Recovery & Advancement of Informal Sector Employment (RAISE) STAKEHOLDER ENGAGEMENT PLAN (SEP) Palli Karma-Sahayak Foundation (PKSF) Aug 2020 Acronym BMET Bureau of Manpower, Employment and Training BTEB Bangladesh Technical Education Board COVID-19 Corona Virus Infection Disease-19 DoSS Directorate of Social Services FGD Focus Group Discussion FID Financial Institutions Division GoB Government of Bangladesh GRC Grievance Redress Committee GRM Grievance Redress Mechanism GRS Grievance Redress Service ICT Information and Communication Technology IDA International Development Association IFC International Finance Corporation IPOs Implementing Partner Organizations JCF Jagoroni Chakra Foundation MIS Management Information System NGO Non- Governmental Organization NSDA National Skills Development Agency PKSF Palli Karma-Sahayak Foundation PMU Project Management Unit POs Partner Organizations PWD Persons with Disabilities RCCE Risk Communication and Community Engagement RPL Recognition of Prior learning RRF Rural Reconstruction Foundation RAISE Recovery & Advancement of Informal Sector Employment SEIP Skills for Employment Investment Program SEP Stakeholder Engagement Plan SNF Shishu Niloy Foundation USD US Dollar WB World Bank WHO World Health Organization 2 Table of Contents EXECUTIVE SUMMARY .................................................................................................................... 4 1. Introduction and Project Description ......................................................................................... 6 1.1 Introduction and Rationale for Stakeholder Engagement Plan ..................................................... 6 1.2 Institutional and Sectoral Context, Project Description, Location and Beneficiaries ................... 6 1.3 Summary of Environmental and Social Impacts........................................................................... 7 2. Legal Regulations and Requirements ......................................................................................... 8 2.1 Key National Legal Provisions .................................................................................................... 8 2.2 World Bank Requirements .......................................................................................................... 10 3. Previous Stakeholder Engagement Activities and Lessons Learnt ........................................ 10 3.1 Previous Consultations and Engagement .................................................................................... 10 3.2 Salient Issues from Engagement ................................................................................................. 13 4. Stakeholder Identification and Analysis ................................................................................... 13 4.1 Stakeholder Category, Identification and Analysis ..................................................................... 13 4.2. Stakeholder Mapping and Further Categorization ..................................................................... 22 5. Program for Stakeholder Engagement ..................................................................................... 22 5.1 Objective and Adaptiveness to Covid-19.................................................................................... 22 5.2 Proposed Mechanisms for Information Disclosure ..................................................................... 23 5.3 Proposed Mechanisms for Consultation ..................................................................................... 27 5.4 Proposed Mechanism for Feedback Loops and Future Communication .................................... 31 6. Grievance Redress and Feedback Mechanism ......................................................................... 31 6.1 Justification on Cultural and Contextual Appropriateness of Project-Specific Grievance Redress and Feedback Mechanism ................................................................................................................. 31 6.2 Receipt to Remedial of Grievance Redress and Feedback Mechanism ...................................... 32 6.3 Communication and Advocacy on Grievance Redress and Feedback Mechanism .................... 33 6.4 Monitoring, Evaluation and Reporting on Processing of Grievances and Feedback .................. 33 6.5 World Bank Grievance Redress Service ..................................................................................... 34 7. Monitoring, Evaluation and Reporting ..................................................................................... 34 7.1 Mechanisms for Stakeholder Participation ................................. Error! Bookmark not defined. 7.2 Reporting Arrangements with Stakeholder Groups .................................................................... 34 7.3 Results Monitoring and Evaluation Framework ......................................................................... 35 8. Resources and Responsibilities for Implementing Stakeholder Engagement Activities ...... 35 3 8.1 Management Functions and Responsibilities .............................................................................. 35 8.2 Financial and Human Resources ................................................................................................. 36 List of Tables Contents Page Table 1: Summary of Previous Stakeholder Engagement 11 Table 2: Description of Project-Specific Stakeholder Groups and Interested Parties 14 Table 3: Vulnerable or Disadvantaged Stakeholders, Their Circumstances and 16 Engagement Mechanisms Table 4: Disclosure Methods for Relevant Information Products 24 Table 5: Stakeholder Consultations and Corresponding Engagement Mechanisms 27 Table 6: Monitoring, Evaluation and Reporting of Stakeholder Engagement 35 Processes Table 7: Tentative Budget to Implement Stakeholder Engagement 36 4 Executive Summary This Stakeholder Engagement Plan (SEP) has been developed by PKSF to maintain and ensure the process of continuous taking part with the different stakeholders in the course of implementation of the Recovery & Advancement of Informal Sector Employment (RAISE) project. PKSF considers the process of engaging stakeholders is important for successful implementation and attaining the goal of the project. During the preparation stage of the SEP, a series of stakeholder consultations were taken place which pave the way for constructing a robust stakeholder engagement plan for the RAISE project. Formerly, the Active Labor Market Program initiated the consultations of PKSF and its POs for preparing the project for the informal sector of Bangladesh. PKSF being the apex body of the MFIs always ensured transparency and greater participation of the beneficiaries. Thus this stakeholder engagement plan attempted to address the maximum stakeholders of this project and portrayed their roles according to their engagement in this project. To achieve above mentioned objective, the SEP will be considered as a public document and open for discussion with the stakeholders subject to regular revision to remain up-to-date. The first draft of the SEP has already been disclosed with stakeholder consultation feedback. The SEP followed the legal regulations and requirements of the GoB and also complied with the international protocols. It also analyzed the previous stakeholder engagement activities and figured out the lessons learnt to apply the best practices in designing the stakeholder engagement program. A suitable grievance redress and feedback mechanism was designed considering the country context. The Monitoring, Evaluation and Reporting system has designed through an integrated system so that throughout the project implementation all interested parties are kept informed. The SEP will act as a guide to ensure the accountability of the implementing agency. 5 Stakeholder Engagement Plan (SEP) 1. Introduction and Project Description 1.1 Introduction and Rationale for Stakeholder Engagement Plan Stakeholder engagement and communication is critical to ensuring transparency, accountability and effectiveness of development and investment project financing. Timely and two-way information sharing and communication can help mobilize and maintain stakeholder support for the project and advance overarching project objectives Consequently, this Stakeholder Engagement Plan (SEP) represents the commitment of the Government of Bangladesh (GoB) and lays out its strategy to engage stakeholders associated with the World Bank-financed Bangladesh: Recovery and Advancement of Informal Sector Employment (RAISE). The Project’s Component 1, 2 and 4.1 will be implemented by the implementing agency— Palli Karma-Sahayak Foundation (PKSF). The purpose of this SEP is to define a program for stakeholder engagement, including public information disclosure and consultation, throughout the lifecycle of the Project. It outlines means in which various stakeholders are identified and includes a mechanism through which they each can raise concerns, provide feedback, or make complaints related to project activities and their execution. Such an engagement begins during inception and be based on prior disclosure and dissemination of relevant, transparent, objective, meaningful and easily accessible information in a timeframe that enables meaningful consultation with stakeholders in a culturally appropriate format, in relevant local languages and is understandable to stakeholders. Doing so enables stakeholders to understand the risks and impacts of the project as well as potential opportunities. The SEP is a living document and will be updated throughout project implementation based on feedback and information received through continued consultation throughout the lifecycle of the Project. 1.2 Institutional and Sectoral Context, Project Description, Location and Beneficiaries With the informal sector in Bangladesh being disproportionately affected in the aftermath of the pandemic, the need for targeted labor market program is more critical than ever before, with low-income youth and involuntarily returned migrants being most severely affected. Yet, existing Active Labor Market Programs predominantly offer short-term technical and vocational training suited for formal sector employment, thus neglecting constraints facing low-income youth and returning migrant labor that limit their access to income generation opportunities and restrict them instead to low-return low-income economic activities. Poor educational attainment within the youth population, with only about 6.8 years of education on average, confines 44 percent of those employed in informal wage labor and another 17 percent in own microenterprises. Youth from poorer households are less likely to have well-developed personal networks, particularly if they are rural-urban migrants, which penalizes them within formal job-matching system, access to informal employment and expansion of their small-scale ventures. Female labor force participation is further inhibited by social norms, insecurity and household labor. Experiencing a similar set of constraints, involuntarily returned migrants experience even more disadvantaged in the absence of initiatives to support their transition back to the domestic economy. Based on this, through 200M USD in credits from the International Development Association and another 100M USD in co-financing from the counterpart, the Recovery and Advancement of Informal Sector Employment Project seeks to enhance access to improved income earning opportunities for low income youth and entrepreneurs including 6 COVID-affected enterprises in urban and peri-urban areas.1 It is composed of four inter-related components: ▪ Component 1 (PKSF): Program Design and Systems Development, which supports development of life skills, self-employment and business management curriculum, and corresponding training to Partner Organizations, master craftsmen and relevant project- level staff to deliver them, and an accompanying case-based Information, Counseling and Referral Systems to identify, provision and track services provided to eligible participants. ▪ Component 2 (PKSF): Economic Inclusion Programming, which facilitates community engagement, identification and profiling and eventually life skills training, informal apprenticeships, microenterprise development and access to microfinance to eligible beneficiaries. ▪ Component 3 (WEWB): Reintegration for Returning Migrants, that provisions field offices, psychosocial support, training referral and stipend to returnee migrants as well as provisions of integrated database. ▪ Component 4 (PKSF 4.1 and WEWB 4.2): Project Management and Implementation that finances operational activities of the Project Management units within PKSF and their partner organizations, including associated capacity strengthening initiatives. ▪ Component 5: Contingent Emergency Response Component, a provisional zero amount component to enable rapid reallocation of loan proceeds from other components in the event of eligible emergencies 1.3 Summary of Environmental and Social Impacts Environmental risks associated with Project activities largely emanate from threats to resource efficiency and biodiversity owing to beneficiaries either matched with economic opportunities utilizing environmentally damaging technologies or engaging in microenterprises with deleterious consequences. To that end, an eligibility criteria, composed of the IFC’s exclusion list and additional negative list to screen out activities with more than moderate risks, is being put in place. This is complemented by a screening mechanism requiring individual entrepreneurs, industry partners employing informal laborers and beneficiary microenterprises to exercise environment-friendly practices and leave only minimal environmental footprint. Thus, environmental risks posed are considered moderate. Meanwhile, with informal wage labor and small-scale microenterprises being hardest hit in the aftermath of COVID-19, low-income youth and returning migrant workers remain severely disadvantaged. Coupled with their poor educational attainment, lack of access to social networks, prevailing social norms against those particularly vulnerable (Persons with Disabilities and ethnic minorities access of intended beneficiaries to economic opportunities and services remains encumbered). This is managed through efficient and effective stakeholder engagement, including advocacy, consultation and outreach, as well as Grievance Redress and Feedback Mechanism. Further, with eligible beneficiaries entering apprenticeships and microenterprise development programs as employees, there remains a need to also safeguard their occupational rights provide reasonable working conditions, and ensure Protection from Sexual Exploitation and Abuse through proposed Labor Management Procedures and Sexual Exploitation and Abuse/Sexual Harassment and Prevention Plan. Granted, given the nature of the health crises, Occupational Health and Safety and emergency measures remains of prime importance. Based on this, social risks associated with this Project are deemed substantial. 1 This encompasses towns, cities, city and municipal corporations, pourashavas and other municipality areas, upazila headquarters and cantonment areas, potential business clusters and extends unto peri-urban areas. 7 2. Legal Regulations and Requirements 2.1 Key National Legal Provisions This section details relevant national laws, and their subsequent amendments, on the right to information disclosure, public engagement, transparency and accountability, and labor force participation as applies to the Project. The legal tenets provided herein inform the Project design and nature of engagement activities undertaken and as defined in this Plan. ▪ Constitution of the People’s Republic of Bangladesh: The Constitution enshrines values of equality of opportunity to all citizens and adoption of effective measures to remove social and economic inequalities towards sound economic growth (Article 19). It attests to citizens’ right to work and compensation as is owed (Article 20), and engage in any lawful profession, occupation, trade or business (Article 40), extending such provisions unto its tribes, minor races, ethnic sects and communities (Article 23A). It prohibits all forms of forced labor (Article 34). It also guarantees its citizen’s rights to move, reside and settle freely throughout the country (Article 36); as well as assemble and participate in public meetings and processions, subject to reasonable restrictions in the interest of public health (Article 37); and form associations or unions (Article 38). Freedom of thought, conscience, speech, expression and press are guaranteed subject to them not overriding interests of the State (Article 39). The Constitution also espouses the formation of local governments responsible for public administration, maintenance of public order, delivery of public services and economic development, financial management and imposition of taxes (Article 59-60) ▪ Consumers’ Right Protection Act, 2009: This Act aims at protection of the rights of consumers, prevention of anti-consumer right practices and related matters therewith. In particular, it mandates temporary closure of any shop, commercial enterprise, factory, workshop or go down if it appears that any goods of anti-consumer right are being sold, manufactured or stored therein (Article 27). It also prohibits manufacture, import, marketing, sale, distribution and transportation of goods injurious to human health (Article 29), bearing particular relevance to selection of master craftsperson involved in training apprentices and vocations chosen by beneficiaries engaging in informal labor or self-employment. ▪ Right to Information Act, 2009: This Act makes provisions to ensure free flow of information and people’s right to information. It articulates individual right s to information from Authority (Article 4), request thereof (Article 8) and receipt within 20 working days (Article 9). It mandates cataloguing and indexing to preserve information (Article 5), publish and publicize all information relevant to decisions taken in a manner accessible to all citizens (Article 6) save those not regarded as being mandatory (Article 7). It further guarantees rights of the people to lodge complaints in response to decisions or non-action and satisfactory disposal (Article 25) and oversight over officers in charge (Article 27), all taken into consideration in the design and delivery of information disclosure. ▪ Information and Communication Technology (ICT) Act, 2006: This Act provides legal recognition and security of Information and Communication Technology and rules of relevant subjects. Specific to the proposed Project, it cautions against publishing fake, obscene or defaming information in electronic form (Article 57), misrepresenting and obscuring information (Article 62) and disclosing confidentiality and privacy (Article 63). ▪ Digital Security Act, 2018: This Act is instituted to ensure national digital security and enact legislation around digital crime identification, prevention, suppression, and trial, among others. Bearing relevance to Project activities, it enables the removal or blocking of data or information deemed threatening (Article 8). It cautions against digital or electronic fraud (Article 23), identity fraud or being in disguise (Article 24), publishing or sending offensive, false or fear inducing data or information (Article 25) and collecting or using identity information without consent (Article 26). It further 8 prohibits publication or broadcast of information that hampers religious sentiments or values (Article 28) and defamatory content (Article 29). Alongside barring illegal transfer or saving of data or information (Article 33), it takes into consideration activities done in good faith (Article 57). ▪ Telecommunication Act, 2001 and Telecommunication Policy, 1998 and 2018: The Act provides for the development and efficient regulation of telecommunication system and services. It identifies the standard of telecommunication, its apparatus and terminal apparatus, and also towards the prevention of harmful interference (Chapter VII). It identifies licensing procedures for radio apparatus (Article 55), as well as penalties for false and incident messaging, interference and eavesdropping, misuse and annoyance, trespassing and damages, among others (Chapter XI). Telecommunications Policy 2018 highlights speaks to the need for universal access (Paragraph 4.1) and telecommunications-based employment and entrepreneurship (Paragraph 6.8), as ensured in designing and delivering stakeholder engagement and potential income- generating opportunities. ▪ Broadcasting Act, 2018: This Act creates provisions for regulation of broadcasting services and measures to promote independent and pluralistic broadcasting in public interest. In particular, it sets out Advertising Code (Article 33) that provides useful guidance towards dissemination of program information to a broad audience. ▪ Labor Act, 2006 and Labor Rules, 2015: This Act pertains to the occupational rights and safety of workers and provision of reasonable working conditions. With overarching tenets being directly applicable to the Project, specific provisions on leave (Article 10), payment of wages for unveiled leave (Article 11), stoppage of work (Article 12), grievance redress procedure (Article 33) and prohibition of employment of children and adolescent (Article 34) have particular relevance to Project activities. Taken further, this Act outlines standards for health, hygiene and safety, including its special provisions, with particular emphasis on disposal of wastes and effluents, fire safety (and also against fumes, explosives and inflammable dust), access to drinking water, latrines and urinals, safe usage and safety with(in) machineries and premises, and response to accidents, diseases and other dangerous occurrences (Chapters V-VII). It also provisions welfare, working hours, leave, payment of wages, and compensation for injuries, focusing on access to first aid appliances, shelters and daycare; daily hours, holidays, shifts, overtime, and casual, sick and annual leave; and schedule, form, deductions, claims and appeals on wages; and liability of employers, amount of redress and investigation of damages received (Chapters VIII-X and XII). Even more so, it outlines obligations of employers and apprentices for arrangements for apprenticeships (Chapter XVIII), which are further elaborated upon in Chapter VII of the Labor Rules, notably on inclusion of eligible participants, allowance and working hours, among others. ▪ National Skills Development Policy, 2011: This Policy guides skill development strategies, outlining commitments and reforms envisioned to that affect. With direct relevance to the Project, it the standards for demand-driven, flexible and responsive provisions for skills training (Chapter 4), competency-based training and assessment (Chapter 6), quality assurance of programs and providers (Chapter 7), data collection and analysis on skills availability and labor market (Chapter 9), and effective and flexible institutional management (Chapter 11). It further sets the stage for competencies and certification of instructors and trainers (Chapter 10), design and delivery of apprenticeships (Chapter 12), recognition of prior learning (Chapter 13), industry training and workforce development (Chapter 17), and skills development for overseas employment (Chapter 18). And, it advises on improved access for underrepresented groups (Chapter 14), enhanced social status of Technical and Vocational Education and Training (Chapter 16), and extends unto roles of industry sectors in skills development (Chapter 8). ▪ National Youth Policy, 2017: Seeking to ensure fulfillment of youth potential and employment, this Policy outlines priorities and programmatic measures around the thematic areas of empowerment. Its emphasis on education, training, employment and entrepreneurship, and development of information and communications technologies provide key implications towards the design and delivery of Project activities. 