DRAFT ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) For Resilience, Entrepreneurship and Livelihood Improvement Project (RELIP) February 2021 Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Bangladesh (GoB) will implement the Resilience, Entrepreneurship and Livelihood Improvement (RELI) project (Project) through Social Development Foundation (SDF), an autonomous entity under the Financial Institutions Division, Ministry of Finance as the implementing agency (IA). The International Development Association (World Bank) will provide financing to GoB for the Project. 2. GoB will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. GoB will also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as the Environmental and Social Management Framework (ESMF), Environmental and Social Impact Assessment (ESIA), Environmental and Social Management Plans (ESMP), Stakeholder Engagement Plans (SEP), Small Ethnic and Vulnerable Community Development Framework (SEVCDF), Small Ethnic and Vulnerable Community Development Plans (SEVCDP), Labor Management Procedures (LMP), Sexual Exploitation and Abuse, and Sexual Harassment (SEA/SH) Action Plan and the timelines specified in those E&S documents. 4. GoB is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the IA, referenced in paragraph 1 above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the World Bank by GoB (through IA) as required by the ESCP and the conditions of the legal agreement, and the World Bank will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the World Bank and GoB, 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, GoB will agree to the changes with the World Bank 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 World Bank and the GoB. The GoB will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the GoB shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include environmental, social, health, and safety, small ethnic and vulnerable communities, and gender-based violence related impacts. 2|Page Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Prepare and submit to the WB regular monitoring reports on Submit semi-annual reports no later than 15 • SDF the environmental, social, health and safety (ESHS) days after the last day of each period. performance of the Project, including but not limited to the implementation of the ESCP, status of preparation and implementation of E&S documents required under the ESCP, stakeholder engagement activities, functioning of the grievance mechanism(s). B INCIDENTS AND ACCIDENTS Promptly notify the World Bank of any incident or accident Any incident or accident shall be notified to the related to the Project which has, or is likely to have, a Bank immediately after learning of the incident • SDF significant adverse effect on the environment, the affected or accident. Subsequent steps of incident communities, the public or workers, including accidents that response process will follow as per WB’s could result in fatalities, injuries, social inequalities, gender- Environmental and Social Incident Response based violence, etc. If an incident occurs, the Borrower is Toolkit (ESIRT). responsible for reporting it to the Bank, gathering the relevant facts, investigating the incident to fully ascertain the root causes, and for developing and implementing the corrective action plan. Central to the process is to ensure that an adequate investigation is undertaken by the Borrower to determine if project activity caused or contributed to the incident occurring. C QUARTERLY CIVIL CONSTRUCTION PROGRESS REPORTS Prepare and submit quarterly progress reports Within the first two weeks of each quarter • SDF ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY • Recruit the following full-time Technical Specialists Within 3 months from Project effectiveness but • SDF referred in the ESMP either as SDF staff or long-term onboarding no later than 30 days after contract consultant. signing. 1. Social Development Specialist 2. Environmental Specialist 3. Gender & GBV Specialist 4. Stakeholder Engagement & Communication Specialist Within 3 months from Project effectiveness. • SDF • Form an Environmental and Social Cell in SDF headed by a Director/GM level official to look after project E&S risk and impact issues. