The World Bank Supporting investments in education for human capital development in Peru (P170478) Concept Environmental and Social Review Summary Concept Stage (ESRS Concept Stage) Public Disclosure Date Prepared/Updated: 05/26/2021 | Report No: ESRSC02069 May 26, 2021 Page 1 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Peru LATIN AMERICA AND P170478 CARIBBEAN Project Name Supporting investments in education for human capital development in Peru Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Education Investment Project 1/11/2022 3/31/2022 Financing Borrower(s) Implementing Agency(ies) Ministerio de Economía y Ministerio de Educación del Finanzas del Perú Perú Proposed Development Objective Public Disclosure The Project Development Objective (PDO) is to improve the use of technology as part of the learning process of students from vulnerable contexts Financing (in USD Million) Amount Total Project Cost 100.00 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] This proposed project will build upon lessons learned from the first phase of delivery of tablets by MINEDU and the multi-canal strategy AeC to improve distance education. In the short term, the project will help maintain learning continuity in the event of schools closing and offer distance learning and teaching modalities that will help build a more resilient education system, by implementing a comprehensive distance learning strategy and improve access and capacity for distance learning. As a large number of children will fall behind in terms of learning, due to the extended school closing and the income, MINEDU will have to rely on technology to maintain school continuity and improved learning in a changing an uncertain context, and provide personalized learning solutions for those most in May 26, 2021 Page 2 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) need. In the medium and long term, the project will contribute to coherently integrate technology within the education system and contribute to close the learning gap in a sustainable manner, allowing for more personalized learning styles, with a special focus on low-income and disadvantaged students. This Project would support activities aimed at improving learning conditions for the most disadvantaged through EdTech investments in three areas: (i) equipment; (ii) content and training; and (iii) innovation and evaluation. These activities will be implemented through four components, namely: 1) Improving access to digital equipment; 2) Strengthening Digital Content and Skills; 3) Promoting innovation in the usage of educational technology and 4) Project Management, Monitoring and Evaluation. The objective of component 1 is to improve the technological readiness of students and teachers at home and in schools through the distribution of hardware to students and teachers, and internet connectivity to rural schools. Specifically, component 1 will focus on (i) replenishing digital devices provided by MINEDU in 2020 and 2021 for students and teachers in a subset of schools in rural and urban areas, (ii) enhancing connectivity through micro servers to a subset of schools in rural districts that have access to electricity but do not have a functioning internet connection. The objective of component 2 is to improve digital skills among teachers, school directors, parents and local education leaders. The component will support the development of a comprehensive digital education strategy to improve content and skills. Evidence shows that investments in hardware do not improve learning unless they are supported by a solid pedagogical model that clearly lays out learning objectives and strategies to achieve them, and relevant Public Disclosure content delivered by trained teachers. This component will specifically support (i) the development of a strategy for improving digital content and skills, (2) the development and evaluation of digital pedagogical content, (ii) capacity building to strengthen teachers’ digital skills and (iii) other actors of the school community, which includes school principals, local education authorities and students’ families, and (iv) evaluation digital competencies of school community members, including students, teachers and school principals. The objective of component 3 is to improve institutional readiness through the design and implementation of replicable innovative initiatives related to distance learning. The component will support the design and implementation of a grant program to pilot and evaluate innovative interventions that aim to spur the effective adoption of technological devices into the learning process, with the ultimate objective of improving learning outcomes. The objective of component 4 is to support project implementation, monitoring and evaluation. D. Environmental and Social Overview D.1. Detailed project location(s) and salient physical characteristics relevant to the E&S assessment [geographic, environmental, social] Location. Component 1 (C1) includes replacing devices (tablets) purchased by the Ministry of Education (MINEDU) in 2020 and 2021 and providing connection to educational applications through the acquisition and installation of micro servers that will also work as routers in schools. Both the devices and the micro servers will target schools with existing electrical connectivity