9 ▪ National Women Development Policy, 2011: This Policy espouses specific measures to enhance safety, security, socioeconomic empowerment and participation of women and reduce male-female disparities. Specific to the Project, it emphasizes on support to women’s human resource development and entrepreneurships, recognition of women’s contribution and use of women-friendly technologies, prioritization of their access to shelter and targeted support to those with disabilities, from smaller ethnic groups and those who are widowed, unmarried and childless, among others. Provisions herein are further reinforced by the Prevention of Oppression Against Women and Children Act, 2000, which safeguards women against social injustices, including those they could risk within the scope of Project design and implementation. ▪ Microcredit Regulatory Authority Act, 2006: This Act outlines guidance on the efficient regulation of microcredit programs and transparency and accountability in the activities of microcredit organizations. It mandates receiving certificate from the Authority (Chapter 4), submitting yearly balance sheets (Article 22), providing loan support and advise to poor people, alongside other eligible activities (Article 24) for an organization to be considered eligible, for the purposes of the Project. ▪ Mobile Financial Services Regulations, 2018: The Regulations provides regulatory framework to facilitate cost-efficient and prompt services, particularly for poor and underbanked population segments, as serviced through this Project. It sets models for business-to-person and government-to-person payments, including their operation modalities (Articles 5-7), thus guiding mechanisms for delivery of cash transfers to targeted beneficiaries. ▪ Money Laundering Prevention Act, 2012 and Money Laundering Prevention Rules, 2019: In mandating punishment for money laundering (Article 4) and other related offenses, this Act, complemented by the Rules, supports financial due diligence in the activities of Financial Intermediaries, Partner Organizations in this case, involved in the Project. 2.2 World Bank Requirements As defined by the Environmental and Social Framework and ESS10, stakeholder engagement is an inclusive process conducted throughout the project life cycle. Where properly designed and implemented, it supports the development of strong, constructive and responsive relationships that are important for the successful management of a project’s environmental and social risks. As per ESS10 the process of stakeholder engagement will involve the following, as set out in further detail in this ESS: (i) stakeholder identification and analysis; (ii) planning how the engagement with stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders; (v) addressing and responding to grievances; and (vi) reporting to stakeholders. ESS10 also requires the development and implementation of a grievance redress (and feedback) mechanism that allows project- affected parties and others to raise concerns and provide suggestions related to the environmental and social performance of the project, and other consequences at it affect them, and to have them addressed in a timely manner. 3. Previous Stakeholder Engagement Activities and Lessons Learnt 3.1 Previous Consultations and Engagement In the lead up to drafting the Stakeholder Engagement Plan and Appraisal, a number of consultations and engagement sessions were held to inform communication, sensitization and mobilization mechanisms deployed for the Project as well as the design of project activities, each of which are summarized below: 10 Table 1: Summary of Previous Stakeholder Engagement Date and Main Points Responses and Measures Participants Location Discussed Adopted October 2018 Executive Directors Design and data Objectives, data needs, study area Agargaon, and Focal Persons collection for and participants of the study were Dhaka of PKSF POs, World Bank study finalized, with the final product PKSF Officials, on Addressing found herein: WB Youth Employment https://documents.worldbank.org/e Representatives in Bangladesh n/publication/documents- reports/documentdetail/817911585 631502879/addressing-youth- employment-in-bangladesh- insights-on-design-from-five- programs-implemented-by-pksf April 2019 Santal youth, Inclusion of ethnic ▪ With unemployed Santal youth Godagari, community leaders minorities in skills experiencing constraints to Rajshahi and senior citizens, development attend skills training with other Wave Foundation training participants. and PKSF Officials ▪ PKSF opened a branch of Training Institute in that vicinity to enroll Santal and other youth from low income households. ▪ Targeted communities received information on skills training. ▪ Increased participation of Santal and youth from the low income households. April 2019 Participants of Study on Self- ▪ Institutional financial support PKSF-SEIP, employed was found to be critical to early- Chuadanga, Neilsen Bangladesh Graduated Trainees stage entrepreneurs who receive Bogura, research team and of SEIP Project, low returns on investment, Shariatpur, PKSF Officials PKSF calling for low-interest rates to Jessore support self-employment. This led to PKSF piloting “Start-Up Capital Loan” offering longer grace period and lower interest rates. ▪ The creditworthiness of potential borrowers evaluated by respective POs found to contribute 20% of the total investment. ▪ Identified individuals who may success in new ventures; psychological indicators were incorporated into the assessment. ▪ An orientation of psychometric profiling was held by a Behavioral Economist to conceptualize entrepreneur’s mindset to support potential entrepreneurs. May 2019 Senior Officials at Introduction to ▪ Behavioral economic tools as a PKSF Psychometric means to select potential Profiling for entrepreneurs based on assessing entrepreneurial ability and 11 Date and Main Points Responses and Measures Participants Location Discussed Adopted Entrepreneur’s creditworthiness. ability & creditworthiness. June 2019 Tea garden Strengthening ▪ With the unemployed youth in Moulivibazar, workers, livelihoods of Tea Tea gardens unable to step Sylhet Representatives garden workers outside, PKSF opened a branch from Skills for of Training Institute in the area Employment to encourage their participation. Investment ▪ Targeted communities received Program (SEIP) information on skills training Partner Training ▪ Increased scopes of improving Institutes, Local livelihood, and a community- Government based group were formed. Representatives & PKSF Officials July 2019 PKSF Officials and Introductory ▪ A pilot survey has been Credit Coordinators meeting on how to conducted on Psychometric from its POs, Prepare Profiling of existing including Rural Psychometric Entrepreneurs in Jessore. The Reconstruction Profile of objective of that pilot survey was Foundation (RRF), Entrepreneurs to reveal the necessity of Jagoroni Chakra Psychometric Profiling & check foundation (JCF), the effectiveness of the tools Wave Foundation, developed by the expert. Shishu Niloy ▪ It is found that half of the Foundation (SNF) entrepreneurs can’t fill up the and Bandhu Kalyan questionnaire. They suggested Foundation (BKF) that language of questionnaire should be simple and legible. ▪ Relevant staff of POs thought this kind of assessment will help them to understand potential micro entrepreneurs. June, 2020 Focal Person of Program design, ▪ Provision of non-residential Dhaka POs and SEIP-PTI training modalities training for aspiring and current and potential trades entrepreneurs participating as for apprenticeships project beneficiaries. under RAISE ▪ Targeting low income project unemployed and partially employed youths for market- responsive opportunities with potential growth ▪ Provision of credit support for the fresh skilled entrepreneurs and Covid-19 affected borrowers. June 2020 Supervisors of Credit channeling ▪ Participants to begin identify Dhaka PKSF Core to RAISE from the POs working in urban Operations Participants, and peri-urban areas. analyzing urban ▪ A rapid survey on economic and peri-urban damage to micro entrepreneurs credit flow and indicates inability to sell owing economic status of to lockdown and changing Covid-affected buying capacities of consumers, micro- hence significant losses in entrepreneurs monthly revenue. Many with 12 Date and Main Points Responses and Measures Participants Location Discussed Adopted microenterprises thus entered below the poverty line as a new vulnerable group. ▪ Financial support to be structured in consideration of the special needs of the Covid-affected enterprisers ▪ Preliminary discussion held regarding selection of Partner Organization (PO) under this project. 3.2 Salient Issues from Engagement Previous stakeholder engagement yielded some unique observations that guide both stakeholder engagement and Project design, including but not limited to: ▪ Inclusive end-to-end skills training program combined with employment services targeting different vulnerable groups such as tea garden workers, ethnic minorities and more is critical to the overarching success of such programs. ▪ Success of home-based entrepreneurship ventures such as tailoring may be a strong motivator for future female participation in similar initiatives. ▪ Male participants indicate a preference for training in Mobile Phone Servicing, electronics and plumbing for employment in different manufacturing industries or even starting their own business with credit support from POs. ▪ Community mobilization play vital role to select appropriate trainees as well as ensure community engagement. ▪ There is a keen interest towards utilizing Psychometric Profile for Entrepreneurs as a tool to assess creditworthiness of entrepreneurs and entrepreneurial ability, as indicated by different initiatives taken in the past year by PKSF. ▪ Financial support is required for severely affected micro-entrepreneurs to reverse the effect of pandemic on their livelihoods. ▪ Financial support to graduated trainees will promote their self-employment activities. 4. Stakeholder Identification and Analysis Mapping project stakeholders marks the first step in preparing the Stakeholder Engagement Plan, given its contribution to developing the Project’s approach to consultation and communication. Doing so entails identifying relevant Project stakeholders or groups of stakeholders, their key characteristics, specific needs or demands, preferred means of communication and appropriate level of engagement needed for each. 4.1 Stakeholder Category, Identification and Analysis In order to ensure effective and tailored engagement, stakeholders of this proposed project have been classified into three overlapping categories ▪ Affected peoples refer to individuals, groups, local communities and other stakeholders that are directly or indirectly affected by the Project, with particular focus being accorded to those directly and/or adversely affected. It also refers to those who are more susceptible to changes associated with project activities, and thus need to be closely engaged in identifying impacts and their signification, as well as in decision-making on mitigation and management measures; 13 ▪ Interested parties predominantly refer to those who are not directly affected by project activities, but are invested owing it its proximity, as in broader local communities where beneficiaries are located, or by virtue of their role in project preparation and implementation. ▪ Disadvantaged and vulnerable groups, although somewhat covered under the first category, they experience unique limitations and barriers to participating in consultation process and being represented in overarching stakeholder engagement. By extension, they are disproportionately impacted or further disadvantaged due to their vulnerable status, notably women, elderly, children, female-headed households, people with disabilities, ethnic and religious minority’s communities etc. Given particular engagement efforts required to enable their equitable representation in consultation and decision-making process for the project, this additional category seeks to explore their constraints, means of receiving information and any additional assistance required. Engagement with all identified stakeholders may incentivize their maximum contribution to successful implementation of the project by drawing on their existing expertise, experience and networks. It also facilitates community and institutional endorsement of project activities. A general list of stakeholder groups identified and one of vulnerable or disadvantaged stakeholders are each tabulated below: Table 2: Description of Project-Specific Stakeholder Groups and Interested Parties Stakeholder Groups and Interested Relevance of Engagement Parties International Development Association Financier of the proposed Project (IDA) Financial Institutions Division, Ministry of Direct recipient of the financing provided to the Finance, GoB Government of the People’s Republic of Bangladesh Implementing Partner Organizations (IPOs) Responsible for identifying eligible participants and of PKSF deliver economic opportunities and services as identified in the Project Appraisal Document at field levels. National Skills Development Authority NSDA was established by the GoB to coordinate skill (NSDA) and Bangladesh Technical development program around the country. BTEB Education Board (BTEB) prepares different course standards for short courses and other diploma courses. If necessary, PKSF can take technical assistance from NSDA & BTEB. In case of RPL, POs will select BTEB registered training organization to assess trainees. Ministry of Fisheries & Livestock, If necessary, PKSF will seek cooperation from them Ministry of Agriculture, Ministry of for the smooth implementation of the project. Industry, Ministry of Youth & Sports, Ministry of Labour and Employment, Bureau of Manpower, Employment and Training (BMET), Directorate of Technical Education (DTE) District Administration, Directorate of Support POs at upazila levels for successful Social Services (DoSS), and other district- implementation of project activities level entities Project Beneficiaries Poor urban and peri-urban youth with low educational attainment, micro entrepreneurs who have been affected by the COVID-19 pandemic. Prospective employers, including owners Provide employment opportunities and skills training 14 Stakeholder Groups and Interested Relevance of Engagement Parties of microenterprises and workshops, and to project beneficiaries master craftspersons Print and electronic media Implementing Partner Organizations may communicate with media for promotional activities. Civil Society Organization (CSOs), NGOs Can provide inputs for design of the project including beneficiary engagement and selection Academia, Think Tanks, Influencers For inputs in project design, baseline analysis and future predictions, experience sharing from similar projects 15 Table 3: Vulnerable or Disadvantaged Stakeholders, Their Circumstances and Engagement Mechanisms Vulnerable or Resources Required (or Preferred or Potential Means of Disadvantaged Limitations and Needs Experienced Activities Envisioned for Recent Engagement Receiving and Exchanging Information Stakeholders Which Resources are Needed) Low-Income ▪ Many are responsible for their entire ▪ Community mobilization, distribution of ▪ Consultations with Partner March 2019 in Rangpur Youth households, and may require extensive leaflets & brochure and social networks Organizations to develop mobilization and financial incentives to can play vital role in order to enable initial listing of potential Participants: override the opportunity cost of voluntary participation and registration eligible youth beneficiaries. Unemployed youth from low participating in disclosure, consultation and of the youth of the low income groups of income family, their guardians, broader engagement activities PKSF Partner Organizations (PO) ▪ Preparation of information PKSF officials ▪ Poor educational attainment calls for higher ▪ Soliciting of listing of low-income youth materials, including website investment to distil and synthesize project- with lack of access to income generation and leaflet/brochure for the related information in a manner that is opportunities through consultation with project accessible. Partner Organizations. ▪ Provision of, participation ▪ An increase in bus fares raises the financial ▪ PO’s beneficiaries in areas most affected grants, covering transportation, and administrative costs of partaking in by the pandemic. and monthly basic sustenance project activities. ▪ Focus group discussions in proximity to for attendance in assigned ▪ A lack of well-developed personal their own locations for awareness project activities. networks, especially if they are rural-urban raising and consultation on project ▪ Promote informal networking migrants, may exclude them from activities. systems among project participation in engagement, consultation ▪ Disclosed list of partner organizations beneficiaries, POs and other and other project activities, notably providing information materials on the relevant stakeholders expanding the microenterprises and seeking project and additional follow-up if informal wage labor on their own. desired. ▪ Although rural-urban youth are the most vulnerable, there may be barriers to targeting them as many have returned to their villages from being unable to retain any form of livelihoods in urban and peri- urban areas. Informal Workers ▪ That informal wage employment structure ▪ Community mobilization, distribution of ▪ Consultations with Partner March 2019 in Bogra not being connected to an efficient job- leaflets & brochure and social networks Organizations to develop matching systems means that there is some can play vital role in order to enable initial listing of potential Participants: reluctance, even amongst those who engage voluntary participation and registration eligible youth beneficiaries. Young informal workers like in them. As such, informal works can be of the youth of the low income groups of ▪ Preparation of information plumbers, electricians, Master reluctant to participate in project activities PKSF Partner Organizations (PO). materials, including website craftsperson (Ustad) , PKSF despite this being their only source of ▪ Soliciting of listing of Informal sector and leaflet/brochure for the officials livelihoods. workers with lack of access to income project ▪ In the aftermath of Covid-19, with those in generation opportunities through ▪ Provision of, participation 16 Vulnerable or Resources Required (or Preferred or Potential Means of Disadvantaged Limitations and Needs Experienced Activities Envisioned for Recent Engagement Receiving and Exchanging Information Stakeholders Which Resources are Needed) informal employment being heavily consultation with Partner Organizations. grants, covering transportation, affected, more extensive communication ▪ PO’s beneficiaries in areas most affected and monthly basic sustenance and sensitization activities would be by the pandemic. for attendance in assigned required to target and mobilize them. ▪ Focus group discussions in proximity to project activities. ▪ Further, with those in informal labor lacking their own locations for awareness ▪ Promote informal networking access to any form of social safety, raising and consultation on project systems among project assistance and insurance, they may require activities. beneficiaries, POs and other commitments to early response and ▪ Disclosed list of partner organizations relevant stakeholders preparedness in order to safeguard providing information materials on the themselves against future shocks and project and additional follow-up if participate in project initiatives. desired. ▪ Additional needs and characteristics correspond with those already identified in the first row for low-income youth. Self-Employed ▪ Identification of those who have been self- ▪ Soliciting of listing of and sharing of ▪ Consultations with Partner April 2019 in Chuadanga and those wage employed after or in response to the information with those self-employed or Organizations to develop Employed by pandemic may be hard wrought. employed by micro-enterprises in need initial listing of potential Participants: Microenterprises ▪ In particular, for low-skilled youth, of further assistance through eligible youth beneficiaries. Self-employed youth those who businesses that they launch may not consultation with Partner Organizations, ▪ Awareness raising, social owns small business like necessarily be climate or Covid-19 and past beneficiaries in