Republic of Iraq Office of the Prime Minister Strengthening Public Financial Management Oversight and Accountability Institutions in Iraq - P170704 - Stakeholder Engagement Plan (SEP) September 23, 2019 1 1. Introduction and Project Description The Strengthening Public Financial Management (PFM) Oversight and Accountability Institutions in Iraq Project is a €15.6 million (US$17.6 million equivalent) World Bank-European Union (WB-EU) Technical Assistance Program that complements the existing International Bank for Reconstruction and Development (IBRD) Modernization of Public Financial Management Systems Project (P151357) for US$41.5 million. The project development objective is to strengthen systems of accountability and oversight in the use and management of public financial resources in Iraq at both the federal and regional levels. This Economic Governance Project has 3 components and 6 subcomponents. Each technical subcomponent corresponds to a specific government reform commitment/objective and has been assigned to a lead government institution/department acting as the World Bank Group (WBG)-EU counterpart. An agreement has been reached with the Federal Government for the financing of some subcomponents through the Recipient-Executed Trust Fund (RETF) with WBG support. Other subcomponents will be initially Bank-executed on behalf of the recipient due to capacity constraints. The project components and tentative amount allocated to each component is provided in Table 1. Phase I of this project is expected to be completed by 2021. Table 1: Components of the Project + Advisory Services and Analytics (ASA) Component Name Cost (US$, millions) Component 1 – Enhancing Fiscal Accountability 8.50 Component 2 – Transparency, Integrity, and Legal Certainty 5.50 Component 3 – Project Management and Implementation Support 3.63 CORRUPTION Total 17.63 In addition to the project RETF activities (RETF and BETF on behalf of the Recipient), there are specific Multi-donor Trust Fund (MDTF)-EU funded Advisory Services and Analytics (ASA P164640) activities that will support the project during the preparation and implementation phases. These include policy notes, analytical briefs, and other reports and recommendations, as well as capacity building, and independent evaluations of projects funded by the Trust Fund. 2. Summary of Previous Stakeholder Activities The environmental risk for the project is rated as Low, whereas the social risk is Moderate. The project will involve institutional strengthening and capacity development related to economic governance — activities that are not likely to result in negative social impacts. However, there might be a possibility of social risks relating to the social exclusion of particularly vulnerable and/or disadvantaged groups, or risks pertaining to labor and working conditions. Other risks include stakeholder risks, conflict or security concerns, and institutions and capacity. The project-affected parties could include all sectors and departments and concerned civil servants within the 13 federal and regional government institutions involved in project implementation, as well as the Project Coordination Unit (PCU). Affected individuals also include women, children, and other vulnerable or disadvantaged groups who wish to access public services. Other interested parties could potentially 2 include federal and regional government institutions, public and private investors, non-state actors and civil society. The initial round of stakeholder consultations will be done after the appraisal mission and negotiation of the grant agreement. However, as a part of project preparation and scoping, multiple meetings were held between the WB-EU technical team and representatives of key federal government institutions and stakeholders, including representatives from the Prime Minister’s Office (PMO), the Council of Ministers Secretariat General, the Federal Ministry of Finance, the Federal Ministry of Planning, the Federal Board of Supreme Audit (FBSA), the Commission of Integrity, the Reconstruction Fund for Areas Affected by Terrorist Operations (REFAATO), the Iraqi Council of Representatives (ICOR), and others. Meetings were also held at the federal level with representatives from the United Nations Development Programme (UNDP) and the Deutsche Gesellschaft für Internationale Zusammenarbeit (German International Development Agency) (GIZ). In the Kurdistan Region of Iraq (KRI), the mission met with representatives from the Kurdistan Regional Government (KRG) Office of the Prime Minister, the Office of the Deputy Prime Minister, the Ministry of Planning, the KRG Commission of Integrity, the KRG Board of Supreme Audit, and the Kurdistan Parliament. The teams also met with the Reform Coordinator of the United States Agency for International Development/Development Alternatives Inc. (USAID/DAI) responsible for the Iraq Governance and Performance Accountability Project, as well as with representatives of civil society organizations. Preliminary stakeholder mapping was conducted and the impact of the project intervention on various parties including civil servants was discussed. 