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT • Prepare, disclose, adopt, update, and implement the Prior to Project appraisal and implemented • SDF Environmental and Social Management Framework throughout implementation (ESMF) • Update/prepare supplementary ESMF and re- Within 90 days from CERC activation • SDF disclose/disclose the updated/supplementary ESMF upon activation of the Contingent Emergency Response Component (CERC), including adding a positive and negative lists of activities/ expenditures at the time of CERC activation, if new activities under CERC are not covered by existing ESMF. • Prepare and disclose ESIAs for the sub- Throughout the project implementation but • Gram Samity, RELI projects/activities, as relevant immediately after identification of each District, Cluster subproject Community Society with support from SDF. 4|Page Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY Management Tools and Instruments • Prepare, disclose, adopt, update and implement the To be done all through the project period after • SDF Environmental and Social Management Plan (ESMPs) site selection during project Implementation/ • Gram Samity, RELI which among other, need to include awareness raising construction/ renovation stage District/Cluster among the targeted households/beneficiaries on Community Society to environmental, and occupational health and safety, for prepare, update and sub-projects/activities, as relevant. disclose site/sub-project specific ESMPs. SDF to train, educate and support them to prepare these ESMPs and monitor their compliances and effectiveness. 1.3 ENVIRONMENTAL STATUTORY CLEARANCE AND APPROVALS • Obtain environmental clearances, licenses/approvals and Prior to commencement of civil works • SDF permits under existing legal framework that are applicable to the Project from relevant national and/or local authorities, as necessary. 1.4 MANAGEMENT OF CONSTRUCTION WORKERS, • SDF INCLUDING THE GRAM SAMITY(ies), RELI DISTRICT/CLUSTER COMMUNITY SOCIETY(IES) • Incorporate the relevant aspects of the ESCP, including Prior to issuance of agreements between the relevant E&S documents and/or plans, and the Labor construction workers and Gram Samity, RELI Management Procedures, into the ESHS specifications of District/Cluster Community Society. the procurement documents, participation agreements, and partnership agreements with Gram Samity, RELI 5|Page Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY District/Cluster Community Societies. Thereafter, ensure • Gram Samity, RELI that they comply with the ESHS specifications of their District, Cluster respective contracts and agreements. Community Society to prepare, update and disclose site/sub-project specific ESMPs containing LMP and ESHS specifications with support from SDF. • ToRs, contracts, and partnership/ participation • SDF During the preparation of site/sub-project • Gram Samity, RELI agreements to include relevant measures in the ESMP. specific ESMPs. District, Cluster Community Society with support from SDF. • Include all relevant E&S provisions in the different • SDF Operational Manuals and other related documents of the Prior to Project’s Effectiveness RELI project, with comments from the Bank. • SDF • Develop and implement Operations and Maintenance • Gram Samity, RELI (O&M) Plan for the proper maintenance of the Following the start of civil constructions, District, Cluster establishments/building in the post-construction period. renovation/refurbishment works but before Community Society to completion of such works. prepare site/sub-project specific O&M plans with support from SDF. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES 6|Page Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY • Prepare, update, adopt, and implement the Labor Prior to project appraisal and maintained • SDF Management Procedures (LMP) throughout Project implementation. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS • Establish, maintain, and operate a grievance mechanism Within 60 days from Project effectiveness and • SDF for Project workers, as described in the LMP and maintained throughout Project implementation. consistent with ESS2 and labor laws of Bangladesh. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES • Prepare, adopt, and implement occupational, health and Prior to start of each sub-project and throughout • SDF safety (OHS) measures specified in the LMP and ESMP. the project duration. • Gram Samity, RELI District, Cluster Community Society with support from SDF. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 CONSTRUCTION MATERIAL SOURCING PLAN: • Prepare, adopt, and implement Construction Material Prior to mobilization of civil work • SDF Sourcing Plan as part of the ESMP for the civil • Gram Samity, RELI District, construction that are acceptable to the World Bank. Cluster Community Society with support from SDF. 3.2 Resource efficiency, Waste Management and Pollution Prevention: Prior to mobilization of civil work, • SDF training and workshops 7|Page Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project • Prepare, adopt and implement Resource Efficiency and • Gram Samity, RELI District and Pollution Prevention and Management Plan in accordance cluster community society with with ESMF. support from SDF. • Prepare, adopt and implement a Waste Management Plan and Site Restoration Plan – as part