areas most behavior change campaign, mobile phone servicing, sensitive, in which case they risk exclusion affected by the pandemic. and small-group consultations tailoring shop, PKSF officials from the Project altogether despite meeting ▪ Awareness raising sessions and with potential beneficiaries other eligibility criteria extended behavior change with support from previous ▪ For those with inadequate education, there communication campaign with potential successful corresponding should be opportunities for those who beneficiaries participants. participate in the program to obtain formal ▪ Disclosed list of partner organizations ▪ Provision of, participation certificates for graduation in order to providing information materials on the grants, covering transportation, increase their employability in the long run. project and additional follow-up if and monthly basic sustenance Given cultural considerations, official desired. for attendance in assigned recognition of their time in the program project activities would provide them the confidence about ▪ Promote informal networking their time invested in the program. systems among project ▪ Lack of formalized knowledge and access to beneficiaries, POs and other capital amongst those who are considered relevant stakeholders self-employed or may enter self- employment for the purposes of this project 17 Vulnerable or Resources Required (or Preferred or Potential Means of Disadvantaged Limitations and Needs Experienced Activities Envisioned for Recent Engagement Receiving and Exchanging Information Stakeholders Which Resources are Needed) means that thorough confidence building initiatives would be required for them to foresee potential benefits from partaking in project activities. ▪ With majority of those who are or have been self-employed solely responsible for sustaining their entire households, opportunity cost of participating in project activities needs to be commensurate with benefits from activities envisioned. Informal ▪ With assistance and stimulus packages thus ▪ Community mobilization, distribution of ▪ Consultations with Partner January 2019 in Bhairob (Shoe Microenterprises far having predominantly targeted formal leaflets & brochure and social networks Organizations to develop cluster) microenterprises, there remain a need for can play vital role in order to enable initial listing of potential awareness raising campaign around support voluntary participation and registration eligible youth beneficiaries. provided to them are commensurate with of the youth of the low income groups of ▪ Preparation of information Participants: their circumstances and shock responsive as PKSF Partner Organizations (PO) materials, including website Youth working at well. ▪ Awareness raising sessions and and leaflet/brochure for the microenterprises like shoe ▪ Prior losses and lack of access to broader extended behavior change project factory, owners of the shoe value chain may have left many of them communication campaign with potential ▪ Provision of, participation factory, NGO officials, PKSF depleted, and options towards potential beneficiaries grants, covering transportation, officials recovery of assets and losses incurred may ▪ Soliciting of listing of and sharing of and monthly basic sustenance need to be explored by the project. information with informal micro- for attendance in assigned February 2019 in Munshiganj ▪ Additional needs and characteristics enterprises in need of further assistance project activities. (mini garments business correspond with those already identified for through consultation with Partner ▪ Promote informal networking cluster) “self-employed and those employed by Organizations, and past beneficiaries in systems among project microenterprises” areas most affected by the pandemic. beneficiaries, POs and other Participants: ▪ Focus group discussions in proximity to relevant stakeholders Workers (youth) of the mini their own locations for awareness ▪ Awareness raising, and FGD garments, owners, association raising and consultation on project with potential beneficiaries members, NGO officials, PKSF activities. with support from previous officials ▪ Disclosed list of partner organizations successful corresponding providing information materials on the participants. project and additional follow-up if desired. Female Laborers ▪ Conservative gender norms and ▪ Community mobilization, distribution of ▪ Consultations with Partner September 2019 in Chuadanga and Business presumptions around vocations that are leaflets & brochure and social networks Organizations to develop 18 Vulnerable or Resources Required (or Preferred or Potential Means of Disadvantaged Limitations and Needs Experienced Activities Envisioned for Recent Engagement Receiving and Exchanging Information Stakeholders Which Resources are Needed) Owners considered appropriate for women may can play vital role in order to enable initial listing of potential Participants: Female workers limit them to only certain forms of wage voluntary participation and registration eligible female beneficiaries. and owners of cottage industry, labor and home-based microenterprises. If of the youth of ▪ Additional consultations with tailoring shop, NGO officials, the latter is considered more feasible, then ▪ Soliciting of listing of female-headed successful female PKSF officials improved virtual connectivity and linkages households, families left behind, women entrepreneurs, politicians, with the value chain need to be ensured for from households hardest hit (or without traditional leaders and women to be able to maximize. dual incomes), and other vulnerable influential figures to develop ▪ Aforementioned customs are also tied to women with lack of access to income initial listing of potential limitations on women’s safety and mobility, generation opportunities through female beneficiaries. which can be mitigated by through consultation with industry partners, ▪ Provision of, participation provision of transportation facilities for Partner Organizations, community- grants, covering transportation, them to jointly travel together to access based organizations, women support and monthly basic sustenance training opportunities and other project organizations and past beneficiaries in for attendance in assigned activities. areas most affected by the pandemic. project activities, and access to ▪ Lack of access to childcare facilities and ▪ Focus group discussions with successful pooled transportation if inability to find suitable replacement during female entrepreneurs, to bring in possible. assigned consultation or training hours can additional potential female beneficiaries ▪ Psychosocial support offered dissuade participation. Likewise, those for sensitization and mobilization to by trained Case Management requiring to prepare meals and support project activities. and Enterprise Development through other forms of domestic labor ▪ Access to psychosocial support and Officers within Partner directly contributing to household income counseling on a case-by-case basis. Organizations, females in this may choose to not join in the absence of due ▪ Disclosed list of partner organizations case to reflect their concerns compensation. providing information materials on the more keenly ▪ Past instances demonstrate women requiring project and additional follow-up if ▪ Preparation of information additional resources than their male desired. materials, including website counterparts to excel in the same ventures, and brochure for the project which needs to be adequately compensated ▪ Promote informal networking for in order to retain them and help them systems among project succeed. beneficiaries, POs and other ▪ Taken further, attempting to reach them relevant stakeholders through heads of households, in the absence of successful social behavior change communication campaign, may not only exclude them, but also subject them to further domestic and financial abuse. Persons With ▪ Societal stigma against those disabled may ▪ Community mobilization, distribution of ▪ Consultations with Partner April 2019 in Dhaka 19 Vulnerable or Resources Required (or Preferred or Potential Means of Disadvantaged Limitations and Needs Experienced Activities Envisioned for Recent Engagement Receiving and Exchanging Information Stakeholders Which Resources are Needed) Disabilities severely discourage those with disabilities leaflets & brochure and social networks Organizations to develop from participating the any consultation, can play vital role in order to enable initial listing of potential PWD Participants: engagement and broader project activities. voluntary participation and registration in their project areas. Persons with disabilities, their ▪ Those with physical, speech, hearing and of members of PKSF-POs. ▪ Subsequent focus group guardians, Founder of an intellectual disabilities often remain in the ▪ listing out of eligible persons with discussions with PWDs. organization ‘PFD’ who are fringes of commonly used means of disabilities ▪ Provision of, participation working with the skills training communication, demonstrated through their ▪ Guided focus group discussions with grants, covering transportation, for PWD, Development limited knowledge of coronavirus. As such, potential eligible PWDs in close and monthly basic sustenance officials who are working with more targeted sensitization and mobilization proximity to their own locations for for attendance in assigned PWD, PKSF officials campaign would be required to access and awareness raising, behavior change project activities, including incentivize their participation. communication and consultation on access to transportation as ▪ Those with disabilities also experience project activities. needed. higher need for relief assistance, special ▪ Access to psychosocial support and ▪ Psychosocial support offered healthcare services and mental health counseling on a case-by-case basis. by trained Case Management support, which may be accommodated by ▪ Social media account for proposed and Enterprise Development the project through referrals. program to allow individualized Officers within Partner ▪ Failure to host activities where persons with solicitation of information. Organizations and additional disabilities may be present in non-accessible ▪ Disclosed list of partner organizations arrangements to facilitate their locations may present physical deterrence to providing information materials on the participation their involvement. project and additional follow-up if ▪ Preparation of information ▪ Their relatively low educational attainment desired. materials, including website may further impede them from effectively and brochure for the project participating in or learning from ▪ Promote informal networking engagement and training sessions unless systems among project adapted to their specific circumstances. beneficiaries, POs and other ▪ The same selection criteria as applied to the relevant stakeholders rest of the beneficiary groups may further impede persons with disabilities from with substantive vulnerabilities from being included in the program. Tribes, Minor ▪ Their status as ethnic minorities mean more ▪ Community mobilization, distribution of ▪ Consultations with Partner August 2018 in Khagrachari Races, Ethnic targeted outreach and advocacy strategies leaflets & brochure and social networks Organizations to develop Sects and may be required in order to encourage their can play vital role in order to enable initial listing of potential Participants: Communities participation voluntary participation and registration ethnic minority beneficiaries Unemployed youth from ethnic ▪ Different linguistic and cultural barriers of members of PKSF-POs. in their project areas. community Chakma, their mean that engagement and training ▪ Soliciting of listing of potential ▪ Focus group discussions with guardians, NGO officials, 20 Vulnerable or Resources Required (or Preferred or Potential Means of Disadvantaged Limitations and Needs Experienced Activities Envisioned for Recent Engagement Receiving and Exchanging Information Stakeholders Which Resources are Needed) activities should be adapted in a manner that beneficiaries through consultation with eligible migrants to raise PKSF officials can accommodate their circumstances organizations working with these awareness of and mobilize ▪ With many individuals from communities communities, them to project activities. April, 2019 in Godagari, such as these living in hard to reach areas, ▪ Guided focus group discussions with ▪ Provision of, participation Rajshahi attention should be provided to bearing potential eligible beneficiaries for grants, covering transportation, costs of their transportation. awareness raising, consultation on and monthly basic sustenance Participants: ▪ Based primarily on their livelihoods, the project activities. for attendance in assigned Unemployed youth from ethnic nature of income generation activities they ▪ Access to psychosocial support and project activities community Santal, their had been engaged in may not be counseling on a case-by-case basis. ▪ Psychosocial support offered guardians, Community leader, immediately comparable with those ▪ National hotline, SMS-based texting and by trained Case Management School teacher, NGO officials, envisioned by the Project. Attention should social media account for proposed and Enterprise Development PKSF officials be given towards ensuring that activities program to allow individualized Officers within Partner presented to them as options are as solicitation of information. Organizations. June, 2019 in Moulivibazar, culturally sensitive as possible. ▪ Disclosed list of partner organizations, ▪ Preparation of information Sylhet include others working with these materials, including website Participants: communities, providing information and brochure for the project Unemployed youth from Tea materials on the project and additional ▪ Promote informal networking garden workers community, follow-up if desired. systems among project their guardians, Community beneficiaries, POs and other leader, NGO officials, PKSF relevant stakeholders officials 21 4.2. Stakeholder Mapping and Further Categorization A stakeholder mapping was undertaken to identify the level of engagement required for each group of stakeholders based on their level of interest and influence, as denoted in Figure 1. Those that appear in the top right quadrant are stakeholders that need to be proactively engaged on a regular basis, by virtue of them being most interested in the Project and having the potential to impact its outcome. Ones in the second and third quadrant need to be kept informed, that is provided information and consulted on issues of interest to the stakeholders. The final stakeholders need to be monitored by tracking changes, if any, to their levels of interest and impact. High Influence-Low Interest High Influence-High Interest (Q2 – Keep Satisfied) (Q1- Manage Closely) Print and Electronic Media International Development LEVEL OF INFLUENCE Academia, Think tanks Association CSOs, NGOs Implementing Partner Organizations (IPO) Low Influence - Low Interest Low Influence - High Interest (Q4- Monitor) (Q3- Keep Informed) General Public Covid affected micro-entrepreneurs Poor urban and peri-urban youth with low educational attainment. Owners of microenterprises and HIGH LOW workshops, and master craftsperson. LOW LEVEL OF INTEREST HIGH The stakeholder list as well as stakeholder analysis and mapping will continue to be revised and updated during the consultation during the planning phase, based on the ongoing receipt of comments and input from local, national and international stakeholders directed to the Project. 5. Program for Stakeholder Engagement 5.1 Objective and Adaptation to Covid-19 This section summarizes the timeline, timeframe, objectives, attendees and any additional description of various proposed activities and at what stage of the project’s lifecycle are they undertaken. It articulates key information that would be relayed to each of the stakeholder groups regardless of the stage of the Project. In light of the outbreak of Covid-19, individuals are mandated by national directives to exercise social distancing, and avoid public gatherings to prevent and reduce the risk of the virus transmission. Meanwhile, WHO has issued technical guidance in dealing with COVID-19, including: (i) Risk Communication and Community Engagement (RCCE) Action Plan Guidance Preparedness and Response; (ii) Risk Communication and Community engagement (RCCE) readiness and response; (iii) COVID-19 risk communication package for healthcare facilities; (iv) Getting your workplace ready for COVID-19; and (v) a guide to preventing and addressing social stigma associated with COVID-19. These can be accessed at: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance. Aforementioned considerations require a review of existing approaches to stakeholder engagement and consultations. These are premised on: ▪ Identifying planned activities requiring stakeholder engagement and public consultations, and for which any postponement may hinder project performance ▪ Assessing the level of required direct engagement with stakeholders, including location and size of proposed gatherings, frequency of engagement, categories of stakeholders. ▪ Evaluating the risks of the virus transmission for and the effect of ongoing restrictions on these engagements ▪ Investigating the level of ICT penetration among key stakeholder groups, if feasible, identifying the type of communication channels that can be effectively used in the project context. 22 In the event public gatherings with a representative sample of project beneficiaries, affected peoples and other interested parties are not feasible, the Project may elect a community representative based on inputs provided by beneficiaries. A network of such representatives can be established across the target communities to determine feasible methods of wider community outreach and consultation with stakeholders. Alternate forms of messaging would be explored and contingency plans instituted to tailor engagement when the intended tools cannot be deployed. Some of these include: ▪ All public gatherings, hearings, workshops and community meetings shall be avoided until deemed safe in line with national and international advisories. However, small-scale focus group discussions may be arranged if permitted, with guidance around social distancing and other precautions closely adhered to ▪ Online channels, social media platforms and chatgroups will be dedicated and deployed subject to ability of all stakeholders to equitably participate in consultations. Traditional channels, notably television and radio broadcasting, dedicated phone-lines and mails will also be leveraged to raise awareness of project activities amongst all user groups as needed. Each of the proposed channels of engagement should specific mechanisms to solicit feedback from relevant stakeholders. ▪ In which case direct communication with certain affected peoples are of the essence, channels for engagement, employing a context-specific combination of email messages, mail, online platforms, dedicated phone lines with knowledgeable operators, will be designed based on preference expressed by said beneficiaries ▪ Everyone involved in stakeholder planning will be trained in positive social behavior and hygiene practices, and are required to preface every engagement session by articulating them. 5.2 Proposed Mechanisms for Information Disclosure As a standard practice, project documentation, including Environmental and Social Safeguards instruments, released for disclosure are accompanied by an invitation for comments and suggestions that are formally recorded by the Project Management Unit. The Stakeholder Engagement Plan is produced in English and is made available for public review for 60 days from publication. The salient features of the plan will also be made available in Bangla. In light of the pandemic and subsequent shut down, materials will only be disclosed online for the time being, with the website equipped with a feedback feature enabling readers to enclose comments therein. The SEP will remain in the public domain for the entire project life cycle, and will be updated on a regular basis as the project progresses through its various phases, in order to ensure timely identification of and engagement with any new stakeholders and interested parties to tracking of changes to characteristics and subsequent methods of engagement, if required. To that extent, the latter would also be revised periodically to main their effectiveness and relevance to project performance and external circumstances. Based on this, the table below underscores information that would be disclosed, stage of the project lifecycle when they are each publicized and generic timeline, specific stakeholder to whom they may hold particular relevant, their means of disclosure to various stakeholder groups, entities responsible for the output and targeted percentage of reach of said product. 