THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) GOVERNMENT OF SIERRA LEONE Ministry of Finance Resilient Urban Sierra Leone Project [P168608] ENVIRONMENTAL & SOCIAL COMMITMENT PLAN March 25, 2021 1|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Sierra Leone (GoSL or Recipient) is implementing the Resilient Urban Sierra Leone Project (the Project) with the involvement of various cities and municipal councils of Sierra Leone, the Ministry of Local Government, and the National Disaster Management Agency. The International Development Association (hereinafter the Association) is providing financing for the Project. 2. GoSL shall implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs) of the World Bank. This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. GoSL shall also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as Environmental and Social Management Framework (ESMF), Environmental and Social Impacts Assessments (ESIA), Environmental and Social Management Plans (ESMP), Resettlement Framework, Resettlement Action Plans (RAP)/ Livelihood Restoration Plans (LRP), and Stakeholder Engagement Plans (SEP), and the timelines specified in those E&S documents. 4. GoSL is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by any ministry, agency, local government units referenced in 1. above or another entity. 5. Implementation of the material measures and actions set out in this ESCP shall be monitored and reported to the Association by GoSL as required by the ESCP and the conditions of the legal agreement, and the Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Association and GoSL, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, GoSL, through such authorized delegates as it may designate, will agree to the changes with the Association and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the Association and the GoSL, through such authorized delegates as it may designate. The GoSL, through such authorized delegates as it may designate, shall promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the GoSL shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include environmental, health, and safety impacts, labor influx, gender-based violence. 2|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Quarterly throughout Project MoF (Fiscal Decentralization The supervising engineer shall be required to conduct daily implementation. Division) through the PMU shall be monitoring and submit monthly Environmental, Social, Health and responsible for funding and submitting Safety (ESHS) report to the Project Management Unit (PMU). ESHS performance report for review Parallel E&S supervision report from the Local Council and discussion to the Association, in a Environmental and Social Officers (ESOs) shall be submitted to the manner satisfactory to the Association. PMU. Ministry of Finance (MoF) through the PMU, shall prepare and submit quarterly monitoring reports on the ESHS performance of the Project to the Association. The reports shall, among other elements, include (i) status of implementation of the ESCP; (ii) conditions, if any, which interfere or threaten to interfere with the implementation of the ESCP; and (iii) corrective and preventive measures taken or required to be taken to address such conditions (iv) stakeholder engagement activities and functioning of the grievance mechanism. The PMU shall establish an electronic or digital tool to facilitate reporting from Project sites to the PMU. 3|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY B INCIDENTS AND ACCIDENTS Notification to the Association should Overall responsibility rests with MoF Recipient shall promptly notify the Association of any incident or take place within 48 hours and shall (Fiscal Decentralization Division) accident related or having an impact on the Project which has, or is occur no later than 72 hours after likely to have, a significant adverse effect on the environment, the becoming aware of the incident or affected communities, the public or workers, including but not accident. limited to fatalities or instances of serious bodily harm, fire injuries, physical violence, Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH), car accidents, communicable diseases, and infections. The Recipient’s report to the Association shall include full detail of Report to be prepared and submitted to the incident or accident, indicating immediate measures taken to the Association on timeframe specified address it, and include information provided by any contractor and by the Association. supervising entity, as appropriate. Subsequently, as per the Association’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. C CONTRACTORS MONTHLY REPORTS The reports shall be submitted to the MoF (Fiscal Decentralization Require and ensure that contractors provide monthly monitoring PMU monthly, and to the Association Division) through the PMU reports, including procurement report, to the PMU. These reports upon request. shall also be submitted to the Association upon request. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 4|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY 1.1 ORGANIZATIONAL STRUCTURE PMU has been established and hiring The MoF shall maintain and Building on the project management unit that was established for of E&S Specialists completed. The strengthen the PMU as necessary. the implementation of the Project Preparation Advance (PPA), specialists shall be maintained Recipient shall maintain a Management Unit for the Project (PMU) throughout Project implementation. with an EHS unit with qualified E&S experts, including one Environmental Specialist, one Social Specialist, one Gender and GBV Specialist, and one community/stakeholder Engagement Specialist (together, the “E&S Specialists�). These E&S Specialists shall be responsible for managing the E&S risks of the Project and ensuring that the Project is implemented in accordance with this ESCP. The E&S Specialists shall be supported by the local council Environment and Social Officers and engineers at the Regional and District levels (in each targeted district) to implement the Project and adequately resourced (with computers and accessories, transportation and stipends). The PMU shall also hire external expertise and consultancy services as necessary to ensure that the Project is implemented in accordance with this ESCP. This organizational structure shall be maintained throughout Project implementation. At the community levels, the existing Ward Development Committees structure shall remain the structures for Project interface with the communities and shall be involved in community mobilization and planning as appropriate. 5|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT ESMF has been finalized, cleared, MoF (Fiscal Decentralization An Environmental and Social Management Framework (ESMF) consulted on and disclosed. ESMF shall Division) PMU to supervise the has been prepared for the Project through independent consultancy be implemented throughout Project preparation of ESF documents. services. It contains preliminary E&S assessment of the landfill and implementation. Funding for consultancy services shall neighborhood upgrading sites. Subprojects shall be screened for be covered by the Project. Environmental and Social risks and impacts in accordance with the Screening of subproject activities for procedures of the ESMF and the ESSs, in a manner acceptable to E&S risks shall be conducted prior to the Association. Based on the screening results, detailed commencing of the relevant sub-project environmental and social assessments shall be conducted and activities. corresponding, site-specific ESIAs and/or ESMPs shall be prepared, disclosed, adopted, and implemented to address any risks Preparation, disclosure, consultation, identified during the process, in accordance with the ESMF and and adoption of all ESIAs and/or ESSs, and in a manner acceptable to the Association. All ESIAs ESMPs shall take place before the start shall be comprehensive to include assessment of waste management of subproject works. and pollution, Labor influx, SEA/SH risk assessment, social diversity and gender, impacts on vulnerable and disadvantaged ESIA for Western Area Rural District groups or individuals, etc., and preparation of a draft ESMP, Labor shall be prepared once interventions Management Procedures (LMP) and SEA/SH Action Plan. have been identified and shall be finalized and approved by the Full Environmental and Social Impact Assessments (ESIA) for the Association before disbursement for construction of the new landfill and one ESIA for the neighborhood Project Component 2.2 may begin. upgrade interventions shall be prepared, disclosed, adopted, and implemented. No disbursement shall be made for the construction of the new landfill in the Western Area Rural District, until (i) a site for the construction of the landfill in Western Area Rural District is secured/selected on the basis of environmental and social assessments satisfactory to the Association, and (ii) receipt by the Association of all required ESIA and RAP for the said landfill site, in form and substance satisfactory to the Association. CONTINGENT (EMERGENCY) RESPONSE FINANCING Develop, adopt, and implement CERC-ESMF that includes a The CERC ESMF shall be prepared no MoF (Fiscal Decentralization description of the ESHS assessment and management arrangements later than 60 days post Project Division) PMU, Office of the National and procedures for the activation and implementation of the CERC Effectiveness and thereafter applied to Security (ONS) under the Project in accordance with the ESSs. CERC activities when triggered. Implement the measures and actions 6|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY Thereafter prepare, disclose, consult, adopt, and implement any required under the CERC E&S environmental and social (E&S) management plans or other management plans or instruments, instruments required for the respective CERC activities in within the timeframes specified in the accordance with the ESSs, CERC-ESMF, the World Bank Group plans. Environmental, Health and Safety Guidelines (EHSGs), and other relevant Good International Industry Practice (GIIP) including World Health Organization (WHO) guidance documents on COVID-19 in a manner acceptable to the Association. Thereafter implement the measures and actions required under the said E&S management plans or instruments, within the timeframes specified in the plans. 