3. Stakeholder Identification and Analysis According to the Environmental and Social Standards 10 (ESS10), there are two categories of stakeholders, as outlined below: 3.1 Affected parties ESS10 refers to the identification of individuals, groups, and other parties who may be directly or indirectly affected by the project, whether positively or negatively. The Stakeholder Engagement Plan (SEP) focuses particularly on those directly affected by the project activities. To date, the directly affected parties under this category have been identified as all departments and concerned civil servants within the 13 targeted federal and regional government institutions, including the PCU — one each at the federal and KRG level. The federal and regional institutions include the Prime Minister’s Office (PMO), the Council of Ministers Secretariat General, the Federal Ministry of Finance, the Federal Ministry of Planning, the Federal Board of Supreme Audit (FBSA), the Commission of Integrity, the Reconstruction Fund for Areas Affected by Terrorist Operations (REFAATO), the Iraqi Council of Representatives (ICOR), the KRG Commission of Integrity, the KRG Board of Supreme Audit, and the Kurdistan Parliament. The project will contribute toward improved public financial management oversight and accountability. The potential for the federal and regional governments to improve service delivery and increase participation, transparency and accountability vis-v-vis their citizenry, elected representatives and creditors is widely recognized. Several factors will help to improve the quality and efficiency of public spending, such as the gradual introduction of e-Government digital services — including e-Government procurement, the new approach for confronting and combating corruption, and the foundation for medium-term performance targets. They should also help to provide information to facilitate improved planning for the strategic allocation of resources. 3 According to the ESS10, it is particularly important to understand the project impacts and whether such impacts may disproportionately fall on disadvantaged or vulnerable individuals or groups — groups that often do not have a voice. In the case of the Economic Governance Program, there could be risks of exclusion of certain civil servants from targeted institutions due to inefficiencies in outreach to these groups to ensure their participation in issues such as payroll reform (that is, people with low information and information and communication technologies [ICT] literacy, disabled civil servants), or by unconscious discrimination/ practices under the current or new systems. There may also be risks of exclusion among certain categories of people in accessing public services due to a lack of information about the reforms, or because of their vulnerabilities (for example, the disabled, women, children, and minorities). These groups will be consulted as a part of the SEP. 3.2 Other interested parties A range of stakeholders may be interested in the project because it indirectly affects their work or has some direct bearing on it. These could include governmental officials from other ministries, for instance from the Ministry of Trade, Planning and Development, or those involved in issues such as human rights, climate change, and so on. Other interested parties could also include various federal and regional government institutions, public and private investors — including state-owned enterprises (SOEs), the WB-EU technical team, other multilateral or bilateral partners, non-state actors, civil society, labor unions, the media, and so on. There could also be possible social risks including labor and working conditions, insufficient stakeholder participation, and institutional and capacity weaknesses. As elucidated in ESS10, although these groups may not be directly affected by the project, they may have a role in the project preparation or have broader concerns beyond their individual interests. Thus, the SEP will entail consultations with representatives of each of these groups and will define a strategy for continual engagement with each throughout the project life. 3.3 Summary of Project Stakeholder Needs Please refer to Annex 1 below. 4. Stakeholder Engagement Program (SEP) 4.1. Purpose and Timing of the Stakeholder Engagement Plan The approach to the stakeholder engagement analysis will be underscored by three elements: a belief in the primacy of qualitative data; a commitment to participatory methods; and flexible, responsive methods. An inclusive and participatory approach will be followed taking the main characteristics and interests of the stakeholders into account, as well as the different levels of engagement and consultation most appropriate to the stakeholders. The SEP provides for enough consultations with all the afore- mentioned stakeholders, and their observations and suggestions will be recorded. A strategy for continual engagement throughout the project life will also be formulated. The project will incorporate multiple citizen engagement mechanisms and will gender tag its components and results framework. The Environmental and Social Commitment Plan (ESCP) and the Stakeholder Engagement Plan provide for regular consultations with and training for stakeholders, such as civil 4 servants within the sectors of intervention, and institutions and departments at the federal and regional levels. The project also supports the efforts of the PCU to increase their capacity in communications and outreach by hiring experienced communications professionals to design and implement awareness and education campaigns. In addition, the project will focus on providing adequate training to civil servants with low ICT skills. To the extent possible, the project will entail an accessible design to ensure that all cases of individuals with disabilities can be considered in Iraq. This will include access to the company’s website, the job application