23 Table 4: Disclosure Methods for Relevant Information Products Project Information to be Responsibilities Mechanism Used (Tentative) Schedule and Location Target Stakeholders (Tentative) Phase Disclosed for Disclosure Project Information Project/PKSF website, and physical Following approval of the All project stakeholders and interested parties, PKSF-PMU, Document informational products document with particular emphasis on eligible project World Bank beneficiaries and Partner Organizations serving them Environmental and Social Project/PKSF website, and physical Following approval of the Partner Organizations and other industry PKSF-PMU PREPARATION (i.e., prior to project effectiveness) Commitment Plan informational products document partners contributing to project activities Stakeholder Engagement Project/PKSF website, and physical Following approval of first All project stakeholders and interested parties PKSF-PMU, Plan informational products and in-person draft and every time for initial session only, with emphasis only on Partner consultations as needed thereafter accompanying a implementing entities and project beneficiaries Organizations revision thereafter Environmental and Social Project/PKSF website, and physical Following approval of first Partner Organizations and other industry PKSF-PMU Management Framework informational products and in-person draft partners contributing to project activities consultations as needed Terms of Reference for Project website, job search portals and Following approval of the Eligible candidates, Partner Organizations and PKSF-PMU Environmental and Social appropriate physical news outlets document other industry partners contributing to project Specialist, and other activities recruited staff positions Labor Management Project/PKSF website, and physical Following approval of first Partner Organizations, industry partners, PKSF-PMU, Procedures informational products and in-person draft, with online master craftsmen and direct project Partner Occupational Health and consultations as needed publication only taking beneficiaries Organizations Safety Measures place after final approval Emergency Action Plan Sexual Exploitation and Abuse/Sexual Harassment Prevention and Response Plan Grievance Redress and Project/PKSF website, and physical Following approval of first Partner Organizations, industry partners, PKSF-PMU, Feedback Mechanism informational products and in-person draft, with online master craftsmen and project beneficiaries Partner consultations as needed publication only taking Organizations place after final approval Project Appraisal Project/PKSF website, and physical Following World Bank All project stakeholders and interested parties, PKSF-PMU, IMPLEM ENTATI Document informational products and in-person Board approval of the with particular emphasis on eligible project World Bank ON consultations as needed Project beneficiaries and Partner Organizations serving them Annual Work Plan Project/PKSF website, and physical Following approval of the Partner Organizations, industry partners and PKSF-PMU 24 Project Information to be Responsibilities Mechanism Used (Tentative) Schedule and Location Target Stakeholders (Tentative) Phase Disclosed for Disclosure Project Procurement Plan informational products and in-person document master craftsmen consultations as needed Bidding Documents for Project/PKSF website and appropriate Following approval of the Eligible candidates and firms, Partner PKSF-PMU Procurement physical news outlets document Organizations and other industry partners contributing to project activities Environmental and Social Project/PKSF website, and physical Published following Partner Organizations, industry partners, PKSF-PMU Standards Training and informational products and in-person completion of training master craftsmen and project beneficiaries Corresponding Module consultations as needed sessions Implementation Project website, and in-person training Published following Partner Organizations, master craftsmen and PKSF-PMU Arrangements in Response sessions for each of the target stakeholder completion of training project beneficiaries to Covid-19 Training and groups sessions Corresponding Module Labor Management, Occupational Health and Safety Training and Corresponding Module, including Code of Conduct Sexual Exploitation and Abuse/Sexual Harassment Training and Corresponding Module, including Code of Conduct Emergency Response and Preparedness Training and Corresponding Module Stakeholder Mapping and Engagement Training and Corresponding Module Grievance Redress and Feedback Mechanism Training and Corresponding Module Environmental and Social Project/PKSF website, and physical Following approval of first Partner Organizations and other industry PKSF-PMU, POs Management Plans for informational products and in-person draft partners contributing to project activities Sub-Projects consultations as needed Informational Products on Project/PKSF website, and physical Following approval of the All project stakeholders and interested parties, PKSF-PMU, POs 25 Project Information to be Responsibilities Mechanism Used (Tentative) Schedule and Location Target Stakeholders (Tentative) Phase Disclosed for Disclosure Case Management System informational products and in-person document with particular emphasis on eligible project and Eligibility Criteria consultations as needed beneficiaries and Partner Organizations serving Informational Products on them Life Skills, Apprenticeship and Self-Employment Curriculum Employer and Master Project website, dissemination in other online Following approval of final All project stakeholders and interested parties, PKSF-PMU, POs, Craftsmen selection and print media, public launching sessions draft with particular emphasis on Partner contracted research and, for targeted stakeholders, Organizations, industry partners, lending firm institutions, master craftsmen, potential employers and other service providers contributing to project activities Midterm & Impact Project website, public information sessions, Following approval of the World Bank PKSF-PMU, POs Evaluation as needed, and focus group discussions document & Research Firms Incidents and Accidents Project/PKSF website, and physical Following resolution of World Bank PKSF-PMU, Report informational products and in-person issues presented, or Partner Grievance Redress and consultations as needed otherwise as needed Organizations Feedback Reports and/or Resolution Monthly Report from Physical informational products and in- Following approval of the World Bank PKSF-PMU Partner Organizations person consultations as needed document Bi-Yearly and Annual Project/PKSF website, and physical Following approval of the World Bank, POs PKSF-PMU Project Reports (Includes informational products and in-person document Mid-Term Review and consultations as needed External Audits) Additional Spot Checks PKSF-PMU Sustainability Plan and Project website, public information sessions Following approval of first All project stakeholders and interested parties, PKSF-PMU Exit Strategy and, for targeted stakeholders, focus group draft, with online with particular emphasis on eligible project discussions publication only taking beneficiaries and Partner Organizations serving CLOSURE place after final approval them Impact Evaluation Project/PKSF website, and physical Following approval of the Project stakeholders PKSF-PMU, informational products and in-person document consultations as needed Final Audit Project/PKSF website, and physical Following approval of the World Bank & other Stakeholders PKSF-PMU informational products and in-person document consultations as needed 26 5.3 Proposed Mechanisms for Stakeholder Engagement This sub-section details all possible measures deployed to consult each of the stakeholder groups, from surveys, polls and questionnaires to public workshops, provide them relevant information and opportunities to voice their views on matter of important. The table below presents topics of consultation, mechanism used, timeline and timeframe, targeted stakeholders for each of the activities, among others. Please note that the sessions and items for consultation will be bundled to the extent possible in order to maximize the cost effectiveness and efficiency of the engagement process. Table 5: Stakeholder Consultations and Corresponding Engagement Mechanisms Project Mechanism Used Topics of Consultation Schedule and Location Target Stakeholders (Tentative) Responsibilities Phase (Tentative) Stakeholder Engagement Plan (including Consultations and Initial consultative All project stakeholders and interested parties for PKSF, Partner programmatic scope and rationale, as targeted focus group workshop and group- the former. Partner Organizations, industry Organizations needed) and Environmental and Social discussions based discussion with partners, master craftsmen and target Management Framework targeted stakeholders beneficiaries (with separate sessions for PREPARATION (i.e. prior to project effectiveness) which has already been identified vulnerable and/or disadvantaged reflected in the first draft groups) Grievance Redress and Feedback Focus group From approval of first Partner Organizations, industry partners, master PKSF, Partner Mechanism (Beta-Testing) discussions/Discussion draft to formal launch of craftsmen and target beneficiaries Organizations mechanism Identification, Mechanisms for Outreach Focus group discussions As soon as possible, prior Partner Organizations, industry partners, support PKSF, Partner and Determination of Unique to formal outreach to groups, community-based organizations, local Organizations, Circumstances of Target Beneficiaries potential beneficiaries administrations, upazila- and union-level politicians, customary leadership and influential figures relevant to, and knowledge and networks with each unique beneficiary group Stocktaking of Capacities of Partner In-depth consultations As soon as possible, prior Partner Organizations, industry partners, lending PKSF, Partner Organizations and administration of to formal outreach to institutions, potential employers and other Organizations questionnaires potential beneficiaries service providers contributing to project activities (extending unto former beneficiaries for cross-validation of information) Engagement, Consultation with and Eligible master craftspersons Selection of Master Craftspersons Promotion of Project-Level Labor Force FGD/Discussion As soon as possible Influential actors within the orbit of eligible PKSF, Partner Participation beneficiary groups with capacity to or interest in Organizations advocating for their participation in project activities, and already identified eligible beneficiaries with reservations about their participation 27 Orientation of Case Managers and Focus group discussions As soon as possible, prior Assigned and/or recruited case managers and PKSF, Partner Psychosocial Support Specialists to and in-depth individual to formal outreach to psychosocial support specialists, line managers Organizations Project Parameters consultations potential beneficiaries and those in senior management within Partner Organizations contributing to project activities Awareness Raising on Project Activities, Focus group discussions, Upon identification of Target beneficiaries (with separate sessions PKSF, Partner Prohibitive Forces, Curricular and Community project sites, and taking adapted for identified vulnerable and/or Organizations, Financial Needs Mobilization place at monthly disadvantaged groups) community-based intervals until launch of facilitators activities Case Management System and Social media awareness Upon approval of Project Partner Organizations, industry partners, master PKSF, Partner Eligibility Criteria campaigns, print by the Board craftsmen and target beneficiaries (with separate Organizations Like Skills, Apprenticeship and Self- communications and sessions for adapted identified vulnerable and/or Employment Curriculum focus group discussions disadvantaged groups) Environmental and Social Standards Technical workshops, Consultation beginning Partner Organizations, industry partners, master PKSF, Partner Training and Corresponding Module training of trainers and upon approval of the craftsmen and project beneficiaries Organizations IMPLEMENTATION Implementation Arrangements in post-learning Environmental and Response to Covid-19 Training and assessments Social Commitment Plan, Corresponding Module with training schedule Labor Management, Occupational determined by Health and Safety Training and effectiveness Corresponding Module, including Code of Conduct Sexual Exploitation and Abuse/Sexual Harassment Training and Corresponding Module, including Code of Conduct Emergency Response and Preparedness Training and Corresponding Module Stakeholder Mapping and Engagement Training and Corresponding Module Grievance Redress and Feedback Mechanism Training and Corresponding Module Environmental and Social Management Targeted focus group Initial consultative All project stakeholders and interested parties for PKSF-PMU Plans for Sub-Projects discussions workshop and group- the former. Partner Organizations, industry based discussion with partners, master craftsmen and target targeted stakeholders beneficiaries (with separate sessions for upon approval on first identified vulnerable and/or disadvantaged draft groups) 28 Profiling of Potential Eligible consultations and Upon completion of Potential beneficiaries (with sessions adapted for Case Managers and Beneficiaries counseling registration of potential identified vulnerable and/or disadvantaged Entrepreneurship eligible beneficiaries for groups) Development the Project Officers Referral of Non-Eligible Registrants Short feedback, Upon completion of Those who expressed interest but were declined Case Managers counseling and referral screening of all project participation in project activities sessions beneficiaries Psychosocial Support and Counseling In-depth individual Based on arrangement Target beneficiaries (with sessions adapted for Case Managers Sessions consultations decided upon with each identified vulnerable and/or disadvantaged Career Counseling Check-Ins with Case of the target groups) PKSF, Partner Managers beneficiaries, or as need Organizations, Review of Business Plans and Proposals arises assigned Case Managers Solicitation/Provision of Grievance Registration of Contingent on concerns Target beneficiaries, and extending unto other PKSF, Partner Redress and Feedback grievances and/or presented by project stakeholders and interested parties Organizations, Case feedback through paper- stakeholders and Managers and based and virtual interested parties extended Committee mechanisms Grievance Redress and Feedback In-depth individual Contingent on concerns Those considered relevant to the issue presented, PKSF, Partner Reports and/or Resolution consultations, joint presented by project and opened to a broader audience on a case-by- Organizations discussions and/or stakeholders and case basis mediation involving interested parties relevant parties or townhall meetings for wider arbitration and/or information sharing as needed Incidents and Accidents Report Reporting through Contingent on concerns Those considered relevant to the issue presented, PKSF, Partner hotlines, texting alerts. presented by project and opened to a broader audience on a case-by- Organizations In-depth individual stakeholders and case basis consultations, joint interested parties discussions and/or mediation involving relevant parties or townhall meetings for information sharing Monthly Report from Partner Monthly report based on After launching the Partner Organizations/ World Bank PKSF Partner 29 Organizations to PKSF specific format project Organizations developed by PKSF- PMU Bi-Yearly and Annual Project Reports Following project Contingent on the World Bank and relevant stakeholders PKSF, Partner milestone and activities schedule Organizations Mid-Term Review In-depth or targeted Based on ToR Partner Organizations, industry partners, master Independent Firm, verbal or written craftsmen and target beneficiaries (with separate PKSF, POs questionnaires, focus sessions for identified vulnerable and/or PKSF, Partner group discussions, disadvantaged groups) Organizations, structured or unstructured interviews, and polls and surveys as needed. Annual project townhalls and targeted focus group discussions beneficiaries to disseminate outcomes Individual Sustainability Plan and Exit Oversight after program Consultations to be Partner Organizations, industry partners, master PKSF, Partner Strategy completion through in- completed within six craftsmen and target beneficiaries (with separate Organizations depth consultations and months from completion sessions for identified vulnerable and/or targeted focus group of activities disadvantaged groups) discussions Overarching Sustainability Plan In-depth or targeted Consultations to be All relevant stakeholders Independent Firm, CLOSURE verbal or written completed within six PKSF, POs Impact Evaluation questionnaires, focus months from completion group discussions, of activities structured or unstructured interviews, and polls and surveys as needed. Annual project townhalls and targeted focus group discussions beneficiaries to disseminate outcomes 30 5.4 Proposed Mechanism for Feedback Loops and Future Communication In principle, feedback and other communications are recorded, reviewed and reported back, regarding their integration into project design and delivery or any other action undertaken, to stakeholders as such: ▪ Comments are received verbally or in writing at the implementation level, with the Environmental and Social Specialist responsible for consolidating and bringing them to the attention of the Project Coordinator. ▪ Unless a meeting is required to be held to address comments shared, the Social Specialist responds to them in the same or equivalent manner as it was received. ▪ In the event the matter needs to be escalated, the Specialist produces a summary of comments to stakeholders at every level. And, in any case, a written record of all communication is retained and maintained, and uploaded in the project website as needed. 6. Grievance Redress and Feedback Mechanism The purpose of this GRM is to record and address any complaint that may arise during the life cycle of the RAISE project (Component 1 and 2) period effectively and efficiently. This GRM is designed to address concerns and complaints raised by the vulnerable urban youths, vulnerable groups and other stakeholders promptly and transparently with no impacts (cost, discrimination) for any reports made by the migrants, vulnerable groups and other stakeholders. This GRM has been planned so that the targeted youths and other stakeholders can report issues without being threatened, which is easily accessible, quick and impartial; delivering decisions by the GRC to the complainant in an unbiased manner. Considering the overall need for the total project period, the PKSF PMU will establish a GRM to address complaints and grievances by the beneficiaries (especially women and other vulnerable groups). The Grievance Redress Committee (GRC) of PKSF PMU will help to resolve issues/conflicts amicably and quickly, saving the targeted youths and other aggrieved persons resorting to expensive, time-consuming legal actions. The GRC and the PMU of PKSF will, however, not bar anyone and other stakeholders to go to the courts of law. The PKSF PMU will ensure that an effective and transparent mechanism is designed and established at the earliest opportunity for the beneficiaries and other stakeholders to be able to lodge complaints and grievances. Necessary sign posting/billboard would be placed at various places, to be decided by the PKSF PMU (where people gather) for sharing detailed information of the GRCs established for the Component 1 and 2 of RAISE Project. The GRM will also be available online so that grievances can be submitted without the need for physical interaction, especially during the time of COVID-19 crisis. 6.1 Justification on Cultural and Contextual Appropriateness of Project-Specific Grievance Redress and Feedback Mechanism The Project extends the customary Grievance Redress Mechanism to receive and respond to non-grievance related feedbacks alike, thus building a Grievance Redress and Feedback Mechanism. Reasons include: ▪ First, past experiences of the Palli Karma-Shahayak Foundation indicates that reporting grievances appears more high stakes, and may easily deter vulnerable beneficiaries from sharing their concerns. Identifying the mechanism as a means to provide feedback instead reduces sentiments of risks adopted associated with registering grievances. In so doing, this mechanism mitigates some of the concerns surrounding project beneficiaries downplaying their own grievances and not reporting them. Once registered, even as a feedback, the Project Management Unit can make a determination regarding the nature of the concern presented to mete appropriate corrective measures. 31 ▪ Second, instituting a Feedback Mechanism also enables soliciting more generic insights on project planning, implementation and evaluation through beneficiary satisfaction surveys, spot checks and process evaluations, and introduces corrective measures through a feedback loop. In light of the pandemic, which severely restricts standard monitoring and evaluation procedures, empowering beneficiaries and field staff to provide online feedback mitigates some of the health and safety concerns associated with travel and enables activities to run smoothly despite lockdown and barriers to physical interactions. In the longer term, this mechanism can be extended to and simplify monitoring and reporting processes for other PKSF-implemented initiatives, thus freeing up resources that can be dedicated towards other critical activities. 