and would not require any civil or refurbishment works for their installation. The devices purchased will be delivered to students, teachers, and primary and secondary schools in Peru’s 24 regions May 26, 2021 Page 3 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) (Lima and Callao considered as one), in rural areas and in districts of quintiles 1 and 2 of poverty in urban areas, targeting around 13,664 schools, 584,282 students and 52,903 teachers. Devices are expected to have a lifespan of three years, as international evidence suggests, after which they should be adequately treated, recycled, reused and/or disposed. Components 2, 3, and 4 will not involve infrastructure works either and consist primarily of strategy and content development, capacity building, evaluation of digital competencies, implementation of grant programs, and support to MINEDU for project implementation, monitoring, and evaluation. Environmental Context: This Project will not finance or require any civil works activities, and it is not expected to have adverse physical environmental impacts. However, the project includes under C1 the purchase and delivery of electronic devices (around 630,000 tablets and an undetermined number of micro servers to adequately deliver the application) to schools located in rural and urban areas throughout Peru’s 24 regions. These devices will convert to e- waste once their lifespan has been reached and will be managed in accordance with an electronic waste (e-waste) plan that will be designed and implemented to avoid or reduce environmental impacts and risks stemming from the generation and management of this e-waste. This e-waste plan will also include the definition of sectoral standards for the purchase of equipment to ensure energy efficiency and maximize the lifespan of the devices that are included in the bidding process. Social Context: The project will be implemented at a national scale and will include students, teachers, and primary and secondary schools in each of Peru’s 24 region. The estimated number of beneficiaries is around 13,664 schools, 584,282 students and 52,903 teachers, located in rural areas and districts of poverty quintiles 1 and 2 in urban areas. For this reason, it will be important to consider in the design and implementation of C1 and C2 the possible Public Disclosure geographical, social and cultural barriers that exist in rural schools, including in terms of number of students, geographical distance and dispersion, quality of support services, ethnic diversity, etc., to avoid the involuntary exclusion of beneficiaries, especially in schools located in the highlands and in the Amazon, which service many students from indigenous communities, and can only be accessed by dirt road or river. D. 2. Borrower’s Institutional Capacity The Project will be implemented by the Ministry of Education (MINEDU), through a new institutional structure to be created within the MINEDU and that will work with inputs from the Direction of Technology Innovation in Education (DITE) and the Programming and Investments Unit (UPI). Project preparation is currently being supported by the DITE and the UPI. Due to the lack of physical environmental impacts it is not anticipated that the PIU will need to have a dedicated environmental specialist; nevertheless, as part of component 4 the PIU will hire an environmental consultant to help develop the e-waste plan. Meantime, the PIU will also contract a full-time social specialist to oversee operation of the project’s grievance mechanism, and to work with the environmental specialist(s) to facilitate the project’s compliance with the commitments established in the Environmental and Social Commitment Plan (ESCP) during project preparation and implementation. This arrangement will be validated as part of the project’s due diligence during project preparation, building on the experience and the analysis of the environmental and social risk management needs of the previous operation. As part of the due diligence it will also be assessed if there is a need to strengthen the E&S risk management capacity of the PIU. II. SCREENING OF POTENTIAL ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Moderate May 26, 2021 Page 4 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) Environmental Risk Rating Moderate Environmental risks and potential impacts stem from the conversion of the devices into e-waste once their lifespan has been reached and/or they have stopped working (C1). The project has considered the design of an e-waste plan to adequately manage this waste. The borrower will outline the e-waste plan as part of the Operational Manual and a preliminary version of this plan will be prepared during the first year of the implementation of the project. This e- waste plan will: (i) consider inputs from the monitoring plan (under C1.1) that will track the usage of the devices by the teachers and students, allowing the project to identify if/when they stop working and need to be replaced and disposed; (ii) follow local regulations specific to management of e-waste and EHS guidelines related to waste management; (iii) build on MINEDU’s current experience, considering lessons learned throughout the process including those from the disposal of devices to be replaced; and (iv) identify existing companies authorized in