7|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 1.3 MANAGEMENT TOOLS AND INSTRUMENTS MoF (Fiscal Decentralization Screen any proposed subproject in accordance with the Screening to be conducted and ESMPs Division) through PMU E&S Unit, and Environmental and Social Management Framework (ESMF) adopted and implemented throughout consultants. Funding from project prepared for the Project, and, thereafter, draft, disclose, consult, Project implementation. budget. adopt, and implement the subproject Environmental and Social Management Plan (ESMP), as required by the ESMF and ESSs, in a manner acceptable to the Association. The GoSL shall: a. Develop disclose and implement an Environmental and a. The ESMF, RPF, and SEP have been Social Management Framework (ESMF) including Labor completed, consulted on, cleared and Management Procedures (LMP), Stakeholder Engagement disclosed, and shall be implemented Plan (SEP), and Resettlement Policy Framework (RPF) throughout Project implementation. satisfactory to the Association. b. Subsequently during project implementation, use the b. Screening shall be conducted as soon subprojects Screening Forms and Impacts Checklist Forms as sub-project locations are identified of the ESMF to screen all subprojects to determine and and before carrying out of such comply with requirements for follow-up E&S instruments, activities. including ESIA, ESMPs, RAPs, Biodiversity Management Plans (BMPs), and Livelihood Restoration Plans (LRP). The ESMF shall include prescreening of subproject activities. If it is determined for these subproject activities that critical biodiversity is likely to be impacted, then a standalone BMP shall be prepared and implemented. The RPF shall determine the preparation of follow-up RAPs and LRPs. c. Prepare, disclose, adopt and implement Environmental and c. Full ESIA, ESMP, RAP, LRP and Social Management Plans (ESMPs), Resettlement Action BMP shall be prepared before Plans and LRPs required for the respective sub-project commencement of construction and, in activities in accordance with the assessment process in the the case of the landfill, before ESMF, the ESSs, the EHSGs, the World Bank interim disbursement under Component 2.2. guidance for construction and stakeholder Engagement during COVID-19, Good practice note on SEA/SH in civil 8|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY works and other relevant Good International Industry Practice (GIIP) including WHO guidelines on COVID-19 prevention. The ESMP shall comprise Environmental and Social Management and Monitoring, Emergency preparedness and response plan (including COVID-19 response plan), GBV Action Plan, Waste Management Plan, Occupational Health and Safety Plan, Community Health and Safety Plan, Traffic Management Plan, Closure or Decommissioning Plan. d. Before carrying out of the relevant d. Prepare, adopt, and implement a Project Operations Project activities. Manual that includes E&S requirements consistent with this ESCP. The Project Operations Manual shall reflect, at a minimum: • The roles of E&S Specialists • The minimum E&S clauses to be included in the terms of reference and tender documents for contractors • Incorporation of E&S indicators into monitoring and evaluation system • Completion timeline 9|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY 1.4 PERMITS, CONSENTS AND AUTHORIZATIONS Permits, consents, and authorizations to MoF (Fiscal Decentralization Division) Obtain or cause others to obtain the relevant permits, consents and be obtained prior to the initiation of /PMU E&S specialist. authorizations that are applicable to the Project from relevant relevant Project activities, and national authorities/agencies such as: therefore complied with throughout • Environmental permits/licenses Project implementation. • Water use permits • Building/construction permits • Verifiable land title deeds • Land use rights/permits • Any other licenses, permits, consents and authorizations as and when required Comply or cause others to comply with the conditions established in these permits, consents and authorizations throughout Project implementation. 10 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY 1.5 MANAGEMENT OF CONTRACTORS Include ESHS provisions in bidding and MoF/PMU, PMU E&S specialists, Manage and supervise contractors and subcontractors to ensure contractual documents for works prior procurement officer. their compliance with the ESSs and the terms of this ESCP, preparation of procurement documents. including by integrating ESHS specifications into procurement Prepare C-ESMP before documents and contracts and thereafter. These ESHS commencement of civil works. specifications shall include but not be limited to: Supervise contractors throughout • Relevant requirements included in contracts and Project implementation. subcontracts (reflecting ESSs and ESCP); • Codes of conduct (CoC) for contractors and subcontractors and their workers to prohibit sexual harassment and exploitation and training of workers on their obligations under the CoC; • Contractor to prepare a costed SEA/SH