6.2 Receipt to Remedial of Grievance Redress and Feedback Mechanism The Program Officer, Case Management and Program Officer, Management Information Systems within the Project Management Unit will responsible for the overarching management of the Grievance Redress and Feedback Mechanism. They will receive guidance from the Project Coordinator, Deputy Project Coordinators and Program Manager (whoever is responsible for oversight over the Partner Organization wherein the grievance is emerging from) and technical assistance from the Social and Environmental Specialist. This Grievance Redress Committee at the PMU level (GRC-PMU) will be supplemented by corresponding structures within project sites to ensure efficient and effective uptake of grievances prior to escalating it upwards. Based on this, a Grievance Redress Committee will be formed within each Partner Organization, responsible for each of the project sites. It will be headed by its senior representative, as identified in line Environmental and Social Commitment Plan. The Committee consists of the Focal Point for Monitoring, Evaluation and Reporting as well as Environmental and Social Standards. This focal point shall oversee appropriate recording and redressing of grievances, and the assigned Case Manager, who will serve as the first line of contact upon receipt of a complaint or feedback and provides context on concerns raised by any of the direct beneficiaries during the previous phase. This Committee will be required to convene within three working days of any grievance arising. The complaints can either be lodged directly with the GRC, through SMS or email which will be provided in every Partner organization upon their selection. Below are the steps associated with processing grievances and feedback, from receipt to remedial: ▪ Uptake of Grievances: In which case the complainant is not able to, or does not desire to, address grievances or feedback with Environmental and Social Focal Point or assigned community-based representative, they can file a paper-based Grievance and Feedback Report at the offices of the Partner Organization, call the project hotline, or file an online complaint. An acknowledgement of receipt of the statement should be made to the complainant within two business days, during which the assigned Environmental and Social Focal Point will be asked to take action on this. During this period, the grievance is logged, and in which case the complainant is a direct project beneficiary, the log is also shared within the beneficiary profile within the Management Information System for the project. ▪ Verification and Action: The Environmental and Social Focal Point is provided ten business days to investigate the nature of the concern and consult the complainant and involved parties on the nature of the grievances and redress sought. Once the concern is resolved through fact finding and mediation, or does not merit additional investigation, the complainant is informed as such within the end of ten business days. A formal notification accompanies this communication within two business days. The log indicates the case as being resolved at this time. ▪ Convening of Grievance Redress Committee: When no satisfactory resolution can be reached or that the complainant is not satisfied with the outcome, the case is escalated to the Grievance Redress Committee. The complainant or the Environmental 32 and Social Focal Point is required to file for an escalation within ten business days of formal communication. The Committee is required to declare its decision and corresponding rationale in presence of the complainant or an assigned representative within five business days of convening. If the redress provided is satisfactory, the case can be logged as being resolved and a formal written or online communication is made to the complainant within two business days of the hearing. ▪ Convening of Project Management Unit: In the event of further engagement required, the Grievance Redress Committee schedules a hearing with relevant staff at the Project Management Unit within ten business days from its declaration with the complainant. The Project Management Unit is required to convene within ten business days of receiving the request during which any additional investigation into the issue is conducted. The complainant is updated every five business days on the status of processing the concern. Alongside identified representatives from the Project Management Unit, the hearing consists of senior representative from the Partner Organization, Environmental and Social Focal Point, complainant and other involved parties. A formal decision on the hearing is communicated within three business days. Legal recourses and public hearings are proposed in the event in which the complainant is dissatisfied with the outcome of the case itself. ▪ Monitoring, Evaluation and Recording of Feedback: Upon conclusion of the case itself, a report is filed which summarizes its key points of conversation and contention, possible alternatives to provided remedial actions, commonalities with other comparable cases within the Project, lessons learnt and proposed modifications to prevent or leverage negative or positive consequences respectively. This case report needs to be completed by the Environmental and Social Focal Point within the Partner Organization, in conjunction with the Case Manager, and Monitoring, Evaluation and Reporting Specialist for the Project, within five business days. Once approved, it is logged by the IT and MIS Specialist into the GRM MIS database, and is shared with the World Bank as requested, and applied towards the bi-yearly Progress Report. 6.3 Communication and Advocacy on Grievance Redress and Feedback Mechanism The Project promotes successful understanding and usage of this tool through awareness raising and advocacy campaigns targeting each of the unique stakeholder groups as part of its overarching stakeholder engagement. This includes: ▪ Adequate Information on Registration and Processing of Grievances and Feedback: Users are informed on what qualifies as and how to submit grievances and feedback. This is achieved through producing physical information materials, and making grievance and/or feedback forms accessible to all beneficiaries during the aforementioned session itself. It also extends to publishing contact details of staff receiving and processing grievances and/or feedbacks in public interfaces relevant to the project. Any information related to Grievance Redress and Feedback Mechanism is made available in Bangla. ▪ Participatory Development of Grievance Redress and Feedback Mechanism: The reporting to remedial process is intended to be as user-friendly as possible so as maximize effective and efficient usage of the mechanism itself. Therefore, consultations and focus group discussions seek to learn about potential caseload and available resources, preferences for remedies and exchange of information. Once a mechanism has been developed, it is beta-tested with key user groups in order to enhance design and delivery processes of the Grievance Redress and Feedback Structure. 6.4 Monitoring, Evaluation and Reporting on Processing of Grievances and Feedback This mechanism consists of strong record keeping practices and streamlined monitoring and evaluation procedures in order to enhance accountability of project performance and adopt corrective measures as needed: ▪ Logging and Registration: All grievances and feedbacks are logged and all inquiries, suggestions, outcomes and responses are recorded and categorized, using an online database at the backend of the Grievance Redress and Feedback Mechanism. 33 ▪ Internal Reporting on Performance: Monthly summaries and internal reports on public grievances, enquiries and related incidents, together with the status of implementation of associated corrective/preventative actions will be collated by responsible staff and referred to the senior management of the Project. This report reflects the number and nature of submissions received; causes of, issues raised and observable trends in grievances and feedbacks; justification for remedial action and provision of redress; time taken and user satisfaction; compliance with business standards and actionable measures to prevent or limit future recurrences. ▪ External Reporting on Performance: This report shall be made public, any changes pending, to enhance visibility of project activities, and engagement with stakeholders and interested parties. Specific cases may also be highlighted there on a case-by-case basis. A specific indicator on Grievance Redress and Feedback Mechanism may also be included into the Results Framework for the project to demonstrate the effectiveness of the structure and overarching beneficiary satisfaction with support and services delivered by the Project. Relevant Contact Information for Grievance Redress and Feedback Mechanism Mr. Md. Abul Kashem General Manager (Program) Palli Karma-Sahayak Foundation (PKSF) E-4/B, Agargaon Administrative Area, Sher-e-Bangla Nagar, Dhaka-1207 Bangladesh Phone: +8801844481317 Email: blkashem@yahoo.com 6.5 World Bank Grievance Redress Service Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to the project-level GRM or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns. Project affected communities and individuals may submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank’s attention, and Bank Management has been given an opportunity to respond. Information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS) can be found at: http://www.worldbank.org/en/projects-operations/products-and- services/grievance-redress- service For information on how to submit complaints to the World Bank Inspection Panel, please visit: www.inspectionpanel.org 7. Monitoring, Evaluation and Reporting Under the guidance of the Project Coordinator, Deputy Project Coordinators, Program Managers and other staffs of PKSF PMU will be responsible for monitoring, supervision, evaluation and reporting overall activities of the project. Mention that every Program Managers will be assigned for looking after day to day activities of the Partner Organization of this project. 7.2 Reporting Arrangements with Stakeholder Groups In collaboration with Implementing Partner Organizations, the Project Management Unit will conduct relevant stakeholder’s consultation e.g. workshops, seminars meeting etc. and will prepare reports on the basis of recommendations of the consultation. 34 7.3 Results Monitoring and Evaluation Framework The quantity and quality, including timeliness, completeness and appropriateness of stakeholder mapping and engagement, and grievance redress and feedback mechanism is assessed using the indicative structure below. Each of these indicators is disaggregated to identify attention accorded to groups identified as being vulnerable and/or disadvantaged for the purpose of this Project. Target indicators are to be included at a later stage during the program management cycle. Table 6: Monitoring, Evaluation and Reporting of Stakeholder Engagement Processes Monitoring Key Elements Timeframe Methods Responsibilities Indicators Stakeholders’ access to Periodic (during Interviews, PKSF, Partner Number of Interviews project information, project preparation and observations, Organizations and surveys held, consultations, public maintained throughout survey, attendance number of beneficiary information and project registers, receipt of and stakeholder dissemination materials implementation) mobility stipends organization covered Project beneficiaries’ Periodic (during Interviews, PKSF, Partner Number of survey and awareness of project project preparation and observations, post- Organizations beneficiary covered. activities, their maintained throughout session Sample beneficiary entitlements and project questionnaires, pre- tested for awareness responsibilities implementation) session checklist Acceptability and Periodic (during Interviews, PKSF, Partner Number of concerns appropriateness of project preparation and observations, Organizations raised by consultation and maintained throughout survey, score cards, beneficiaries, engagement project spot checks, process comparison between approaches implementation) evaluations expected and actual beneficiary engaged Community Periodic (during Interviews, PKSF, Partner Number of facilitators’ project preparation and observations, Organizations engagement and engagement with target maintained throughout survey, score cards, number of beneficiaries project spot checks, process beneficiaries covered implementation) evaluations Public awareness of Periodic (during Interviews, PKSF, Partner Random sampling GRM channels and project preparation and observations, post- Organizations public response of their reliability maintained throughout session awareness project questionnaires, pre- implementation) session checklist Acceptability and Periodic (during Interviews, PKSF, Partner Number of complaints appropriateness of project preparation and observations, Organizations received and average days to solve the same GRM mechanisms maintained throughout survey, score cards, project spot checks, process implementation) evaluations Reporting, processing Periodic (maintained Review of case PKSF, Partner Number of complaints and resolution of throughout project reports, interviews, Organizations received and average days to solve the same grievances implementation) survey, score cards, spot checks, process evaluations 8. Resources and Responsibilities for Implementing Stakeholder Engagement Activities 8.1 Management Functions and Responsibilities The Project Management Units established within PKSF is responsible for the implementation of activities listed. They receive monthly reporting on services delivered by the Partner Organizations, which reflects also on the performance of stakeholder engagement activities, alongside monthly stocktaking of Grievance Redress and Feedback, and Accidents and Incidents Report. These materials are compiled into the bi- yearly Progress Report mandated by the Environmental and Social Commitment Plan. The World Bank Task Team for the Project provides oversight on these, and may request any of the monthly reports as needed. 35 8.2 Financial and Human Resources A tentative budget for implementing the Stakeholder Engagement Plan throughout the entire program management cycle is provided below, to be finalized post effectiveness. This will be annually reviewed by the Project Management Unit, and adjusted as needed. Table 7: Tentative Budget to Implement Stakeholder Engagement Unit Cost Times/Mo Total Cost Ser Stakeholder Engagement Activities Quantity (USD) nth (USD) Staff/ Consultant Salaries (1 x Paid from Environment Specialist, 1X Social Project 1 Development Specialist etc) Consulting Service Budget Training on Stakeholder Engagement 3 times 7,000 21,000 2 and GRC issues 3 Information Desk Officer 1 300 36 18,000 Stakeholder/Community/ Lump Sum 30,000 4 Sensitization meeting 5 Meeting with Govt Officials 3 meeting/yr 2,000 18,000 6 Meeting with PMU, Welfare offices 3 meeting/yr 2,000 18,000 Surveys (including satisfaction surveys) 1 /yr 5,000 15,000 7 for report preparation 8 Travel Expenses Lump sum 10,000/yr Three yrs 30,000 9 Communication Materials Lump Sum 10,000 10,000 10 GRM Guidebook Lump Sum 4,000 4,000 11 Suggestions Box 40 100 4,000 12 GRM/GRC expenses Lump Sum 20,000 20,000 13 GRM MIS Database Lump sum 20,000 20,000 14 Honorarium for committees Lump sum 20,000 20,000 15 Contingency (10%) 22,800 Total (Less Serial 1) (Rounded) 250,000 36 37 RECOVERY AND ADVANCEMENT OF INFORMAL SECTOR EMPLOYMENT (RAISE) STAKEHOLDER ENGAGEMENT PLAN (SEP) Wage Earners’ Welfare Board (WEWB) Ministry of Expatriates’ Welfare and Overseas Employment Aug, 2020 i ABBREVIATION AP Affected People BCC Behavior Change Communication COVID-19 Coronavirus Disease 2019 DP Development Partner ECA Environmental Conservation Act ECR Environmental Conservation Rule ESMF/P Environmental and Social Management Framework/Plan E&S Environment and Social EHS Environmental Health and Safety ESF Environmental and Social Framework ESMF Environment and Social Management Framework ESIA Environment and Social Impact Assessment ESP Essential Services Package ESS Environment and Social Standards GBV Gender-based Violence GoB Government of Bangladesh GRC Grievance Redress Committee GRM Grievance Redress Mechanism GRS Grievance Redress System HCD Human Capital Development HNP Health, Nutrition and Population IA Implementing Agency IDA International Development Association IEC Information, education and communication IPC Infection Prevention Control LGD Local Government Division LGI Local Government Institution LMP Labor Management Procedures M&E Monitoring and Evaluation ii MFI Micro-Finance Institution MICS Multiple Indicator Cluster Survey MEWOE Ministry of Expatriates’ Welfare and Overseas Employment NCD Non Communicable Disease O&M Operation and Maintenance OOP Out-of-Pocket PAI Project Area of Influence PAPs Project Affected Persons PD Project Director PDO Project Development Objective PKSF Palli Karma Sahayak Foundation PI/MU Program Implementation/Management Unit PPE Personal Protective Equipment PPR Public Procurement Rule SEP Stakeholder Engagement Plan WEWB Wage Earners’ Welfare Board iii TABLE OF CONTENTS Introduction and Project Description 1 Introduction 1 Project Description 1 Project Location and Beneficiaries 2 Environmental and Social Impact Summary 3 Purpose of Stakeholder Engagement Plan 4 Legal Regulations and Requirements 5 Key national Legal Provisions 5 World Bank Requirements 6 Previous Stakeholder Activities and Lessons Learned 7 Previous Consultation and Engagement 7 Salient Issues from Engagement 8 Stakeholder Identification and Analysis 9 Stakeholder Category, Identification and Analysis 9 Stakeholder Mapping 12 Stakeholder Engagement Method 13 Engagement Method and Tools in light of COVID-19 Outbreak 13 Description of Information Disclosure Method 14 Planned Stakeholder Engagement Strategy 16 Review of Comments 20 Grievance Redress Mechanism (GRM) 21 Details of GRM Structure 21 Steps to a Solution 21 Publication of GRM Steps 22 GRM Contact Information 24 Implementation of Stakeholder Engagement Plan and Budget 25 iv SEP Implementation Arrangement 25 Budget for SEP Implementation 26 Monitoring and Reporting 27 Reporting Back to Stakeholders 27 Annex A Methods, Tools and Techniques for Stakeholder Engagement 30 TABLES 1. Previous Public Consultation 7 2. Potential Stakeholder Groups and Interested Parties 9 3. Vulnerable or disadvantaged stakeholders and their needs 11 4. Stakeholder Engagement and Disclosure Methods 15 5. Stakeholder Engagement Strategy 17 6. Role and Responsibilities for SEP Implementation 25 7. SEP Implementation Budget 26 8. Monitoring Requirements 27 v INTRODUCTION AND PROJECT DESCRIPTION INTRODUCTION Stakeholder engagement and communication is an important tool for ensuring transparency, accountability and effectiveness of development projects. This document lays out a stakeholder engagement strategy for engaging stakeholders associated with the World Bank funded ‘Recovery and Advancement of Informal Sector Employment (RAISE)’ Project’s Component 3 (Recovery and reintegration support for returning migrants). This Stakeholder Engagement Plan (SEP) is to be implemented by the Wage Earners’ Welfare Board (WEWB) of Ministry of Expatriates’ Welfare and Overseas Employment (MEWOE)—the Implementing Agency (IA) of the Project’ Component 3. The SEP outlines in detail the commitment of the Government of Bangladesh (GoB) as regards to engaging the stakeholders of the project. Timely and two-way information sharing, and communication can help to mobilize and maintain stakeholder support for the project and advance the overall project goals. PROJECT DESCRIPTION To accelerate economic transformation, the GoB has emphasized labor intensive job creation in the modern sector, but there are programming gaps for boosting employment for low income urban youth, to enhance coverage of labor market programs for post-COVID recovery and assisting returnee migrants who have been forced to deport due to COVID-19 pandemic. Globally, labor market interventions have proven to be a popular instrument in COVID response and recovery. Focusing only supply-side interventions, wage subsidies account for 60 percent of the global COVID-response labor market portfolio, with programs being implemented in Jamaica, Kosovo, Malaysia and Thailand. The Project intends to provide apprenticeship opportunities to low income urban youth as well as provide psychosocial support, referral services and stipend to returnee migrants who were forced to leave their country of employment due to COVID-19 pandemic. The pressure of returnee migrants are manifolds—loss of remittance, uncertainty of securing the lost job overseas, lack of employment opportunity in the local market which is already burdened with the rise of unemployment, social integration of the returnees etc. The project has following components: (of which WEWB is responsible for Component 3 and this SEP covers Component 3 aspects only) • Component 1 builds the system that will help workers identify their aspirations, strengths, and constraints (e.g. human capital, or financial). The systems established under Component 1 would be of use in a) screening potential beneficiaries for services provided 1|P a g e under Component 2; b) case management of beneficiaries enrolled in Component 2 programs including M&E and tracking employment status of beneficiaries six months after completion; and c) providing information on services offered outside the supported project, depending on the results of the profiling. Component 1 would be open to all interested members of the labor market, aged 15 to 34 and under class 8 education, and the emphasis would be on services for members of low-income urban and peri-urban living households. • Component 2 addresses the specific needs of improving the employability and productivity of youth from low income urban and peri-urban households through a package of services, including imparting essential life skills; on-the-job-learning opportunities through informal apprenticeships; access to seed capital, and coaching and mentoring. These services would be designed to enable beneficiaries to acquire aptitude and experience for entering informal wage employment or self-employment once they complete the program. • Component 3 This component would be supporting the Government of Bangladesh’s (GoB) ongoing measures to provide psychosocial support, orientation program, referral services to other training and job placement services, stipends to those who joins such services, provision of Welfare Offices in various districts to provide these supports and creation and maintenance of a digital database to track and monitor the migrants. • Component 4 This component will support the establishment and operation of Project Management Units (PMU) at PKSF. This component will also support the establishment and operation of Project Implementation Units (PIUs) in the Partner Organization (POs) that will be implementing the economic inclusion programming under Component 2. Each PO will be competitively selected by PKSF based on a set of criteria, including past performance; capacity to deliver all four elements of the economic inclusion package, and administration of the case management system. • Component 5 would be a Contingent Emergency Response Component (CERC). This is a provisional zero amount component to allow for rapid reallocation of loan proceeds from other project components during an emergency. PROJECT LOCATION AND BENEFICIARIES The Project will be implemented in the 30 Welfare Offices that will be set up in the Ministry’s District Employment and Manpower Offices (DEMO) that will be augmented by 5 Welfare Offices each to provide project related support to the returnee migrants. 