Peru to collect, recycle, reuse, treat and dispose of e-waste. Given these considerations, it is expected that the activities related to e-waste are adequately managed and that potential impacts on the environment arising from these are not significant; therefore, the proposed environmental risk rating is Moderate. Two other potential health and safety risks related to (i) minor risks of occupational health and safety during storage distribution activities; and (ii) risks of road accidents during distribution of devices, have also been identified and the standard H&S measures available for implementation are expected to be sufficient to prevent accidents. Civil works activities of any kind that could increase the risk of the project are not expected. Social Risk Rating Moderate The proposed social risk classification for the project is Moderate under the World Bank ESF. This project is not going Public Disclosure to involve infrastructure or land acquisition that could lead to adverse impacts on people. However, because of the national scope of the project, there is a risk of involuntary exclusion in the delivery of devices under C1 (equipment) and of benefits under C2 (digital pedagogical content and capacity building) in rural schools, because of geographical, cultural and social barriers, especially in schools in the Andes or the Amazon of difficult access with and students from indigenous communities. Rural schools have structural problems in quality of infrastructure (water and electricity services, equipment) and teachers (low capacity, high turnover, frequent absences). A cultural barrier in many rural schools with indigenous students is the urban background and formation of teachers, who tend to have Spanish as their mother tongue. In addition, there is the risk that the pedagogical content may not be socio- culturally appropriate in some settings, particularly in those with intercultural bilingual programs. A social assessment will be necessary to identify the risks of unintentional exclusion from receiving project benefits in schools, particularly for indigenous and Afro-Peruvians but also extending to migrants, the LGBTQI+ community and other vulnerable groups, and to identify measures for promoting their full integration into the project. B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: This standard is relevant. May 26, 2021 Page 5 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) Given that the project will include the provision of devices to students, teachers, and schools without the need for new infrastructure, environmental risks and potential impacts would mainly arise from the management and disposal of the devices once they turn into e-waste. To manage this waste, the Borrower will develop an e-waste plan, following an outline included in the Operational Manual. A preliminary version of this plan will be prepared during the first year of the implementation of the project, to help the client with the proper management of the e-waste generated by the devices purchased during 2020 and 2021. This e-waste plan will be updated after the Midterm Review, considering the lessons learned of the management and disposal of the first batch of devices (purchased 2020/2021). This plan will also address the following activities related to the e-waste to be generated: collection, transportation, storage, treatment, reuse and final disposal. In addition to building on local regulation and MINEDUs previous experience, the e-waste plan will follow manufacturer(s) guidelines regarding the reuse, recycling and disposal of the devices. The Bank will support the PIU in the development of this plan, making sure it covers ESS1 and ESS3 requirements, EHS General Guidelines on Waste Management, and national legislation requirements regarding electronic waste management, including those provisions set specifically for the public sector. The Bank will also review existing recycling and or disposal facilities for e-waste and will incorporate its findings into the e-waste plan. The specific milestone for presentation of this plan will be defined in the ESCP at appraisal stage; however, it is anticipated that a first version of this plan will be required during the project’s implementation first year and an updated version after the Midterm Review, within a certain timeframe following the delivery of the devices. The ESCP will also outline the required contents of both the draft and final versions. It is unknown at the moment if the storage and distribution of the devices will be carried out by a contractor or by MINEDU personnel. In either case, the ESCP will include a commitment to incorporating H&S measures into the Public Disclosure Operational Manual, which will also need to define criteria to distribute the devices acquired by the project in a way that prevents exclusion, particularly when there are not enough devices for all the ones who need it. Some measures will be also included as part of the project’s Labor Management Procedures. Said measures will either be followed by MINEDU or will be included in the bid documents if these activities are contracted. The ESCP will also include a provision to leave as a legacy the e-waste plan that will manage the devices once they have reached the end of their expected lifespan and are converted to waste. The project will