process, workplace technologies and content. In general, engagement is directly proportional to the impact and influence of a stakeholder. Due to moderate social risks —and in light of the security situation and emergency nature of the project — appropriate engagement methods will be designed. They will also be flexible throughout the project cycle. The engagement methods will include key informant interviews, public meetings, workshops, and focus group meetings. As the extent of the project impact on a stakeholder group increases — or the extent of influence of a stakeholder on a project increases — engagement with this specific stakeholder group should intensify and deepen in terms of the frequency and the intensity of the engagement method used. 4.2 Proposed Strategy for Information Disclosure Multiple consultative workshops will be held, and a representative sample of directly affected and other interested parties along with vulnerable groups will be invited. These platforms will be used to gather input about the project design and could also serve as information disclosure forums. The SEP and Environment and Social Commitment Plan will also be disclosed on the World Bank website. 4.3 Proposed Consultations Strategy Key Informant Interviews Consultations with all the afore-mentioned stakeholders will take place through a participatory process. As much as possible, key informant interviews will be conducted face-to-face; some interviews will be conducted remotely by telephone, or video conferencing if the stakeholders are not nearby or readily available. This will constitute the core method of data collection. Key informant interviews will be conducted using a semi-structured questionnaire, with key focus areas to be covered according to the type of informant. Questions will be formulated from the objectives and component areas outlined in the Project Appraisal Document (PAD). In addition, public meetings and workshops with relevant stakeholders, as well as focus group meetings with female employees, could also be used for consultations. 4.4 Proposed Strategy to Incorporate the Views of Vulnerable Groups Consultations will be carried out with representatives of disabled citizens groups. Accordingly, the design and engagement mechanisms and frequencies will be customized to those people who may be vulnerable, or to disadvantaged groups such as women, children, minorities, and so on. This will continue throughout the project life span. 5 4.5 SEP Timeline Table 2 outlines the tentative work plan and timeline. Table 2: SEP Timeline Activity Timeline Desk-based - Review Project Appraisal Document and the ESS Guidance Note and Completed/ summary to ascertain planning and execution of activities for each output. Questionnaire to be - Develop the questionnaire and identify the sample. developed before implementation. Engagement with Project Staff and Local Stakeholders - Engage with Project Staff to: Will continue a) Interview relevant persons at the PCU, Ministry. throughout project b) Conduct a focus group discussion with female employees. implementation c) Identify and interview relevant local stakeholders for this analysis. Consultations/ Meetings Will continue throughout project implementation. 4.6 Review of Comments Comments will be noted and reviewed during each type of consultation, including key informant interviews, focus group discussions, consultative workshops, and workshop discussions. These notes will then be formulated into a report. Based on the analysis collected, changes may be made to project implementation. 4.7 Future Project Phases The detailed consultations will suggest modes of communication and frequency of future engagements suitable to each type of stakeholder. Annex 2: Planned Stakeholder Engagement Activities include the targeted stakeholder for engagement, the topics to be discussed, the methods to be applied, the location and frequency, the responsible institutions. 5. Resources and Responsibilities for Implementing Stakeholder Engagement Activities 5.1 Resources The project will have two part-time Social Specialist (Federal and Regional levels) overseeing the implementation of the SEP. In addition, the PCU will designate part-time environment and social focal points at each ministry charged with implementing the individual components. The project will also undertake measures for institutional capacity building, including implementation of the SEP. Regular training will be organized for the staff of the PCU and the Project Implementation Units (PIUs). World Bank staff will also provide additional training to the PCU and PIU staff as needed. SEP preparation costs will be 6 secured under operational costs. Costs for implementation will be covered under the overall costs of implementing the ESCP (staff time, and so on). 5.2 Management Functions and Responsibilities The Social Specialist at the PCU will be responsible for implementing the SEP and will serve as the project focal point. There will be a separate Social Specialist at the federal and regional levels. 