Action Plan as part of the contractor ESMP • Preparation of a contractor ESMP (C-ESMP) that is costed, with sufficient budget to mitigate E&S risks • Monitor Contractor commitment and compliance • Ensure contractors provide details on contractor’s oversight on environmental, social, health and safety (ESHS) performance • Contractor to develop a grievance redress mechanism to handle concerns of their employees • Labor Management Plan to be developed by contractor based on the project Labor Management Procedure as part of the ESMF. 1.6 THIRD PARTY MONITORING TPM shall be hired no later than one MoF (Fiscal Decentralization Third Party Monitoring: An independent consultant (firm) shall be month after Project Effectiveness to Division). PMU E&S specialists shall appointed to monitor the implementation and compliance with the conduct baseline assessment upon hire ensure that the selected TPM ESMPs (including contractor Labor Management Plan, GBV and thereafter conduct monitoring once consultant conduct the monitoring in a action Plan), RAPs, LRPs, SEP, OHS plan, emergency. a year throughout Project manner satisfactory to the PMU and preparedness and response plan implementation. the Association. ESS 2: LABOR AND WORKING CONDITIONS 11 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY 2.1 LABOR MANAGEMENT PROCEDURES a. LMP has been prepared as part of MoF (Fiscal Decentralization a. The Labor Management Procedures (LMP) developed for the ESMF and shall be implemented Division) Project shall be implemented throughout Project implementation. throughout Project implementation. PMU E&S specialists shall ensure that The LMP shall set out the way in which Project workers shall be the selected contractor comply with managed, in accordance with the requirements of Sierra Leone these requirements. national law and ESS 2. The LMP shall address the way in which ESS2 will apply to different categories of Project workers, including through implementing adequate occupational health and safety (OHS) measures, setting out grievance arrangements for Project workers and requirements for Project contractors to manage their workers b. The Labor Management Procedure shall be referenced in the b. ESHS specifications spelled out prior ESHS specifications of the procurement documents with to the preparation of procurement requirements for contractors to update into a Plan during documents. Contractor ESHS measures implementation and comply with its requirement. It shall also to be maintained throughout Project require preparation of an OHS plan consistent with the World Bank implementation. Group’s EHS Guidelines. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Grievance mechanism operational prior MoF and contractors Establish, maintain, and operate a grievance redress mechanism to recruitment of Project workers and (GRM) for Project workers, including contractors, as described in implemented throughout Project the LMP and consistent with ESS2. implementation. 12 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) OHS plans adopted prior to initiating MoF/PMU/ E&S Specialists/ MEASURES construction in accordance with ESMP Contractors Require and ensure that contractors prepare, adopt, and implement timeframe under 1.3 and implemented occupational, health and safety (OHS) measures specified in the throughout Project life. ESMP prepared under action 1.3 of this ESCP. Require and ensure that Project contractors abide by the approved occupational, health and safety (OHS) plan/measures. The OHS plan shall conform with GIIP, ESHS Guidelines as well as WHO country and technical guidance – coronavirus disease (COVID-19) documents for the prevention of the transmission of the COVID 19 infection. Contractor measures shall also be consistent with GoSL’s directive and policy on COVID 19. Contractor’s Health and safety officer and MoF E&S specialists shall train/orientate employees of Project Contractors on various aspects of OHS relevant to the project. 2.4 EMERGENCY PREPAREDNESS AND RESPONSE Prior to initiation of subprojects MoF (Fiscal Decentralization As part of the OHS measures specified above in 2.3, institute involving construction. Division)/PMU E&S specialist/ measures on Emergency Preparedness and Response, and ensure Contractors. effective coordination with measures under 4.5., including ensuring Maintained throughout Project that Project workers and contractors are trained on emergency implementation preparedness and response and the implementation the relevant plan. 2.5 PROJECT WORKERS TRAINING Training to be completed within one MoF (Fiscal Decentralization Implement training programs for Project workers to improve month of recruitment, with periodic Division)/PMU E&S specialist. awareness of environmental and social risks of the Project and to refresher trainings thereafter Funding from Project budget mitigate impacts on local communities, as defined in the LMP, throughout Project implementation. ESMF/ESMPs and GBV action plan. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 13 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/ AUTHORITY 3.1 RESOURCE EFFICIENCY AND POLLUTION Solid Wastes Management Plan (SWM), MoF through the PMU. PREVENTION AND MANAGEMENT Hazardous Waste Management Plan, Funding covered by the Project Resource efficiency and pollution prevention and management Emergency Response Plan (ERP), and measures shall be addressed in the ESMPs to be prepared under Traffic Management Plan shall be action 1.3 above, in accordance with ESS3 and in a manner prepared once sites for specific satisfactory to the Association. These measures shall account for interventions have been identified. The and mitigate, among other risks, air pollution, noise, and land and above plans shall be part of ESMP and water pollution. In addition, a Traffic Management Plan, applied throughout Project Emergency Response Plan (ERP), Hazardous Waste Management implementation. Same timeframe as for Plan shall be prepared to mitigate and manage the anticipated risks. the preparation and implementation of the ESMPs. The ESMF shall provide the framework for the assessment and management of E&S risks for Western Area landfill site, solid waste management in Western Area and secondary cities and neighborhood upgrades. For the development of the landfill site in the Western Area, an ESIA and a standalone Solid Waste Management (SWM) plan shall be prepared that includes mitigation of E&S impacts in accordance with ESS3. For market upgrades in secondary cities, waste management shall be address under the ESMPs in accordance with the ESMF and ESS3. For general wastes management, require and ensure that Project contractors develop and implement a waste management plan, including to manage hazardous materials and chemicals, as an annex to the Contractor ESMPs. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Measures adopted on ESMP timeframe MoF through the PMU; Funding Require and ensure that Project contractors develop and implement specified in 1.3 and implemented covered by the Project measures and actions to assess and manage traffic and road safety throughout Project implementation. risks. These measures shall be included in the ESMPs to be developed under action 1.3 above. 14 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 4.2 COMMUNITY HEALTH AND SAFETY: Measures to be adopted on same MoF/PMU/E&S Specialists/ shall Require and ensure that contractors develop and implement timeframe as ESMPs under 1.3 above, ensure that the document is approved adequate measures and actions to assess and manage risks and and thereafter implemented and available prior to Project impacts to the community arising from Project activities in throughout Project implementation. implementation activities as well as accordance with ESS4. These measures shall be reflected in a supervise implementation of the ESMP Community Health and Safety Plan to be included in the ESMP. by the contractor. These measures shall include, inter alia, measures to prevent, minimize, and mitigate: the potential for community exposure to communicable diseases, accidents and pollution; harm caused by Project workers; risks of labor influx; harm from responses to emergency situations; and sexual exploitation and abuse, and sexual harassment; and harm to or exclusion of Project benefits for individuals or groups who, because of their particular circumstances, may be disadvantaged or vulnerable, including but not limited to persons with disabilities. Contractors’ measures, and work methods shall be validated by the local authorities and approved by the PMU. The Community Health and Safety Plan (CHS plan) shall also include guidelines provided by WHO and GoSL’s directives on the prevention of community transmission of coronavirus disease (COVID-19). Each contractor shall be required to conduct its activities in such a manner as to ensure that its workers do not become the source or means of transmission of COVID-19 infection in communities. CHS shall be part of the ESMPs, which shall be prepared in accordance with the ESMF, in accordance with ESS4 and in a manner acceptable to the Association. 15 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 4.3 GBV AND SEA RISKS: a. Submit the GBV Action Plan for the MoF (Fiscal Decentralization a. Prepare, adopt, and implement a stand-alone SEA/SH Action Association’s approval no later than 90 Division) through the PMU/Project Plan (GBV Action Plan) satisfactory to the Association and days after Project Effectiveness and in E&S Specialists/ Contractors. applicable to the Project as a whole, to assess and manage the any event before the preparation of the Funding as part of Project cost. risks of sexual exploitation and abuse (SEA) and Sexual procurement documents. Once Harassment (SH) consistent with ESS4. approved, implement the GBV Action Plan, throughout Project b. Hire a local nongovernmental organization (NGO) to assist in implementation. SEA/SH response, including supporting the preparation of the GBV Action Plan, the design of SEA/SH sensitive GRM, training b. NGO to be hired no later than 30 days and awareness raising on SEA/SH for the local communities and after Project Effectiveness. MoF, ensuring that care seeking behaviors and knowledge of how and where to report SEA/SH cases are known and support survivors to receive appropriate support services (medical/physical-social