also conduct a social assessment (SA), which will serve as the basis for an Indigenous Peoples Planning Framework (IPPF). In addition to analyzing the challenges faced specifically by indigenous and Afro-Peruvian students, this assessment will identify other vulnerable populations in the context of the proposed project activities and define specific measures to account for their vulnerability, assess gender roles and how those differences may be related to the project, and the potential issues facing students with disabilities and those belonging to the LGBTQI+ community. Areas where “Use of Borrower Framework” is being considered: None ESS10 Stakeholder Engagement and Information Disclosure This standard is relevant. May 26, 2021 Page 6 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) MINEDU will prepare and disclose a draft Stakeholder Engagement Plan (SEP), proportionate to project risks, in accordance with this standard. Based on the identification of affected and interested stakeholders in the project, this SEP will include consultations with other government institutions and organizations from civil society that have an interest (or have pertinent knowledge) and experience that could contribute to improve the design of the project and maximize benefits for the intended beneficiaries, and those who could be subject to project risks. The draft version of the SEP will be prepared and disclosed prior to the beginning of appraisal, informed by the consultations carried out until that point, and will also specify the activities that should continue after appraisal and during project implementation, defining the needs, methods, tools and techiques for stakeholder engagement with affected parties and other interested parties and institutional partners. The SEP should also include adaptations needed in the participatory mechanisms proposed (considering the COVID-19 restrictions still in place in Peru) and a Grievance Redress Mechanism (GRM) that is specific to the project, which will need to include a budget. The SEP will outline the resources, responsible parties and plans for monitoring and reporting on its implementation. The different components of project will involve many stakeholders. The identification of stakeholders (via mapping) will be an early SEP activity. In the case of rural schools in various parts of the country it will be important to consider the views of indigenous organizations on the best ways to promote the inclusion of indigenous populations from the earliest stages of the project. The project will incorporate measures based on non-discrimination provisions to promote the inclusion of other interested parties, such as women and girls, people with disabilities, migrants and LGBTQI+ people. Vulnerable stakeholders will be identified and measures will be specifically designed to facilitate their participation in the benefits of the project. Public Disclosure B.2. Specific Risks and Impacts A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions This standard is relevant. The standard recognizes the importance of upholding fair labor practices and providing safe and healthy working conditions. MINEDU will develop and implement Labor Management Procedures (LMP) to identify the main labor requirements and risks associated with the project, and determine the necessary resources to address project related labor issues, including potential situations of sexual exploitation and abuse and sexual harassment (SEA/SH), and occupational health and safety issues. Project workers will include both direct workers (PIU workers hired specifically for the implementation of the project or legally transferred to the project), and (most likely) contracted workers. To prepare the LMP, the Borrower shall conduct a review of the regulatory framework and labor regulations. The LMP will incorporate a Grievance Redress Mechanism (GRM) specifically for project workers, which is expected to be based on a combination of company labor procedures and the functioning of the specialized government agency SUNAFIL. The LMP will describe the working conditions and management of workers relationships, the conditions of employment and provisions for non-discrimination and equal opportunity, worker’s organizations and freedom of association, and occupational health and safety measures for workers. While child and forced labor are not expected, given the characteristics of the project, the LMP will also include measures aimed at the prevention of child and forced labor, particularly among vulnerable students. May 26, 2021 Page 7 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) The LMP will further ensure that the health and safety of workers are adequately addressed using WBG General Environmental, Health and Safety (EHS) Guidelines, WHO guidelines on COVID-19 and national regulations. A Workers Code of Conduct which outlines obligations for all workers involved in the project will be part of the LMP. The LMP will not include teachers because they are not project workers but beneficiaries of the project, but measures related to their interactions with students resulting from the Social Assessment may be part of the IPPF and the ESCP. In case the project needs to hire contracted workers to support activities under C1, C2 or C3, they will be considered in the LMP, in a manner