6. Grievance Redress Mechanism (GRM) A Grievance Redressal Mechanism (GRM) will be developed and operationalized, commensurate with the requirements of the ESS10. This GRM will serve as a channel by which to voice complaints and/or issues raised or faced by beneficiaries and stakeholders. The SEP follows the template/guidelines provided by the World Bank to prepare and operationalize the GRM. Ultimately, the objective of engaging with the various stakeholders is to create an atmosphere of understanding. These groups should be provided with enough opportunity to voice their opinions and concerns on issues that may influence project decisions. The PCU maintains an online Complaints section, where anyone can register a complaint about any issues pertaining to this project. The website provides the complainant with the choice of sending hard copies and provides a mailing address. The existing government website will also include a section on online complaints to be moderated by the PCU. In addition, social media pages such as Facebook and Twitter could also be used for complaints. For stakeholders who are not information technology (IT) savvy, a complaint box could be placed at various locations, including locations easily accessible to the disabled. The Alternate Dispute Resolution is a system whereby the stakeholders can refer any project issues and recommendations for consideration to independent experts to be constituted by the PCU as needed. Separate GRMs will be established at the federal and regional levels after the PCUs become operational (Timeline for processing complaints, monitoring, recording, reporting protocols, etc.). However, the effectiveness of the entire system needs to be evaluated for its timely response, engagement and resolution process, as well as the frequency of communications with the complainant. The PCU will require assistance in making the GRM simpler, and more linguistically appropriate (for example, complaint forms should also be available in Arabic), as well as accessible through other means. Also, accessibility to lesser educated and disabled stakeholders needs to be ensured. In addition, information about the GRM needs to be widely circulated through dedicated media campaigns using print, electronic, and social media so that all stakeholders are aware of this facility dedicated to their benefit. 7. Monitoring and Reporting 7.1 Involvement of stakeholders in monitoring activities The ESCP and the SEP will require regular consultations with stakeholders to obtain feedback regarding the effectiveness of facilitation measures and will seek to gather suggestions for further improvements. These consultations will also be used to gather information about the project’s progress in meeting the results indicators, as noted in the project’s results framework. 7 Biannual ESCP compliance monitoring reports will be prepared and submitted by the project’s Environment and Social Specialists throughout the project life. 7.2 Reporting to stakeholder groups The biannual reports will be submitted to the World Bank. The results of stakeholder engagement activities will be reported back to both affected stakeholders and broader stakeholder groups. The project also supports the PCU’s efforts to increase its communications capacity and outreach by hiring experienced communications professionals to design and implement stakeholder awareness, education campaigns, as well as a feedback loop. 8 Annex 1: Summary of Project Stakeholder Needs Stakeholder Identified Party Key Characteristics Needs/Issues Preferred Notification Specific Group and Frequency Needs Departments and civil Nationwide presence with Federal and regional governments need to To be decided. To be servants within the 13 more than 3 million civil improve service delivery and increased identified. federal and regional servants, excluding those participation, transparency and accountability government working in SOEs. vis-v-vis their citizenry, elected institutions, including representatives and creditors. the PCU and PIUs. Civil servants need to be paid in a timely and accurate manner. Relevant civil servants need to be trained on key IT systems and competencies (i.e. e-government payment and e-government procurement systems, ICT- based case management system, etc.) Affected Parties Capacity building, staffing, and training of PCU and PIUs to comply with the Environmental and Social Framework (ESF) requirements. Basic requirements on labor and working conditions: terms and conditions of employment, non-discrimination and equal opportunity, worker’s organizations, child and forced labor, the grievance mechanism, and occupational health and safety (OHS). Issues might occur if institutional reforms have an impact on worker-related issues, such as hiring practices/ retrenchment. People with low ICT training may not be Unable to use computers or utilize the online To be decided. To be Affected information and enough to handle the reporting formats. identified. Parties communication advanced software and technologies (ICT) hardware systems. 9 Stakeholder Identified Party Key Characteristics Needs/Issues Preferred Notification Specific Group and Frequency Needs literacy (including both employees and citizens). Government set quotas for Job retention, promotion and incentives; non- To be decided. To be female civil servants. discrimination and equal opportunities. An identified. enabling environment and performance Affected incentives are required and should be based Parties Female employees on a robust appraisal system and measures to promote a more diverse workforce by improving the hiring and retention of women. Other Federal and regional Various participating Project information, scope, rationale, E&S To be decided. To be Interested government government agencies at the principles identified. Parties institutions, public and federal and regional levels private investors, need to coordinate with the May have a role in the project preparation, or including SOEs, the PCU to provide the required have