of the C-ESMP, in accordance with ESMF ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY: • Prepare, adopt, and implement measures and action to assess and manage specific risks and impacts to the Prior to institutional mobilization • SDF community arising from Project activities. This may • Gram Samity, RELI District and include, as relevant any of the following: TORs, Cluster Community Society contracts, and partnership/ participation agreements to with support from SDF. include relevant measures in the ESMP. This may include, as relevant: ESMP for civil work, Occupational Health and Safety Plan, Water and Waste Management Plan, Traffic Management and Road Safety Management Plan, Site Restoration Plan and Community Health and Safety Plan. 4.2 GBV AND SEA/SH RISKS • SDF • Prepare and finalize SEA/SH Action Plan. Prior to project approval • Gram Samity, RELI District and Cluster Community Society with support from SDF. 4.3 • Establish, maintain, and operate a grievance mechanism Within 60 days from Project • SDF specific to GBV/SEA/SH concerns, as elaborated in the effectiveness and maintained • Gram Samity, RELI District and SEA/SH Action Plan. throughout project implementation. Cluster Community Society with support from SDF. 8|Page Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project 4.4 GBV AND SEA RISKS DURING PROJECT IMPLEMENTATION: • SDF • Implement measures as per SEA/SH action plan During project implementation • Gram Samity, RELI District and including the Code of Conduct on SEA/SH for all the Cluster Community Society stakeholders. with support from SDF. 4.5 • Adopt and implement OHS safety protocol in all During project implementation • SDF activities related to COVID-19 pandemic. • Gram Samity, RELI District and Cluster Community Society with support from SDF. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 • Prepare, adopt, disclose and implement the guidelines on Prior the Project appraisal and • SDF “willing buyer willing seller� and “voluntary land implemented throughout project • Gram Samity, RELI District and donations� in the ESMF. implementation Cluster Community Society with support from SDF. ESS6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 • Implement screening criteria for sub-projects having any During sub-project implementation • SDF impacts on ecologically sensitive areas and natural • Gram Samity, RELI District and habitats in accordance with the ESMF Cluster Community Society with support from SDF. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 9|Page Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project 7.1 SMALL ETHNIC AND VULNERABLE COMMUNITY DEVELOPMENT PLAN: • Prepare, disclose, adopt, update, and implement Small Prior to Project appraisal and • SDF Ethnic and Vulnerable Community Development implemented throughout project Framework (SEVCDF) implementation. • Prepare, disclose, adopt, update, and implement Small • SDF Ethnic and Vulnerable Community Development Plan Prior to start of activity that has • Gram Samity, RELI District and (SEVCDP) by carrying out due diligence for inclusion of potential impacts on the small ethnic Cluster Community Society the targeted beneficiaries for each subproject/activity, and other vulnerable communities with support from SDF. where needed. ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS: • Prepare and implement chance finds procedure described Prior to the commencement of civil • SDF in the ESMF and include as a requirement in ESMPs and works • Gram Samity, RELI District and in other work contracts. Cluster Community Society with support from SDF. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Prior to project appraisal and • Prepare, update, adopt, and implement a Stakeholder maintained throughout project • SDF Engagement Plan (SEP). implementation. 10.2PROJECT GRIEVANCE MECHANISM: • Prepare, adopt, maintain and operate a grievance Within 30 days from Project • SDF mechanism, as described in the SEP and ESMF. effectiveness and maintained throughout project implementation CAPACITY SUPPORT (TRAINING) 10 | P a g e Environmental and Social commitment plan Resilience, Entrepreneurship and Livelihood Improvement Project CS1 • Based on E&S Capacity Assessment following types of training will be provided to the relevant target groups, • SDF During Project implementation such as SDF staff, stakeholder community, project • Environmental and Social workers, consultants: Development Specialists • Introduction to World Bank ESF • Labor and working conditions • Community health and safety • Stakeholder Engagement • Indigenous peoples and ESS7, and Social Inclusion • Preparation of ESIA under ESMP • ESF/ESS compliance monitoring and audit • GBV/SEA/SH management and mitigation • OHS and Labor Management audit • Cultural heritage impacts management 11 | P a g e