2|P a g e The project beneficiaries are returnee migrants who had to be deported from overseas due to COVID-19 pandemic. The target beneficiaries are likely to face constraints to productive economic activity that would be addressed through the project’s Components 3 interventions and follow-on support through referral services and stipends. Selection of Migrant Beneficiaries: Any return migrant worker that has returned to Bangladesh since February 2020 will be eligible. Eligibility verification will be: Return migrants that have been registered by the systems developed under the GoB repatriation program, or registered into the returnee database will have their recent return status automatically verified. Return migrants that are not included in the database or systems (such as due to coming back before the systems were online, or on their own resources) will need to provide proof of their last return, such as their contract, re-entry documentation from Bangladesh SB during immigration, and/or flight details. Return migrants would be informed about the program during their reentry into Bangladesh, and/or through social mobilization, and public communication campaigns in high migration districts. ENVIRONMENT AND SOCIAL IMPACT SUMMARY The project’s impacts on the environment and the society are summarized below: Environmental Impacts The Project’s Component 3 would provide orientation services, psychosocial support and referral services, a one-time stipend to returnee migrants who would join the referral services as well as provision of an integrated returnee migrants’ database. With the information at hand at the moment, these activities will not be environmentally degrading will leave minimum environmental footprint. Since potential type of activities are not likely to cause any environmental impact the Environmental risk will be Low. Social Impacts 3|P a g e The present COVID-19 crisis has rendered the earning of returnee migrants to spiral below a livable level causing social tension and potential social instability. Selection and inclusion of returnee migrants (including their minority groups and the disabled)—who may lack networking and who may potentially be left out of the community engagement/outreach programs will also be a major challenge. Therefore, differentiated measures need to be undertaken to include all of these segment who may face disproportionate risk of exclusion. Given the COVID-19 pandemic, without proper protocol enforcement beneficiaries undergoing psychosocial, referral and orientation program support may be exposed to the virus. Ensuring protocol enforcement may pose challenges as well since some of the intended beneficiaries may be reluctant to follow the same. Though the GBV risk assessment for the project has been estimated to be Low, the female returnee migrants may nonetheless be subject to Gender-Based Violence (GBV) in the hands of the beneficiary selectors and Welfare Officers where they will be provided with Project benefits and support. The social risk is likely to be Moderate. PURPOSE OF STAKEHOLDER ENGAGEMENT PLAN The purpose of this SEP is to define a program for stakeholder engagement, including public information disclosure and consultation, throughout project lifecycle. The SEP outlines the ways in which various stakeholders will be identified and includes a mechanism by which they can raise concerns, provide positive or negative feedback, or make complaints about the project activities. This will begin very early in the project cycle and will be based on the prior disclosure and dissemination of relevant, transparent, objective, meaningful and easily accessible information in a timeframe that enables meaningful consultation with stakeholders in a culturally appropriate format, in relevant local languages and is understandable to stakeholders. The SEP will endeavor to disclose information that will allow stakeholders to understand the risks and impacts of the project as well as potential opportunities. It will also provide stakeholders with access to information, as early as possible before the Bank proceeds to project appraisal, and in a timeframe that enables meaningful consultations with stakeholders on project design. The SEP is a living document and will be updated throughout project implementation based on the feedback and information received through continued consultation conducted throughout the life of the project. 4|P a g e LEGAL REGULATIONS AND REQUIREMENTS KEY NATIONAL LEGAL PROVISIONS Bangladesh has relevant and adequate law/regulation on the right to information, information disclosure and transparency during decision making/public hearing etc. Relevant laws and regulations pertaining to these issues are given below: Constitution of the People's Republic of Bangladesh Article 36. Freedom of movement. Subject to any reasonable restrictions imposed by law in the public interest, every citizen shall have the right to move freely throughout Bangladesh, to reside and settle in any place therein and to leave and re-enter Bangladesh. Article 37. Freedom of assembly. Every citizen shall have the right to assemble and to participate in public meetings and processions peacefully and without arms, subject to any reasonable restrictions imposed by law in the interests of public order health. Article 38. Freedom of association. Every citizen shall have the right to form associations or unions, subject to any reasonable restrictions imposed by law in the interests of morality or public order; Article 39. Freedom of thought and conscience, and of speech . Citizen’s freedom of thought and conscience is guaranteed; subject to any reasonable restrictions imposed by law in the interests of the security of the State, friendly relations with foreign states, public order, decency or morality, or in relation to contempt of court, defamation or incitement to an offence the right of every citizen of freedom of speech and expression; and freedom of the press, are guaranteed. Article 59. Local Government. Local Government in every administrative unit of the Republic shall be entrusted to bodies, composed of persons elected in accordance with law; everybody shall, subject to this Constitution and any other law, perform within the appropriate administrative unit such functions as shall be prescribed by Act of Parliament, which may include functions relating to administration and the work of public officers and the maintenance of public order; the preparation and implementation of plans relating to public services and economic development. 5|P a g e Article 60. Powers of local government bodies. For the purpose of giving full effect to the provisions of article 59 Parliament shall, by law, confer powers on the local government bodies referred to in that article, including power to impose taxes for local purposes, to prepare their budgets and to maintain funds. The Consumers’ Right Protection Act, 2009 This Act aims at protection of the rights of the consumers, prevention of anti-consumer right practices and related matters connected therewith. 6|P a g e Right to Information Act (RTIA) 2009 The Act makes provisions for ensuring free flow of information and people’s right to information. The freedom of thought, conscience and speech is recognized in the Constitution as a fundamental right and the right to information is an alienable part of it. The right to information shall ensure that transparency and accountability in all public, autonomous and statutory organizations and in private organizations run on government or foreign funding shall increase, corruption shall decrease and good governance shall be established. Law on Local Government Bangladesh is a democratic republic with two spheres of government: national and local. Local government is enshrined in the constitution (Chapter IV Articles 59 and 60) and the main legislative texts include the Acts covering zila parishads (2000), upazila parishads (1998, amended 2009), union parishads (2009), pourashavas (2009), city corporations (2009) and hill district councils (1989). The local government division within the Ministry of Local Government, Rural Development and Cooperatives is responsible for local government, with the exception of the hill district councils, which are under the Ministry of Hill Tract Affairs. Bangladesh Labor Law, 2006 (Amended in 2013) and Labor Code 2015 This Law pertains to the occupational rights and safety of workers and the provision of a comfortable work environment and reasonable working conditions. The Labor Law of Bangladesh 2006 bans children under the age of 14 from working. Chapter III of the Act under “EMPLOYMENT OF ADOLESCENT WORKER” puts restrictions on employment of children and adolescents as follows: (1) No child shall be employed or permitted to work in any occupation or establishment. (2) No adolescent shall be employed or permitted to work in any occupation or establishment, unless: (a) A certificate of fitness in the form prescribed by rules, and granted to him by a registered medical practitioner is in the custody of the employer; and (b) He/She carries, while at work, a token containing a reference to such certificate. WORLD BANK REQUIREMENTS 7|P a g e As defined by the ESF and ESS10, stakeholder engagement is an inclusive process conducted throughout the project life cycle. Where properly designed and implemented, it supports the development of strong, constructive and responsive relationships that are important for successful management of a project’s environmental and social risks. As per ESS10 the process of stakeholder engagement will involve the following, as set out in further detail in this ESS: (i) stakeholder identification and analysis; (ii) planning how the engagement with stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders; (v) addressing and responding to grievances; and (vi) reporting to stakeholders. ESS10 also requires the development and implementation of a grievance redress mechanism that allows project-affected parties and others to raise concerns and provide feedback related to the environmental and social performance of the project and to have those concerns addressed in a timely manner. 8|P a g e PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES AND LESSONS LEARNED PREVIOUS CONSULTATION AND ENGAGEMENT A number of stakeholder meetings were undertaken at various times and venues, the summary of which is appended below. It is to be noted that COVID-19 pandemic didn’t allow face to face consultation. Table 1: Previous Public Consultations Activity Who Date and Main observations Venue KIIs and FGDs on GoB: Manikganj October 15-23, Recognition that migrants face many challenges at safe migration DEMO staff, Expat Welfare 2018, Dhaka, their destination Desk at Shahjalal Manikganj International Airport, Airport Police, More can be done to protecting migrants, including Bangladesh Korea TTC, by increasing their skills and targeting higher wage Prabashi Kalyan Bank, occupations, or destinations that pay higher wages BMET, BOESL, MoEWOE Conflicting views about the extent of liability of Civil society INGOs/NGOs: recruitment agencies, and division of BRAC, OKUP, SDC, responsibilities between migrants, host and RMRRU, WARBE sending country governments, and recruiters Development Foundation Many services are centralized in Dhaka so difficult Private Sector: BAIRA to reach aspirant migrants, or migrant families at management and member their hometowns firms Costs of migration are incredibly high (despite GoB Beneficiaries: Aspirant commitments to supporting fair recruitment), migrants, forced returnees, which leads to high debt burdens voluntary returnees, current migrants on break Perception among some quarters that there is oligopolistic behavior by recruitment firms Media: Daily Star/New Age Jobs and migration GoB: MoE, MoEWOE, June 22, 2020, Better information could help aspirant migrants policy forum BMET, FID, Finance Division, Dhaka make better decisions PKSF (Inclusive Jobs for Information measures would also need to be held Youth high-level Civil society: BRAC, BIGD, at community level, and include information on 9|P a g e Activity Who Date and Main observations Venue policy forum) RMRRU, Dhaka University, formal processes to reduce exploitation, and also SANEM, Moner Bondhu on costs-benefits DPs: KOICA, ILO, IOM, SDC Diversifying destinations and occupations can reduce exposure to exploitative situations GoB is already offering many services to migrants GoB has commitments to fair recruitment practices Government-to-Government programs, like Korea EPS, are good public system that reduces costs, protects worker rights, ensures minimum wages and labor protection, and facilitates return/reintegration Safe migration GoB: BOESL, WEWB, Dec 5-6, 2019, Currently no way to track migrants when they workshop MoEWOE, BMET Bangkok come back (Towards Safer and Civil society: BRAC, Migrant Multilateral platforms like Abu Dhabi Dialogue and More Productive Forum Asia, Colombo Process important for fair recruitment Migration in South Asia) South Asian Trade Union Council, South Asian Forum of Employers Trade unions and employer groups in destination countries important stakeholders for migrant safety at destination DPs: ADB, EC, ILO New technologies can help improve government service delivery Supporting migrants when they return is critical, but completely ignored Returning migrants may need additional services that are not currently provided, e.g. trauma counseling in the case of sexual/physical exploitation of female migrants 10 | P a g e SALIENT ISSUES FROM ENGAGEMENT Previous stakeholder meetings yielded a number of inputs for the Project: Given the outbreak of COVID-19 and the resulting loss of earning, returnee migrants are in desperate need of training and employment assistance immediately. They lack network, country or industry specific experience and also add to the ever increasing unemployment due to COVID pandemic. A database to track migrants’ whereabouts and needs and aspirations is critical and should be interoperable with other similar MIS platforms Besides job placement and technical support, returnee migrants need psychosocial counseling as well as counseling to address trauma for GBV victims. Cost of migration and the cost of return are extremely high putting pressure on both the migrants and their family members. Aspiring migrants need better information to make better decisions which also need to be provided at community level, with information on formal processes to reduce exploitation, and also on costs-benefits. 11 | P a g e STAKEHOLDER IDENTIFICATION AND ANALYSIS The first step in preparing a SEP is mapping the Project stakeholders. This analysis is central to the designing of the SEP, particularly in developing the Project’s approach to consultation and communication. This involves identifying relevant Project stakeholders or groups of stakeholders, characterizing the key stakeholder issues and concerns, and mapping the Project stakeholders to determine the appropriate level of engagement for each stakeholder or stakeholder group. This section describes the outputs from the stakeholder mapping process. STAKEHOLDER CATEGORY, IDENTIFICATION AND ANALYSIS For the purposes of effective and tailored engagement, stakeholders of the proposed project have been divided into the following core categories: Affected Parties: Persons, groups and other entities directly influenced, either positively or adversely, (actually or potentially) by the project and/or have been identified as most susceptible to change associated with the project, and who need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures; Other Interested Parties: Individuals/groups/entities that may not experience direct impact from the Project but who has interests in the project and could affect the project and the process of its implementation in some way; and Vulnerable Groups: Persons who may be disproportionately impacted or further disadvantaged by the project as compared with any other groups due to their vulnerable status (women, elderly, children, female headed household, people with disabilities, indigenous peoples, ethnic/religious/gender minorities, LGBT community), and that may require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the project. Engagement with all identified stakeholders will help ensure the greatest possible contribution from the stakeholder parties toward the successful implementation of the project and will enable the project to draw on their pre-existing expertise, networks and agendas. It will also facilitate both the community’s and institutional endorsement of the project by various parties. Access to the local knowledge and experience also becomes possible through the active involvement of stakeholders. A general list of stakeholder groups identified is presented in Table 2 below. 12 | P a g e Table 2: Potential Stakeholders Group and Interested Parties STAKEHOLDER GROUP INTEREST/CAUSE IN ENGAGEMENT International level International Development Association Is financing the project. (IDA) National level (Interested Parties) Wage Earner Welfare Board (WEWB) of Implementing Agency Ministry of Expatriate Welfare and Overseas Employment Bureau of Manpower, Employment and They host the District Employment and Manpower Offices where Training (BMET) Welfare offices will be setup Different government Agencies like City Would be responsible to support WEWB for the successful Corporations, Representatives from implementation of the Project. Support/consent from all these District Administration etc. agencies is required during the project implementation at different stages. Mass media (Print and Electronic) They are intermediaries for informing the general public about the planned activities of the project developer and for information disclosure. Prospective employers of beneficiaries They will provide employment opportunities for the project beneficiaries and have a say in project design and content making Civil Society Organizations (CSOs)) and Different CSOs and women’s organizations will be highly interested Women’s organizations in the area with the project as during the implementation and operational stages, there would be specific programs to redress GBV issues and scope of employment of local women, vulnerable migrants in project activities. Prabashi Kalyan Bank (PKB) and These organizations will support access to finance and support for Bangladesh Overseas Employment remigration Services Limited (BOESL) Researchers (Migration Study), Can be involved in understanding migration issues related to COVID- Academia, Think Tanks 19 Local Level Project Beneficiaries (affected people) Migrants who have involuntarily returned to Bangladesh in the face 13 | P a g e of the COVID-19 crisis Project Beneficiaries (Vulnerable people) Women, single women/ mothers, people with disability, small ethnic community people among the migrants Project employees and Project’s They will directly affect the training/ Psychosocial support/ consultants, trainers, Welfare Officers employment of the project beneficiaries Component-3 stakeholders, methods, tools and techniques for stakeholder engagement is given at Annex A. Component-3 related identification and specific needs assessment of the vulnerable groups and means of consultation appended at the table below: 14 | P a g e Table 3. Vulnerable or disadvantaged stakeholders and their needs Project Vulnerable Groups Characteristics/ Needs Preferred means of notification/ Additional Resources component and Individuals consultation Required Component 3: Returnee migrants Development of a database These returnee migrants lack local job experience, lack Investments in an integrated information Reintegration of who have no to track and register the networking, lack financial strength who have left everything and management system would enhance returning connection/network returnee migrants will be back to their host countries due to COVID-19 situation. the use of the unique smartcard ID to and lack local job required to track and include migrants enable tracking of aspirant and deployed experience this group migrants. Development a returnee database, would provide an opportunity to include them in project benefit. The returnee database would allow tracing of returnees to provide any additional health support under COVID-19 (or public health services, such as contact tracing); provide referrals for reintegration support, as well as building a sustainable system that could provide necessary services in the event of any future shocks. Component 3: Undereducated and Do These vulnerable groups of migrants mostly were engaged in In addition to above, special care must be Reintegration of young female informal household maids/ housekeepers and may have faced taken into consideration while consulting returning migrants violence and other traumatic experiences. Further, their lack with these vulnerable groups given their migrants of network, lack of experiences in the local market and social lack of motivation in coming in public for norms make them more vulnerable than other returnees. consultation. Female officers/ staffs must be assigned for such activities. If required, commuting fees and a secured place of consultation only for these returnees to be ensured. 