consistent with ESS2. The draft LMP will be prepared and disclosed prior to Board approval because it will need to take into account and build on the results of the social assessment, and to provide more flexibility for the client to prepare a more robust LMP, particularly given the recent intensification of the COVID-19 effects among Peruvian residents, which limits the ability to collect relevant information about the projects, as well as the recent electoral context of Peru. ESS3 Resource Efficiency and Pollution Prevention and Management This standard is relevant. Resource efficiency: SC 1.1. covering the replacement of devices purchased in 2020 and 2021, will consider the design and implementation of an e-waste plan that will, in addition to addressing future e-waste management, also consider the definition of sectoral standards for the purchase of equipment. At this stage, it has been proposed that two Public Disclosure standards are considered: energy efficiency and lifespan, and that other standards covering potential energy use and raw material use will be evaluated and considered during project preparation. These standards and considerations will be laid out in the project’s operational manual and in the bid documents for the acquisition of the devices. Pollution prevention and management: As indicated in section D, Environmental and Social Overview, the estimated lifespan of the devices to be purchased will be three years, after which period the devices should be replaced. The e- waste plan will cover the requirements set forth in local regulation and manufacturer guidelines and will define and include measures to minimize any pollution generated from an inadequate handling, transportation, reuse, or disposal of the e-waste. In addition to this, the e-waste plan will also consider the availability of e-waste recycling providers, the cost of such service, who will bear the cost, and provisions to prevent that these devices (particularly the ones with batteries) be discarded as regular trash, particularly since the project will potentially have concluded when the devices reach their maximum lifespan and require disposal. This e-waste plan will be outlined as part of the Operational Manual; a draft plan will be prepared during the first year of project implementation, and a final version will be prepared after the Midterm Review. Relevance of this ESS will be further assessed as part of the Bank’s due diligence, as more information becomes available about the scope of activities under C1 and C2. ESS4 Community Health and Safety This standard is currently not relevant. May 26, 2021 Page 8 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) The project will not support building activities or new infrastructure that generate environmental impacts. The environmental risk level is low because of the possibility of generation of e-waste at the end of the lifespan of the devices purchased, but it will be managed according to the e-waste Plan, so the risk to community health and safety is very low. Relevance of this ESS will be further assessed as part of the Bank’s due diligence, as more information becomes available about the scope of activities under C1 and C2. Activities related to SEA/SH will be included in the LMP and its code of conduct, as well as in the IPPF, as applicable. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement This standard is not relevant. The project will not support building activities or new infrastructure that would require land acquisition, restrictions on land use or involuntary resettlement (including physical and economic displacement). ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources This standard is currently not relevant. Public Disclosure The project will not support building activities or new infrastructure. Therefore, there is no risk of affecting natural habitats or living natural resources. Relevance of this ESS will be further assessed as part of the Bank’s due diligence, as more information becomes available about the scope of the activities under C1. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities This standard is relevant. Many rural schools have indigenous students from communities beset by structural problems of economic poverty, social exclusion, and cultural discrimination. These students, together with Afro descendant students in both rural and urban areas, may face sociocultural and practical barriers to the proper uptake of the learning approaches being promoted by the project and the technologies accompanying them, unless strategies are put into place from the project design phase that facilitate equitable access to project benefits by the students and their families. It is important to consider the levels of readiness of indigenous and Afro-Peruvian students to take advantage of the types of e-learning activities promoted by the project’s activities, and if gaps are identified, there will be a need to implement measures aimed at reducing these gaps so that they can access project benefits, as practicable. A social assessment (SA) will serve as the key means for doing this. An Indigenous Peoples Planning Framework (IPPF) will be prepared based on the findings of the SA and disclosed by MINEDU prior to project appraisal. The SA will identify May 26, 2021 Page 9 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) other