of structure that may FME and the Participating States. Prepare, adopt, and implement site specific ESMPs that include mitigation affect biodiversity. measures to minimize and manage the risks and impacts associated with natural habitats, in accordance with the guidelines of the ESMF prepared ESMP(s) shall be prepared once subproject for the Project, and in a manner acceptable to the Association. site is identified and prior to launching the bidding process and implemented throughout the project. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES. There are no Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities in the Project area. Therefore, ESS7 is not relevant for the Project. ESS 8: CULTURAL HERITAGE: 8.1 CHANCE FINDS: Environmental and Social Management FME and the Participating States. The project will not finance activities that will affect cultural heritage Plan(s) including Chance Find Procedure however, the treatment of Physical Cultural Resources (PCR) including acceptable to the Association will be archaeological relics, fossils, human graves, shrines, sacred trees or prepared once subproject site is identified groves that may be encountered will follow a Chance Finds Procedure and prior to launching the bidding process. that will be elaborated, adopted and implemented as described in the Implemented throughout Project ESMP.s implementation. ESS 9: FINANCIAL INTERMEDIARIES: The Project will not involve the use of financial intermediaries. ESS9 not relevant. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND The SEP was disclosed on 29 January 2020. FME and the Participating States. IMPLEMENTATION SEP to be implemented throughout Project Prepare, adopt, disclose, and implement the Stakeholders Engagement implementation. Plan (SEP), including GRM. SEP to be incorporated into the Project’s management system, adequate staffing and budget will be allocated for the implementation of the SEP. 10.2 PROJECT GRIEVANCE MECHANISM: Grievance mechanism to be established by FME and the Participating States. Prepare, adopt, maintain and operate a grievance mechanism, as Effectiveness and operated throughout described in the SEP. Project implementation. 8|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – May 2020 CAPACITY SUPPORT (TRAINING) CS1 Training of Project team on the Association procurement processes and Within two months after effectiveness and FME and the Participating States. ESF for project workers throughput the project as required CS2 Training on occupational health and safety for project workers Prior to commencement of civil workers and FME and the Participating States. as required during project implementation Funding from project budget 9|Page