15 | P a g e STAKEHOLDER MAPPING Stakeholder-mapping illustrated in the figure below was undertaken to identify the level of engagement required for each group of stakeholders based on their level of interest and level of impact. The mapping description is as follows: The stakeholders that appear in the top right quadrant are those that need to be managed closely (i.e. the stakeholders that need to be proactively engaged on a regular basis and engagement efforts should be focused on this group). This is because these are the stakeholders that are most interested in the Project and have the potential to impact its outcome (i.e. the ability of the Project to go ahead). The stakeholders that appear in next quadrants (i.e. in Q2 and Q3) need to be kept informed – i.e. provided information and consulted on issues of interest to the stakeholders. The final stakeholders (i.e. in Q4) need to be monitored – i.e. informed of key Project aspects. It is important to track if their level of interest or impact changes. The stakeholder list as well as stakeholder analysis and mapping will continue to be revised and updated during the consultation during the planning phase, based on the ongoing receipt of comments and input from local, national and international stakeholders directed to the Project. High Influence-Low Interest (Q2 – Keep High Influence-High Interest (Q1- Manage Closely) Satisfied) HIGH Government Agencies Media Potential Employers Academia CSOs LEVEL OF INFLUENCE Think Tanks Women Organizations Low Influence - Low Interest (Q4- Monitor) Low Influence - High Interest (Q3- Keep Informed) General Public Project affected communities Vulnerable Groups LOW LOW LEVEL OF INTEREST HIGH 16 | P a g e STAKEHOLDER ENGAGEMENT METHOD ENGAGEMENT METHODS AND TOOLS IN LIGHT OF COVID-19 OUTBREAK With the outbreak and spread of COVID-19, people have been mandated by national or local law, to exercise social distancing, and specifically to avoid public gatherings to prevent and reduce the risk of the virus transmission. Various restrictive measures, some imposing strict restrictions on public gatherings, meetings and people’s movement, and others advising against public group events have been adopted. At the same time, the general public has become increasingly aware and concerned about the risks of transmission, particularly through social interactions at large gatherings. WHO has issued technical guidance in dealing with COVID-19, including: (i) Risk Communication and Community Engagement (RCCE) Action Plan Guidance Preparedness and Response; (ii) Risk Communication and Community engagement (RCCE) readiness and response; (iii) COVID-19 risk communication package for healthcare facilities; (iv) Getting your workplace ready for COVID- 19; and (v) a guide to preventing and addressing social stigma associated with COVID-19. All these documents are available on the WHO website through the following link: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance. Given the COVID-19 pandemic situation, managing public consultation and stakeholder engagement in the Project needs to adhere to national requirements and any updated guidance issued by WHO. The alternative ways of managing consultations and stakeholder engagement will be in accordance with the local applicable laws and policies, especially those related to media and communication. The suggestions set out below are subject to confirmation that they are in accordance with existing laws and regulations applying to the project. With growing concern about the risk of virus spread, there was an urgent need to adjust the approach and methodology for continuing stakeholder consultation and engagement. Taking into account the importance of confirming compliance with national law requirements, below are some suggestions for stakeholder consultation amidst COVID-19 outbreak: • Identify and review planned activities under the project requiring stakeholder engagement and public consultations. • Assess the level of proposed direct engagement with stakeholders, including location and size of proposed gatherings, frequency of engagement, categories of stakeholders. • Assess the level of risks of the virus transmission for these engagements, and how restrictions that are in effect in the country / project area would affect these engagements. • Identify project activities for which consultation/engagement is critical and cannot be postponed without having significant impact on project timelines. 17 | P a g e • Assess the level of ICT penetration among key stakeholder groups, if feasible, to identify the type of communication channels that can be effectively used in the project context. Based on the above, specific channels of communication that will be used while conducting further stakeholder consultation and engagement activities need additional considerations. The following are some considerations while selecting channels of communication, in light of the current COVID- 19 situation: • Avoid public gatherings (taking into account national restrictions), including public hearings, workshops and community meetings; • If smaller meetings are permitted, conduct consultations in small-group sessions, such as focus group meetings; If not permitted, make all reasonable efforts to conduct meetings through online channels, including WebEx, Zoom and Skype; • Be sure that everyone involved in stakeholder planning articulate and express their understandings on social behavior and good hygiene practices, and that any stakeholder engagement events be preceded with the procedure of articulating such hygienic practices. • Diversify means of communication and rely more on social media and online channels. Where possible and appropriate, create dedicated online platforms and chatgroups appropriate for the purpose, based on the type and category of stakeholders; • Employ traditional channels of communications (TV, newspaper, radio, dedicated phone- lines, and mail) when stakeholders to do not have access to online channels or do not use them frequently. Traditional channels can also be highly effective in conveying relevant information to stakeholders, and allow them to provide their feedback and suggestions; • Where direct engagement with project affected people or beneficiaries is necessary, identify channels for direct communication with each affected beneficiary household via a context specific combination of email messages, mail, online platforms, dedicated phone lines with knowledgeable operators; • Each of the proposed channels of engagement should clearly specify how feedback and suggestions can be provided by stakeholders; • However, in situations where none of the above means of communication are considered adequate for required consultations with stakeholders, small group meetings ensuring social distancing and use of PPEs will be ensured. DESCRIPTION OF INFORMATION DISCLOSURE METHOD As a standard practice, the Project materials (ESMF, SEP etc) released for disclosure are accompanied by making available the registers of comments and suggestions from the public that are subsequently documented by the PMU in a formal manner. PMU will continue applying the similar approach to disclosure for any additional E&S appraisal materials that will be prepared as part of the project development. 18 | P a g e The ESMF, and SEP will be made available for public review in accordance with the World Bank and standard international requirements. The SEP will be released in the public domain simultaneously with the ESMF and ESMP reports and will be available for stakeholder review. Distribution of the disclosure materials will be through making them available online for the moment given COVID-19 situation. This will allow stakeholders with access to Internet to view information about the planned development and to initiate their involvement in the public consultation process. The website will be equipped with an on-line feedback feature that will enable readers to leave their comments in relation to the disclosed materials. Basing on the improvement of situation, free copies may be available at PMUs office locations. The SEP will remain in the public domain for the entire project life cycle. It is a live document and will be updated on a regular basis as the project progresses through its various phases, in order to ensure timely identification of any new stakeholders and interested parties and their involvement in the process of collaboration with the project. The methods of engagement will also be revised periodically to maintain their effectiveness and relevance to the project’s evolving environment. The outline presented in the table below summarizes the main stakeholders of the project, types of information to be shared with stakeholder groups, as well as specific means of communication and methods of notification. Table below provides a description of recommended stakeholder engagement and disclosure methods to be implemented during stakeholder engagement process. Table 4: Stakeholder Engagement and Disclosure Methods (Note: Preferably online/ digital method will be followed till COVID-19 situation improves) Stakeholder Group Project Information Shared Means of communication/ disclosure Beneficiaries directly ESMF, SEP; Online notices. benefited by project schemes Public Grievance Procedure; Electronic publications and press releases on the Project website. Regular updates on Project development. Dissemination of hard copies at designated public locations. Any other ES instruments (site specific ES assessment etc) if prepared during Press releases in the local media. implementation Consultation meetings. Information leaflets and brochures. Separate focus group meetings with vulnerable groups, as appropriate. Non-governmental ESMF, SEP; Public notices. and community- based organizations Public Grievance Procedure; Electronic publications and press releases on the project website. Regular updates on Project development. Dissemination of hard copies at designated public locations. 19 | P a g e Stakeholder Group Project Information Shared Means of communication/ disclosure Press releases in the local media. Consultation meetings. Information leaflets and brochures. Government ESMF, SEP; Dissemination of hard copies of the ESMF, ESMP, authorities and and SEP at PMU offices agencies Regular updates on Project development; Project status reports. Additional types of Project’s information Meetings and round tables. if required for the purposes of regulation and permitting. Related Welfare SEP; Public Grievance Procedure; Electronic publications and press releases on the Offices, employers Project website. and enterprises Updates on Project development and tender/procurement announcements. Information leaflets and brochures. Procurement notifications. Project Employees Employee Grievance Procedure including Staff handbook. including workers, GRM for the Labor Force; Updates on trainers etc Project development. Email updates covering the Project staff and personnel. Regular meetings with the staff. Posts on information boards in the offices and on site. Reports, leaflets. PLANNED STAKEHOLDER ENGAGEMENT STRATEGY Stakeholder engagement strategy will need to provide stakeholder groups with relevant information and opportunities to voice their views on issues that matter to them. Table below presents the stakeholder engagement activities PMU will undertake for the project. The activity types and their frequency are adapted to the main project stages: project preparation and implementation stages. 20 | P a g e It so to be noted that preferably digital, internet, social media etc will be followed where face to face interaction can be avoided till COVID-19 situation improves. Other face to face interaction should be applicable for post COVID-19 period, unless necessary. 21 | P a g e Table 5: Stakeholder Engagement Strategy Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities Project Affected People: ESMF, ESIA, ESCP, SEP; Project Online meetings, separate meetings Quarterly meetings at PMU scope and rationale; Project E&S for women and the vulnerable group; Welfare Offices and as Vulnerable beneficiaries principles; Grievance mechanism various components are process Face-to-face meetings, if applicable executed and put to maintaining COVID protocol operation, continuous Stage 1: Project preparation (Project design, ESMF/ESCP/SEP Disclosure) Mass/social media communication (as communication through needed) mass/social media and routine interactions Disclosure of written information: brochures, posters, flyers, website Information boards or desks Grievance mechanism Local newspaper Other Interested Parties ESMF, ESMP, ESIA, ESCP, SEP Online meeting and Face-to-face Quarterly meetings in PMU disclosures; meetings if possible PMU and Welfare Offices Project scope, rationale and E&S Joint public/community meetings principles with PAPs Grievance mechanism process Other Interested Parties ESMF, ESMP, ESIA, ESCP, and SEP Online meeting and Public meetings, Project launch meetings PMU disclosures if possible with relevant Press and media stakeholders Grievance mechanism trainings/workshops (separate Local NGOs, Different meetings specifically for women and Meetings as needed; Government Departments Project scope, rationale and E&S vulnerable people as needed) having link with project principles Communication through implementation namely Mass/social media communication mass/social media (as District Administration needed) District Police, Municipal, Disclosure of written information: Information desks with 22 | P a g e Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities DoE etc. Brochures, posters, flyers, website brochures/posters in Welfare Offices General public Migrants etc. Information boards Grievance mechanism Notice board for employment recruitment Other Interested Parties Legal compliance issues Online meeting, Face-to-face Disclosure meetings PMU meetings if protocol can be ensured, Other Government Project information scope and Reports as required Departments from which rationale and E&S principles Invitations to public/community permissions/clearances are meetings required; Coordination activities Submission of required reports Grievance mechanism process ESMF/ESMP/ESIA/ESCP/SEP disclosures Project Affected People Grievance mechanism Online meeting, Public meetings if Quarterly meetings PMU STAGE 2: Implementation /Returnee migrants possible, trainings/workshops Health and safety impacts (EMF, Communication through community H&S, community Separate meetings as needed for mass/social media as concerns) women and vulnerable group needed Phase Employment opportunities Individual outreach to PAPs as Notice boards updated needed weekly Project status Disclosure of written information: Routine interactions brochures, posters, flyers, website 23 | P a g e Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities Information boards; Brochures in local offices Notice board(s) at Welfare Offices Grievance mechanism Local monthly newsletter Other Interested Parties Project scope, rationale and E&S Online meeting, Face-to-face As needed PMU principles meetings Grievance mechanism Joint public/community meetings with PAPs Project status Other Interested Parties Project information - scope and Public meetings, open houses, Same as for PAPs/ at PMU rationale and E&S principles, trainings/workshops regular intervals Press and media Project status throughout the project Disclosure of written information: period to educate and Various Government Health and safety impacts brochures, posters, flyers, website, Departments raise awareness amongst Information boards Notice board(s) the population about the Employment opportunities at Welfare Offices General public, migrants pitfalls of GBV and Environmental concerns Grievance mechanism making them capable of arresting GBV in GBV related consultation, respective community. Grievance mechanism process GBV related issues would be handled and awareness on the issue including change of mind on the matter by the society at large would be addressed by implementing agencies including, WASH sector NGOs, NGOs specifically working on GBV matter, local leadership, Religious leaders, village elders including women representatives, Headmasters of the 24 | P a g e Stage Target stakeholders Topic(s) of engagement Method(s) used Location/frequency Responsibilities local schools and Madrassas. 25 | P a g e REVIEW OF COMMENTS The comments received from the stakeholder engagement activities will be gathered (written and oral comments) and reviewed, and reported back to stakeholders on the following process: ▪ Comments are received from stakeholders orally or in the written form at the project level. Due to COVID-19 outbreak, comments will be received through means preferably not engaging physical interactions (telephone, email etc) ▪ The Social and Environmental Specialist / responsible officer would summarize the comments and bring to the notice of the PMU ▪ The Social and Environmental Specialist on his behalf the PMU would respond to the comments by oral/ written/digital means at the project level ▪ The PMU may also organize the meeting with respective stakeholders ▪ If it’s not solved by PMU, then it will be addressed by Project Steering Committee (PSC) ▪ The Social and Environmental Specialist will share the summary of the comments to stakeholders in every level ▪ A written record of all these will be kept and maintained and uploaded in the relevant website for easy access of all. 26 | P a g e GRIEVANCE REDRESS MECHANISM (GRM) The purpose of this GRM is to record and address any complaint that may arise during the life cycle of the RAISE project (Component 3) period effectively and efficiently. This GRM is designed to address concerns and complaints raised by the returnee migrants, vulnerable groups and other stakeholders promptly and transparently with no impacts (cost, discrimination) for any reports made by the migrants, vulnerable groups and other stakeholders. This GRM has been planned so that the migrants and other stakeholders can report issues without being threatened, which is easily accessible, quick and impartial; delivering decisions by the GRC to the complainant in an unbiased manner. Considering the overall need for the total project period, the WEWB PMU will establish a GRM to address complaints and grievances by the returnee migrants (especially returnee women and other vulnerable groups). The Grievance Redress Committee (GRC) of WEWB PMU will help to resolve issues/conflicts amicably and quickly, saving the migrants and other aggrieved persons resorting to expensive, time-consuming legal actions. The GRC and the PMU of WEWB will, however, not bar any returnee migrants and other stakeholders to go to the courts of law. The WEWB PMU will ensure that an effective and transparent mechanism is designed and established at the earliest opportunity for the beneficiaries and other stakeholders to be able to lodge complaints and grievances. Necessary sign posting/billboard would be placed at various places, to be decided by the WEWB PMU (where people gather) for sharing detailed information of the GRCs established for the Component 3 of RAISE Project. The GRM will also be available online so that grievances can be submitted without the need for physical interaction, especially during the time of COVID-19 crisis. DETAILS OF GRM STRUCTURE Grievance Redress Committee (GRC) for Component 3 of RAISE Project will be formed in PMU of WEWB. Prior to the start of project activities, WEWB PMU officials will confirm establishment of such committees, with the understanding that they will have to meet when complaints are received. As a minimum the composition of the GRC will be as follows: • PMU senior representative - GRC Chair and Convener • One PMU staff - GRC Committee Secretary • Social and Environmental Specialist in PMU - GRC Committee member • One representative of Affected People (AP) - GRC Committee member STEPS TO A SOLUTION 27 | P a g e Step 1: The complainant will be advised to settle the complaint through the GRC. The GRC will endeavor to solve the problem within a week. The problem and solution will be recorded in the Grievance Log kept with the GRC. Step 2: Should the complaint not be addressed within a week; the Complainant will take the matter to the Project Director at the PMU, either via digital means or of situation permits by physical presence. The complaint will be recorded and the Project Director will solve the same within two weeks. The problem and solution will be recorded in the Grievance Log kept with the GRC. Step 3: If Step 2 fails to resolve the issue, the Project Steering Committee (PSC) will be involved centrally to solve the issue in question within two weeks and the complainant will be informed of the timeline to solve the issue. The problem and solution will be recorded in the Grievance Log kept with the GRC. The complainant will not be barred to seek legal remedies. PUBLICATION OF GRM STEPS Prior to the beginning of project activities, PMU or its representatives will publicize the establishments of the grievance redress steps and the process, and advertise all via contact information and the grievance redress steps posted at every PO Office involved, their websites, as well as at busy public places of project area. The poster(s) will be in the local language(s) and posted before start of project activities. The PMU’s representative will check at least monthly to ensure that the posters are prominently displayed and provide clear contact instructions and numbers. This procedure and monitoring will be reported in the semi-annual monitoring report submitted to the WB. 28 | P a g e Grievance GRC Level 1st Level Grievance One Week Grievance days Days3 Redressed Days days5 Not redressed Two Weeks nd PMU Level 2 Level Grievance Grievance Redressed Not redressed Grievance Redressed. 3rd Level PSC level Mitigation Two Weeks executed Grievance within 5 Max 5 Weeks to days of Redress a Grievance decision from receipt of the making complaint The Structure of Grievance Mechanism Any grievance filed with the GRC, must be reported in the Annual report to the WEWB PMU who will then submit a consolidated report to WB. To ensure impartiality and transparency, hearings on complaints will remain open to the public. The GRC will record the details of the complaints and their resolution in a register, including intake details, resolution process and the closing procedures. PMU will maintain the following three Grievance Registers: Intake Register: (1) Case number, (2) Date of receipt, (3) Name of complainant, (4) Gender, (5) Father or husband, (6) Complete address, (7) Main objection (8) Complainants’ story and expectation with evidence, and (9) Previous records of similar grievances. Resolution Register: (1) Serial no., (2) Case no.,(3) Name of complainant, (4) Complainant’s story and expectation, (5) Date of hearing, (6) Date of field investigation (if any), (7) Results of hearing and field investigation, (8) Decision of GRC, (9) Progress (pending, solved), and (10) Agreements or commitments. Closing Register: (1) Serial no., (2) Case no., (3) Name of complainant, (4) Decisions and response to complainants, (5) Mode and medium of communication, (6) Date of closing, (7) Confirmation of complainants’ satisfaction, and (8) Management actions to avoid recurrence. 