vulnerable populations (not just indigenous peoples) that need to be considered and the different instruments prepared should draw from this information in defining appropriate interventions. The information currently available on this project shows that C1 and C2 could certainly have positive effects via the full inclusion of indigenous and Afro-Peruvian students. The social assessment to be carried out in a participatory manner during project preparation will serve to provide information on the current status of rural school and the extent to which students from these demographic groups are already using the technologies in question. It will also identify key factors in the promotion of social inclusion and the equitable sharing of project benefits among these students. To allow indigenous students, in particular, to share in the benefits of such projects, it is important to recognize, respect and preserve indigenous culture, local knowledge and traditional practices of native communities, as well as to provide them with the opportunity to adapt to changing conditions in a way and in a timeframe acceptable to them. The social assessment process will culminate in the preparation and disclosure of the IPPF, which is the instrument of choice given that the full range of indigenous and Afro descendant communities to be included in the project. While their exact locations will not be known until project implementation, the IPPF will contain a series of general measures aimed at preventing their exclusion, as well as the criteria and procedures for the preparation of site-specific Indigenous Peoples Plans in the course of implementation, should the need arise. The circumstances requiring Free, Prior and Informed Consent (FPIC) application will be included in the IPPF. However, given the nature of the project, the interventions planned are not expected to require the application of FPIC. ESS8 Cultural Heritage Public Disclosure This standard is currently not relevant. The project will not support building activities or new infrastructure. Therefore, there is no risk of affecting material cultural heritage. While the project is not expected to have adverse impacts on the intangible cultural heritage of the beneficiaries, this risk will be further assessed as part of the social assessment to be conducted as part of the IPPF. Relevance of this ESS will be further assessed as part of the Bank’s due diligence, as more information becomes available about the scope of activities under C1. ESS9 Financial Intermediaries This standard is currently not relevant. C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No OP 7.60 Projects in Disputed Areas No III. WORLD BANK ENVIRONMENTAL AND SOCIAL DUE DILIGENCE May 26, 2021 Page 10 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) A. Is a common approach being considered? No Financing Partners There are no other financing partners. B. Proposed Measures, Actions and Timing (Borrower’s commitments) Actions to be completed prior to Bank Board Approval: Based on the available information, the team will prepare the following list of the different studies and instruments, proportionate to the scale of the risk and impacts of the project, to be developed by the Borrower prior to the specified milestones: 1. Draft LMP: prior to Board approval; final version 30 days after loan effectiveness. 2. Draft SEP: prior to appraisal; finalized prior to Board approval. 3. Draft Indigenous Peoples Planning Framework (IPPF), based on a social assessment: prior to appraisal; final version 30 days after loan effectiveness. Possible issues to be addressed in the Borrower Environmental and Social Commitment Plan (ESCP): The Environmental and Social Commitment Plan (ESCP) will include the requirement to prepare an e-waste plan, a draft (at the end of the first year of the implementation of the project) and a final version required to be ready before the first batch of devices purchased under this project reach their expected lifespan of three years. In addition to this, the ESCP will also include appropriate health and safety measures for the activities of storage and distribution of the Public Disclosure devices. These measures shall be also incorporated in the Operational Manual and in the bidding documents for purchasing and/or distribution of the devices. The ESCP will also include measures to promote social inclusion, based on the results of the social assessment. C. Timing Tentative target date for preparing the Appraisal Stage ESRS 14-Oct-2021 IV. CONTACT POINTS World Bank Contact: Ciro Avitabile Title: Senior Economist Telephone No: 5357+2338 / 51-1-6222338 Email: cavitabile@worldbank.org Borrower/Client/Recipient Borrower: Ministerio de Economía y Finanzas del Perú Implementing Agency(ies) Implementing Agency: Ministerio de Educación del Perú May 26, 2021 Page 11 of 12 The World Bank Supporting investments in education for human capital development in Peru (P170478) V. FOR MORE INFORMATION CONTACT The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Leader(s): Ciro Avitabile Practice Manager (ENR/Social) Maria Gonzalez de Asis Recommended on 24-May-2021 at 09:35:4 GMT-04:00 Safeguards Advisor ESSA Angela Nyawira Khaminwa (SAESSA) Cleared on 26-May-2021 at 14:45:45 GMT-04:00 Public Disclosure May 26, 2021 Page 12 of 12