broader concerns beyond their individual WB-EU technical team, information. interests (i.e. human rights, climate change, other multilateral or etc.) bilateral partners, non-state actors, civil society, labor unions, and so on. Women, children, Their vulnerabilities might Small, focused meetings may be needed to To be decided. To be Disadvantaged minorities, and other affect their abilities to access provide a more comfortable environment in identified. / Vulnerable vulnerable or public services (for example, which to raise issues. Need translation into a Individuals or disadvantaged groups public finance literacy minority language. Lack of transportation to Groups who wish to access campaigns). events, difficulties in accessing venues. public services. Disadvantaged Disabled stakeholders Not able to operate or access People who are physically handicapped (blind To be decided. To be / Vulnerable ICT. or unable to use their hands) or who have a identified. Individuals or learning disability such as dyslexia can be Groups excluded. 10 Annex 2: Planned Stakeholder Engagement Activities Stakeholder Identified Party Topics of Engagement Method(s) Used Preferred Responsible Group Notification and Institutions Frequency Departments and civil Project information- scope, Key informant interviews, other interviews (by To be decided. PCU Social servants within the 13 rationale and E&S principles, phone/ video conferencing), public meetings, Specialists federal and regional especially e-government workshops, focus group meetings government institutions, payment/ procurement/ case Each including the PCU and management reforms Training on e-government digital services Ministry’s Affected PIUs. environment Parties Training on e-government Capacity building, staffing, and training of PCU and social Nationwide presence digital services and PIUs to comply with the Environmental focal points with more than 3 million and Social Framework (ESF) requirements civil servants, excluding Grievance mechanism those working in SOEs. process People with low Project information- scope, Dedicated training to civil servants with low To be decided. PCU Social information and rationale and E&S principles, ICT skills Specialists communication especially e-government technologies (ICT) literacy payment/ procurement/ case Consultations or focus group meetings Each Affected (including both management reforms Ministry’s Parties employees and citizens). Complaint box placed at various locations, environment Adequate ICT training, or including locations easily accessible to the and social alternative methods disabled. focal points Grievance mechanism process Female employees Project information- scope, Conduct a focus group discussion with women To be decided. PCU Social rationale and E&S principles, employees Specialists especially e-government payment/ procurement/ case Training on e-government digital services Each Affected management reforms Ministry’s Parties environment Training on e-government and social digital services focal points 11 Stakeholder Identified Party Topics of Engagement Method(s) Used Preferred Responsible Group Notification and Institutions Frequency Grievance mechanism process Other Federal and regional Project information- scope, Consultations with representatives of each of To be decided. PCU Social Interested government institutions, rationale and E&S principles these groups. Specialists Parties public and private investors, Coordination activities including SOEs, the WB- EU technical team, other Grievance mechanism multilateral or bilateral process partners, non-state actors, civil society, labor unions, and so on. Women, children, Project information- scope, Small, focused meetings may be needed to To be decided. PCU Social minorities, and other rationale and E&S principles provide a more comfortable environment in Specialists vulnerable or which to raise issues. Need translation into a disadvantaged groups Accessible design to ensure minority language. Provide transportation to Disadvantaged who wish to access public disadvantaged/ vulnerable events if needed. / Vulnerable services (for example, individuals or groups are Individuals or public finance literacy considered and advocated for Complaint box placed at various locations, Groups campaigns). including locations easily accessible to the Grievance mechanism disabled. process Disabled stakeholders Project information- scope, Consultations or focus group meetings. To the To be decided. PCU Social who are not able to rationale and E&S principles, extent possible, the project will entail an Specialists Disadvantaged operate or access ICT. For especially e-government accessible design to ensure that individuals / Vulnerable example, people who are payment/ procurement/ case with disabilities are considered and advocated Each Individuals or physically handicapped management reforms for in every stage of a company’s operations Ministry’s Groups (blind or unable to use and processes. This includes access to the environment their hands) or who have Accessible design to ensure company’s website, the job application and social individuals with disabilities process, workplace technologies and content. focal points 12 Stakeholder Identified Party Topics of Engagement Method(s) Used Preferred Responsible Group Notification and Institutions Frequency a learning disability such are considered and advocated as dyslexia. for. Complaint box placed at various locations, including locations easily accessible to the Grievance mechanism disabled. process 13