29 | P a g e The WEWB PMU will keep records of all resolved and unresolved complaints and grievances (one file for each case record) and make them available for review as and when asked for by Bank. The PMU will also prepare periodic reports on the grievance resolution process and publish these on the IAs website. Any Gender Based Violence (GBV) related complaints will be handled in a survivor-centric manner in line with the World Bank guidelines provided in the WB good practice note on GBV2. GBV-related complaints will be dealt with strict confidentiality, based on the wishes of the GBV-survivor. Any GBV- survivor will be referred to a GBV Service Provider/ NGO assigned for the project by PMU to manage and respond to GBV cases. They will support GBV survivors in accessing service providers and guiding them through options of lodging a complaint. GRM CONTACT INFORMATION AND COMPLAINT LODGE CHANNELS Information on the project and future stakeholder engagement programs will be available on the project’s website and will be posted on information boards in the project office in situ, and WEWB PMUs’ Offices at the Welfare Offices. Description Contact details Company: WEWB GRC Office To: Project GRC, RAISE Project Address: Eskaton Garden Road, Dhaka-1000 E-mail: Website: wewb.gov.bd Telephone: 02-9334888 Complaints can be raised through personal appearance in the GRC and Welfare offices, through SMS, email and paper mails. All of which will be compiled into a central GRM system by the GRC. WB GRIEVANCE REDRESS SERVICE Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to the project-level GRM or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns. Project affected communities and individuals may submit their complaint to http://documents.worldbank.org/curated/en/399881538336159607/Environment-and-Social-Framework-ESF- Good-Practice-Note-on-Gender-based-Violence-English.pdf 30 | P a g e the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank’s attention, and Bank Management has been given an opportunity to respond. Information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS) can be found at http://www.worldbank.org/en/projects- operations/products-and- services/grievance-redress-service. Information on how to submit complaints to the World Bank Inspection Panel, visit www.inspectionpanel.org. IMPLEMENTATION OF SEP AND BUDGET SEP IMPLEMENTATION ARRANGEMENT The management, coordination and implementation of the SEP and its integral tasks will be the responsibility of dedicated team members within PMU and its Welfare Offices. The Project will ensure necessary logistics and budget to implement the SEP. The contact information is given below: Description Contact details Company: WEWB Office To: Project Director, RAISE Project Address: Eskaton Garden Road, Dhaka-1000 E-mail: Website: wewb.gov.bd Telephone: 02-9334888 Table 6: Role and Responsibilities for SEP Implementation ACTOR/STAKEHOLDER/ RESPONSIBILITIES RESPONSIBLE PERSON 31 | P a g e ACTOR/STAKEHOLDER/ RESPONSIBILITIES RESPONSIBLE PERSON Communication/SEP team - Overall planning and implementation of the SEP; - Lead activities on stakeholders’ engagement - Management and resolution of grievances; - Guide/coordinate/supervise Welfare Offices - Monitoring and reporting on SEP - Take lead in carrying out the beneficiary satisfaction survey WEWB PMU Officials - Visit Welfare Offices for M&E (at least quarterly) Social and Environmental - Supervision/monitoring of SEP and GRM Consultant Welfare Offices - Report/inform PMU on issues related to the implementation of the SEP / engagement with the stakeholders. - Resolve and convey management/resolution of grievance cases to the project GRM team - Collaborate/inform the local communities and other local level stakeholders on E&S monitoring Other interested - Participate in the implementation of SEP activities stakeholders - Monitor/ensure project’s compliance with the laws of Bangladesh - Engage with the project’s stakeholders on E&S issues 32 | P a g e BUDGET FOR SEP IMPLEMENTATION A tentative budget for implementing this SEP for the entire duration of the project is included below. The budget includes all the activities pertaining the project’s stakeholder engagement plan and comprises of a range of activities of the project. This budget will be annually reviewed by WEWB PMU and if necessary, will be revised and adjusted. The budget is provided in the table below (all figures are in USD): Table 7: SEP Implementation Budget Stakeholder Engagement Unit Cost Times/ Total Cost Ser Quantity Activities (USD) Month (USD) Staff/ Consultant Salaries (1 x Social Paid from and Environmental Specialist etc) Project 1 Consulting Service Budget Training on Stakeholder 2 times 5,000 10,000 2 Engagement and GRC issues 3 Information Desk Officer 1 300 36 18,000 Stakeholder/Community/ Lump Sum 20,000 4 Sensitization meeting 5 Meeting with Govt Officials 3 meeting/yr 10,00 9,000 6 Meeting with PMU, Welfare offices 3 meeting/yr 1,000 9,000 7 Surveys for report preparation 1 /yr 3,000 9,000 Travel Expenses Lump sum 5,000/yr Three 15,000 8 yrs 9 Communication Materials Lump Sum 10,000 10,000 10 GRM Guidebook Lump Sum 2,000 2,000 11 Suggestions Box 20 100 2,000 12 GRM/GRC expenses Lump Sum 10,000 13 GRM MIS Database Lump sum 10,000 10,000 14 Honorarium for committees Lump sum 10,000 10,000 33 | P a g e 15 Contingency (10%) 13,400 Total (Less Serial 1) (Rounded) 150,000 34 | P a g e MONITORING AND REPORTING Regular monitoring of project progress will be built into the design, in the form of appropriate indicators, targets, information systems, and review mechanisms. Project progress will be assessed using monitoring data, and course corrections will be made as necessary. PMU officials will undertake regular supervision visits to project sites for supervision and monitoring, at least quarterly. Innovative actions under the project would include their own impact evaluation. The officer designated (preferably the Social and Environmental Consultant) for will be responsible for the monitoring and reporting of this SEP. S/he will prepare periodic monitoring report as required (monthly, quarterly, six-monthly, annual, etc.) by the PMU. In case consolidated report on E&S management is prepared, s/he will ensure that specific sections/chapters on the SEP implementation are entered in such reports. Monitoring and reporting will include involving Project Affected Parties, internal and external stakeholders, interested group and the vulnerable in monitoring mitigation measures that will be agreed on the ESCP to satisfy stakeholder concerns; thus, promoting transparency. The Project will establish a monitoring system that is participatory, which will utilize indicators that are sensible to concerned stakeholders. Furthermore, the project will involve affected parties by gathering their observations to triangulate scientific findings and involve them in participatory discussions of external and monitoring and evaluation missions. The monitoring report will include clear and specific indicators both as regard the engagement with stakeholders and also the project’s grievance redress management. The communication officer will work on a reporting matrix in this regard. Table 8: Monitoring Requirements Key elements Timeframe Methods Responsibilities Monitoring Indicators Stakeholders’ access Periodic (during project Interviews, WEWB PMU together Number of Interviews and to project information preparation and observations, survey with external monitor surveys held, number of and consultations maintained throughout beneficiary and stakeholder project implementation) organization covered Project beneficiaries’ Periodic (during project Interviews, Do Number of survey and awareness of project implementation) observations, survey beneficiary covered. Sample activities, their beneficiary tested for awareness entitlements and responsibilities Acceptability and Periodic (during project Interviews, Do Number of concerns raised by appropriateness of implementation) observations, beneficiaries, comparison consultation and survey, score-card as between expected and actual engagement relevant beneficiary engaged approaches Community Periodic (during project Interviews, Do Number of engagement and 35 | P a g e Key elements Timeframe Methods Responsibilities Monitoring Indicators facilitators’ implementation) observations, number of beneficiaries covered engagement with survey, score-card as target beneficiaries relevant Public awareness of Periodic (during project Spot checks, Do Random sampling public GRM channels and implementation) interviews, response of awareness their reliability observations Accessibility and Periodic (during project Spot checks, Do Results of spot checks and readability of public implementation) interviews, desk- reviews, number of places information review materials are placed with public dissemination access materials Tones in social media Periodic (during project Social media Do Number of positive reviews and and broader public implementation) monitoring, negative reviews by public, perceptions (including interviews, beneficiaries and influences NGOs) observations Rate of grievances Periodic (during project Desk review, Do Number of complaints received and complaints implementation) interviews, survey and average days to solve the (reported and same unreported) REPORTING BACK TO STAKEHOLDERS The PMU will ensure regular/periodic reporting back and information sharing with the PAPs and as well as the stakeholders’ groups. This ‘reporting back’ measures vis-à-vis the PAPs should be always carried through network based or, if possible, face-to-face meeting or direct interactions, for the other stakeholders’ group. Other pertinent media, such as website, social media, press briefing, may also be used. Monthly summaries and internal reports on public grievances, enquiries and related incidents, together with the status of implementation of associated corrective/preventative actions will be collated by responsible staff and referred to the senior management of the project. The monthly summaries will provide a mechanism for assessing both the number and the nature of complaints and requests for information, along with the Project’s ability to address those in a timely and effective manner. The Project will arrange necessary training associated with the implementation of this SEP that will be provided to the members of staff who, due to their professional duties, may be involved in interactions with the external public, as well as to the senior management. Specialized training will also be provided to the staff appointed to deal with community stakeholder grievances as per the Grievance Procedure. Project contractors will also receive necessary instructions for the Grievance Procedure and in relation to the main principles of community relations GRM in relation to the labor force working under them. 36 | P a g e Information on public engagement activities undertaken by the Project during the year may be conveyed to the stakeholders in two possible ways: • Publication of a standalone annual report on project’s interaction with the stakeholders. • A number of Key Performance Indicators (KPIs) will also be monitored by the project on a regular basis, including the following parameters: Number of public hearings, consultation meetings and other public discussions/forums conducted within a reporting period (e.g. monthly, quarterly, or annually); Frequency of public engagement activities; Geographical coverage of public engagement activities – number of locations and settlements covered by the consultation process; Number of public grievances received within a reporting period (e.g. monthly, quarterly, or annually) and number of those resolved within the prescribed timeline; Type of public grievances received; Number of press materials published/broadcasted in the local, regional, and national media; Amount of Project’s charitable investments in the local communities in the Project Area of Influence. The outcomes/feedback from these ‘reporting back’ measures will be compiled and shared/disclosed with the stakeholders’ and general public through the use of proper media, such as WEWB website, social media accounts, communication materials, etc. 37 | P a g e 38 | P a g e 39 | P a g e Annex A. Methods, Tools and Techniques for Stakeholder Engagement (Subject to COVID-19 Situation) Method / Tool Description and Use Contents Dissemination Method Target Groups Information Provision Distribution of Used to convey information on the Printed materials present illustrative Online publication. • Beneficiaries directly benefited by printed public Project and regular updates on its and written information on Project scheme materials: leaflets, progress to local and national activities, facilities, technologies and If COVID-19 situation permits, distribution brochures, fact stakeholders. design solutions, as well as impact as part of consultation meetings, public • Local government institutions sheets mitigation measures. hearings, discussions and meetings with stakeholders, as well as household visits • Vulnerable groups and the Presented contents are concise and in various areas to meet the elderly and disadvantaged adapted to a layperson reader. Graphics the disabled. • Press and Media and pictorials are widely used to • NGOs describe technical aspects. Placement at the offices of Welfare • Government Organizations Information may be presented both in Offices and NGOs, libraries and other Bangla for local and national • Welfare offices stakeholders. Some could also be public venues. printed in Braille targeting the blind. Distribution of A newsletter or an updated circular Important highlights of Project Circulation of the newsletter or update • As above printed public sent out to Project stakeholders on achievements, announcements of sheet with a specified frequency in the materials: a regular basis to maintain planned activities, changes, and overall Project Area, as well as to any other newsletters/ awareness of the Project progress. stakeholders that expressed their interest updates development. in receiving these periodicals. Means of distribution – post, emailing, Printed materials should be available in electronic subscription, delivery in two languages – Bangla and English for person. the local and national audience. 40 | P a g e Welfare Offices Printed Inserts, announcements, press Notification of forthcoming public Placement of paid information in local, • As above advertisements in releases, short articles or feature events or commencement of specific and national print media, including those the media stories in the printed media – Project activities. intended for general reader and newspapers and magazines specialized audience General description of the Project and its benefits to the community. Advertisements should be available in two languages – Bangla and English for the local and national audience. Radio or television Short radio programs, video Description of the Project, Project Collaboration with media producers that • All stakeholders entries materials or documentary development updates, solutions for operate in the region and can reach local broadcast on local TV. impact mitigation. and national audiences. Advance announcement of the forthcoming public events or commencement of specific Project activities. Communication will be in Bangla. Visual Visually convey Project information Description of the Project and related Presentations are widely used as part of • Beneficiaries directly benefited by presentations to affected communities and other solutions/impact management the public hearings and other scheme interested audiences. measures. consultation events with various stakeholders. • Local government institutions Updates on Project development. • Vulnerable groups and the disadvantaged • Press and Media • NGOs • Government Organizations 41 | P a g e • Welfare Offices Notice boards Displays of printed information on Advance announcements of the Printed announcements and notifications • As above notice boards in public places. forthcoming public events, are placed in visible and easily accessible commencement of specific Project places frequented by the local public, activities, or changes to the scheduled including libraries, Welfare Offices, post process. offices, shop, local administrations. Noticeboard information will be in Bangla. Websites All the project activities, All contents mentioned above will be Through websites and social media • For all types of stakeholders having documentation, notice, project displayed in the project websites. platforms access to internet facility. Including dedicated updates will be published in the social media project websites. platforms WEWB can use their already operational websites keeping provision of specific These platforms will upload Website should be available in two portal within it or develop a dedicated completed, ongoing and planned languages – Bangla and English for the website. project activities to encourage the local and national audience. target population to participate more actively. 42 | P a g e Information Feedback Information Placement of Project-related Various Project-related materials, Deposition of materials in publicly • All stakeholders repositories information and printed materials ESMF/ /SEP and other safeguard available places (Welfare Offices, local accompanied by a in dedicated/designated locations documentation, environmental and administrations, etc.) for the duration of a feedback that also provide visitors and social action plans. disclosure period or permanently. mechanism readers with an opportunity to Audience is also given free access to a leave their comments in a feedback register for comments and suggestions. register. Internet/Digital Launch of Project webpage (on Information about Project Management A link to the Project webpage should be • For all types of stakeholders having Media WEWB websites) to promote Unit, Project development updates, specified on the printed materials access to internet facility. various information and updates on health and safety, community relations, distributed to stakeholders. the overall Project, impact community updates, employment and assessment and impact procurement, environmental and social management process, aspects. Other on-line based platforms can also be procurement, employment used, such as web-conferencing, webinar opportunities, as well as on presentations, web-based meetings, Project’s engagement activities Website should be available in two Internet surveys/polls etc. especially due with the public. languages – Bangla and English for the to COVID-19 related restrictions. local and national audience. Webpage should have a built-in Limitation: Not all parties/stakeholders feature that allows viewers to leave have access to the internet, especially in comments or ask questions about remote areas and in communities. the Project. Surveys, Interviews The use of public opinion surveys, Description of the proposed Project and Soliciting participation in surveys/ • Beneficiaries directly benefited by and Questionnaires interviews and questionnaires to related solutions/impact management interviews with specific stakeholder scheme obtain stakeholder views and to measures. groups or community-wide. complement the statutory process of public hearings. Questions targeting stakeholder Administering questionnaires as part of 43 | P a g e perception of the Project, associated the household visits. impacts and benefits, concerns and suggestions. Materials will be in Bangla. Feedback & A suggestion box can be used to Any questions, queries or concerns, Appropriate location for a suggestion box • All stakeholders Suggestion Box encourage residents in the affected especially for stakeholders that may should be selected in a safe public place communities to leave written have a difficulty expressing their views to make it readily accessible for the feedback and comments about the and issues during public meetings. community. Project. Feedback and suggestions expected to Information about the availability of the Contents of the suggestion box be in Bangla. suggestion box should be communicated should be checked by designated as part of Project’s regular interaction Project staff on a regular basis to with local stakeholders. ensure timely collection of input and response/action, as necessary. Consultations & Participation Public hearings Project representatives, the Detailed information on the activity Wide and prior announcement of the • All stakeholders affected public, authorities, and/or facility in question, including a public hearing and the relevant details, regulatory bodies and other presentation and an interactive including notifications in local, regional stakeholders for detailed discussion Questions & Answers session with the and national mass media. on a specific activity or facility that audience. is planned by the Project and which Targeted invitations are sent out to is subject to the statutory expert stakeholders. review. Hearings will be conducted in Bangla. Public disclosure of Project materials and associated impact assessment documentation in advance of the hearing. Viewers/readers of the materials are also given free access to a register of 44 | P a g e comments and suggestions that is made available during the disclosure period. Household visits Household-level visits can be Description of the Project and related Project’s designated staff should conduct • Beneficiaries directly benefited by conducted to supplement the solutions/impact management visits with a specified periodicity. scheme statutory process of public measures. hearings, particularly to solicit feedback from vulnerable Limitation: logistical challenges in community members that includes Any questions, queries or concerns, reaching households in various locations. the disabled, elderly and the especially for stakeholders that may Restrictions to COVID-19 affected minority ethnic communities who have a difficulty expressing their views households. may be unable to attend the formal and issues during formal community- hearing events. wide meetings. Consultations will be in Bangla. Focus Group Used to facilitate discussion on Project’s specific activities and plans, Announcements of the forthcoming • Beneficiaries directly benefited by Discussions and Project’s specific issues that merit design solutions and impact mitigation/ meetings are widely circulated to scheme Round Table collective examination with various management measures that require participants in advance. Workshops groups of stakeholders. detailed discussion with affected • Local government institutions stakeholders. • Vulnerable groups and the Targeted invitations are sent out to disadvantaged stakeholders. • Press and Media Discussions to be held in Bangla. • NGOs • Government Organizations • Welfare Offices 45 | P a g e 46 | P a g e