counseling and legal aid as agreed with the survivor). c. Contractors to integrate GBV-related measures as part of Contractor ESMP c. Project contractors shall be required to integrate GBV-related on timeframe specified in in 1.5, and measures consistent with the GBV Action Plan as part of the thereafter implement those measures contractor ESMP and shall strictly implement the GBV-related throughout Project implementation. measures and accountability framework spelled out in this ESMP. Recipient to monitor contractor The contractors shall ensure adequate costing and funding for the compliance with GBV Action Plan and implementation of these GBV-related measures. GBV-related measures in ESMP throughout Project implementation 4.4 GBV AND SEA RISKS DURING PROJECT Monitoring of contractor compliance MoF (Fiscal Decentralization IMPLEMENTATION: with GBV Action Plan throughout Division) through the PMU/project GBV Action Plan shall be required by the contractor as part of C- Project implementation E&S Specialists/ Contractors. ESMP with adequate funding for implementation. Funding as part of Project cost. 16 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 4.5 SECURITY PERSONNEL: Security-related mitigation measures to MoF (Fiscal Decentralization Subject to the provisions of ESS4 and the adoption of appropriate be integrated in ESMP prior to hire of Division) through the PMU/project mitigation measures in the contractor ESMP, contractors may security personnel, and thereafter E&S Specialists/ Contractors. employ unarmed guards to help secure Project sites. These implemented throughout Project mitigation measures shall include security awareness training, implementation. fencing, sign-posing, lighting, ESHS, adherence to a GBV code of conduct, reasonable background enquiries, and referral to the Project GRM of any incidents or grievances related to security personnel. Any further security measures for the Project may only be adopted with prior written approval of the Association. Ensure that contractors do not engage in activities that may impede the operations of the Emergency Operations Center (EOC) or the security forces that are implementing the GoSL’s COVID- 19 emergency preparedness and response under the current State of Public Health Emergency. Require and ensure that contractors observe all national laws, directives, regulations, lockdowns or curfews instituted by GoSL. 4.6 TRAINING FOR THE COMMUNITY Prior to initiating construction, with MoF (Fiscal Decentralization Conduct training programs for Project-affected communities to regular refresher training. Division) /PMU E&S specialists raise awareness of Project-related environmental and social risks, Funding as part of Project cost. impacts and mitigation measures, including but not limited to training on the following issues: • Community grievance redress mechanism as described in the SEP/ ESMF • Communicable and other diseases including HIV- AIDS/STI • SEA/SH awareness and prevention • Road Safety Awareness ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 17 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 5.1 RESETTLEMENT PLANS: MoF/PMU E&S Specialists shall a. Prepared, adopt, and implement a Resettlement Policy a. RPF has been prepared and disclosed ensure that the RAP has been Framework (RPF) for the Project consistent with ESS5 and prior to appraisal, and to be implemented consistent with ESS 5 satisfactory to the Association. implemented throughout Project before mobilization of contractor. implementation. b. Prepare, adopt, and implement resettlement plans (RAPs) and b. RAPs and Livelihood Restoration Livelihood Restoration Plans (LRPs) in accordance with ESS 5 and Plans (LRPs) prepared for the consistent with the requirements of the RPF. The respective RAPs neighborhood upgrade, landfill site and and LRPs shall be implemented before carrying out the market upgrade and approved by the corresponding activities, in a manner acceptable to the Association. Association before commencement of procurement activities that involve land acquisition and resettlement. 5.2 GRIEVANCE MECHANISM MoF (Fiscal Decentralization GM to be operationalized prior to The grievance mechanism (GM) to address resettlement-related Division) shall ensure a GRM has been commencement of resettlement complaints shall be described in the RPF, RAPs and SEP, and will set up and is operationalized before activities and maintained throughout be completed before commencement of project activities. The mobilization of contractor. implementation. GRM will integrate existing GRM systems in place at the MoF and the local level. 5.3 MONITORING AND REPORTING ON RESETTLEMENT Quarterly throughout implementation MoFPMU E&S Specialists shall ACTION PLANS of RAPs ensure that the regular RAPs Prepare and submit to the Association regular monitoring reports implementation reports are prepared on the implementation of Resettlement Action Plans, including on in a manner consistent with the issues related to land acquisition, assessment/census of Project- requirements of ESS 5. affected people and compensation. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 18 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 6.1 BIODIVERSITY RISKS AND IMPACTS Measures to be adopted as part of ESIAs MoF (Fiscal Decentralization No Project activity shall be conducted in the forest reserve or its and ESMPs on timeframes specified in Division)/PMU E&S specialist. buffer. Project activities shall be conducted in accordance with action 1.3, and thereafter implemented ESS6 to assess and avoid expected impacts on biodiversity and throughout Project implementation. habitats., Where avoidance is impossible, such impacts shall be minimized, mitigated, and offset in accordance with the mitigation Where a Biodiversity Management Plan hierarchy provided in ESS1, including through the following is required, it shall be prepared and procedures: adopted prior to commencement of field 1. Screening and risk classification of each subproject shall work, and thereafter implemented be conducted in accordance with the ESMF throughout Project implementation. 2. The risk level shall be reviewed throughout the Project life; 3. Where the anticipated biodiversity impacts are low or moderate, then biodiversity mitigation measures shall be described in the ESIA and ESMP; 4. Where they are substantial or high, a separate Biodiversity Management Plan shall be prepared and implemented by the contractor, in accordance with ESS6 and in a manner satisfactory to the Association. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 Not currently relevant to the Project ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS Chance Find procedure integrated in MoF (Fiscal Decentralization Adopt and implement a Chance Find procedure in the ESMF sub-project ESMPs in accordance with Division)/PMU E&S specialists developed for the Project in accordance with ESS8. Integrate timeframe in action 1.3, and thereafter Chance Find procedure in subproject ESMPs. implemented throughout Project implementation. In the event of a find, the Monuments and Relics Commission (MRC) that is entrusted with the protection of cultural heritage in Sierra Leone shall be contacted within 72 hours of the find. ESS 9: FINANCIAL INTERMEDIARIES 9.1 Not currently relevant to the Project ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 19 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION A draft SEP has be prepared and MoF (Fiscal Decentralization AND IMPLEMENTATION disclosed prior to appraisal. It shall be Division)/PMU E&S specialists Update, adopt, and implement Stakeholder Engagement Plan updated during implemented as needed (SEP) consistent with ESS10 in a manner satisfactory to the when major changes are required and Association. A draft SEP has been prepared and disclosed before re-disclosed. appraisal and thereafter shall be updated during implementation. 10.2 PROJECT GRIEVANCE MECHANISM The framework for project Grievance MoF (Fiscal Decentralization Prepare, adopt, maintain and operate a grievance mechanism, as Mechanism in place prior to appraisal. Division)/PMU E&S specialists described in the SEP, consistent with ESS10. It shall be updated and finalized, and the Grievance Mechanism operationalized as soon as possible before project effectiveness, and maintained throughout Project implementation. CAPACITY SUPPORT (TRAINING) 20 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 CS1 Specify Training to be provided Specify Targeted Groups and Specify Training Completed PMU and Contractor staff shall be required to enhance their E&S Timeframe for Delivery This will be done before start of capacity in accordance with the project E&S capacity building District Engineers and Environmental project implementation. plan, including by undergoing training. Training requirements Officers, Project Consultants. shall include: MoF (Fiscal Decentralization • stakeholder mapping and engagement Training shall be conducted as soon as Division), PMU E&S specialists and • specific aspects of environmental and social assessment workers are mobilized for the project contractors. • Subproject Environmental and Social screening implementation and shall continue • emergency preparedness and response every quarter. • community health and safety. • Occupational Health and Safety • Training on COVID 19 transmission, prevention, preparedness and response • Community health and safety • Monitoring and Reporting • SEA/SH Risk Mitigation • Disability inclusion training • GRM • Waste management (domestic solid wastes and sewage) • Documentation and reporting • Labor Management Procedures CS2 Train Project workers and community on occupational health and Training shall be done before MoF (Fiscal Decentralization safety, including on emergency prevention and preparedness and commencement of civil works Division), PMU E&S specialists and response arrangements to emergency situations. Training subjects contractors shall include: • community health and safety. • Occupational Health and Safety • communicable diseases/HIV-AIDS/STI awareness and prevention • community grievance redress mechanism as described in the Stakeholder Engagement Plan/ ESMF • process for resolving conflicts between workers and community members • SEA/ SH and Child protection. 21 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 22 | P a g e