THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Recovery and Advancement of Informal Sector Employment (RAISE) (P174085) DRAFT ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) Aug 2020 Government of Bangladesh 1|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Bangladesh (GoB) (the Recipient) will implement the Recovery and Advancement of Informal Sector Employment Project (the Project), with the involvement of Palli Karma-Sahayak Foundation (PKSF) and Wage Earner Welfare Board (WEWB) of Ministry of Expatriates’ Welfare and Overseas Employment (MEWOE). The International Development Association, IDA (the Bank) has agreed to provide financing for the Project. 2. The Recipient will implement material measures and actions so that the Project is implemented in accordance with the National Law and ESS. 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. The Recipient will 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, for WEWB), Labor Management Plan (LMP), and Stakeholder Engagement Plan (SEP), Environmental and Social Management System (ESMS, for PKSF)and the timelines specified in those E&S documents. 4. The Recipient is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Implementing Agencies (PKSF and WEWB of MEWOE) referenced in 1 above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Bank by the Recipient as required by the ESCP and the conditions of the legal agreement, and the Bank will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank and the Recipient, 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, the Recipient will agree to the changes with the 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 Bank and the Recipient. The Recipient 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 Recipient shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. 2|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Submit Half yearly (every six months) PKSF and WEWB of MEWOE Prepare and submit to the Bank, regular monitoring reports on reports in an agreed format throughout (Implementing Agency, IAs) environmental, social, health and safety (ESHS) performance of Project implementation. The report will the Project, including but not limited to the implementation of the be submitted by July 31 and January 31 ESCP, status of preparation and implementation of E&S for the period ending June 30 and documents required under the ESCP, stakeholder engagement December 31 respectively. activities, functioning of the grievance mechanism(s). Setup and manage a web-based platform to track the project’s Web-based Platform will be setup progress based on the results framework. within 30 May 2021 (Given effectiveness is on 31 March 2021) Carryout Impact Evaluation by mid and end term. Submit Impact Evaluation Report within 30 days of completion of evaluation Deploy Independent Verification Consultants (IVCs) for monitoring and verifying project outputs and carryout Deploy IVCs within 30 May 2021 (Given independent environmental, social, health and safety audit to effectiveness is on 31 March 2021) propose corrective measures. B INCIDENTS AND ACCIDENTS Notify the Bank within 24 hours of IAs (PMUs) Notify the Bank of any incident or accident related to the Project learning of the accidents or incidents. which has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers Provide a report on action taken on the including accidents that could result in fatalities, injuries, cases of same by 07 (Seven) days of notifying GBV/SEA, serious mismanagement in handling waste, security the Bank. breach, etc, provide sufficient details regarding the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and supervising entity, as appropriate. Subsequently, as per the Bank’s request, prepare a report on the 3|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) incident or accident and propose any measures to prevent its recurrence. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Appointment of all specialists (1 ES, IAs (PMUs) 1SDS, 1 SES) will be completed within PKSF to recruit an Environmental Specialist (ES) – responsible 15 May 2021 (Given effectiveness is for addressing environmental risks/impacts, environment related on 31 March 2021) The specialists will occupational health and safety issues as well as waste provide inputs as necessary throughout management issues and a Social Development Specialist (SDS) the Project implementation. Until the – responsible for addressing risks associated with social issues recruitment, the IA’s existing staff will (labor, gender, OHS), and for monitoring and ensuring support the project’s E&S application of COVID-19 protocol of Ministry of Health and Family Welfare (MoHFW) and World Health Organization (WHO) management. with qualifications, experience and under terms of reference satisfactory to the Bank. Specialists may be taken from existing Environment and Climate Change Unit of PKSF or inducted in that unit as part of the project. WEWB, MEWOE to recruit a Social and Environmental Specialist (SES) – responsible for addressing risks associated with social issues (labor, gender, OHS) and environmental issues 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT ESMS updated and approved by PKSF PKSF Management and WEWB’s PKSF’s ESMS was reviewed and recommendations made under senior management prior fund PMU ESS9 of ESCP. Update ESMS as per recommendations. WEWB to transaction. prepare an Environmental and Social Management Frameworks (ESMF) detailing policy, procedure and guidance for WEWB ESMF disclosed before Project assessment and management of environmental and social risks appraisal and impacts. During detailed design stage of each Prepare and disclose E&S assessment and screening for sub- sub-project projects as soon as they are known. 1.3 ELIGIBILITY CRITERIA FOR SUBPROJECT Exclusion list is a part of ESMS PKSF PMU Implement the exclusion list (which is a part of PKSF ESMS) that will be used as a guiding tool for funding interventions which will not adversely impact the environment and the people. Conduct 4|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) screening to exclude those in the exclusion list and keep the documentation during the project implementation. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT: Implement the Project in a manner LMP disclosed before appraisal and IAs (Social Specialists of PMUs) acceptable to the Bank, including through, inter alia, measures will be implemented implementing adequate occupational health and safety measures throughout Project implementation. (including emergency preparedness and response measures), ensuring appropriate working condition amidst a public health emergency (including measures against outbreak of COVID-19); provision of training/apprenticeship on handling emergency situation especially health related issues; and setting out grievance arrangements for Project workers, and incorporating labor requirements in the procurement documents and contracts with contractors and supervising firms. The Recipient will prohibit child labor (any person under the age of 18), forced labor and trafficked persons. Prepare a Labor Management Procedures (LMP) for implementation throughout the Project. 2.2 GRIEVANCE REDRESS MECHANISM (GRM) FOR PROJECT GRM for the workers will be established IAs (GRCs) WORKERS before commencement of Project Establish, maintain, and operate a GRM for the Project which will activities and it will remain operational include issues of Project workers, as described in the LMP throughout Project implementation. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Before beginning of project activities IAs (PMUs) Prepare, adopt, and implement occupational, health and safety and maintained throughout Project (OHS) measures specified in LMP, especially measures related to implementation mitigating COVID-19 risks. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND The operation manual approved prior PKSF (PMU) MANAGEMENT: fund transaction 5|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) PKSF ESMS (refer 1.2 above) includes an exclusion list of interventions/ businesses that could potentially create significant pollution adversely affecting the environment. In addition the operation manual specifies that any sub-projects with substantial and high ES risks will be ineligible. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 Put measures in place to prevent or minimize the spread of the ESMS (PKSF), ESMF (WEWB) and SEP IAs (ES Specialists of PMUs) infectious diseases/COVID-19 to the community and among have been prepared and community workers/beneficiaries by following national and WHO guidelines health and safety issues described of social distancing and other measures. therein will be adopted and followed throughout Project implementation Ensure the avoidance of all forms of Gender Based Violence (including all required updates to the (GBV)/Sexual Exploitation and Abuse (SEA) by establishing documents). WEWB ESMF and SEP will written Codes of Conduct for all workers in the project area as well be disclosed before Appraisal, PKSF as train and sensitize them on this issue. Prepare SEP and adopt ESMS prior fund transaction and implement a Project Grievance Redress Mechanism (GRM) under SEP as well as a labor related GRM under LMP. Project GRM will also manage the risks of GBV and SEA. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 No Land acquisition and resettlement necessary for the Project Not Relevant Not Relevant ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: ESMS (including exclusion List) PKSF (Environment Specialists of PMUs) ESMS (Refer 1.2 above) includes an exclusion list so that potential disclosed prior fund transaction business/ microenterprise that may adversely affect biodiversity and living natural resources are not funded. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 INDIGENOUS PEOPLES PLAN: Not Relevant Not Relevant The Project is unlikely affect any small ethnic minority meeting the requirement of ESS7 ESS 8: CULTURAL HERITAGE 8.1 ESMS (refer 1.2 above) includes an exclusion list that will not fund ESMS (including exclusion List) PKSF PMU any potential business/ microenterprise that may adversely affect disclosed prior fund transaction any cultural heritage 6|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) ESS 9: FINANCIAL INTERMEDIARIES 9.1 Existing PKSF’s ESMS will be updated and address the following IA will ensure ESMS is updated, PKSF PMU, POs and the Bank issues: approved and disclosed prior fund transaction. Agreement between PKSF (i) Develop a ES policy statement to assess and manage ES risks and and POs (to ensure PKSF’s ESMS is impacts endorsed by the senior management; (ii) Enhance the legally binding for POs) to be made capacity of the Environmental and Climate Change unit by within 15 days of identification and recruiting additional Environmental and Social specialists (which selection of POs or fund transaction, may include gender/GBV specialist, climate change specialist, whichever is earlier. waste management specialist, biodiversity specialist, labor law expert, occupational health and safety specialist, stakeholder engagement specialist, field researchers); (iii) Develop training policy and training plan for staffs on E&S issues and develop a complete training manual/ curriculum including audio visual presentations; (iv) Clear description of relevant national laws and their adoption in the ESMS; (v) Align the risk categorization system of existing ESMS for both environmental and social risks with national/ ESF risks rating (four instead of three); (vi) Detail description of reporting requirement, channel and frequency of reporting and person responsible; (vii) Develop a beneficiary screening mechanism and format including women, people with disability and the vulnerable; (viii) Develop OHS measure as per Good International Industry Practices and employment of child between 14 to 18; (ix) Develop measures to address formation of labor/workers/employee organizations (x) Develop a guidance for legal agreement structure between the PKSF and its POs/ participating FIs, legally binding POs to adopt the ESMS. Ensure that each PFIs/POs have a staff dedicated to oversee its ES activities, monitor and report on the same. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 7|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND SEP prepared and disclosed prior to IAs (Social Specialists of PMUs) IMPLEMENTATION Project appraisal and adopted, Prepare, update, adopt, and implement Stakeholder updated and implemented throughout Engagement Plan (SEP) the Project implementation period. Within30 April 2021 (Given PROJECT GRIEVANCE MECHANISM: effectiveness is on 31 March 2021) and Prepare, adopt, maintain and operate a grievance mechanism, as updated from time to time as needed described in the SEPs and maintained throughout project implementation. CAPACITY DEVELOPMENT SUPPORT (TRAINING) Specify Training to be provided Targeted Groups and Timeframe Training Completed The IAs, (with support of third-party resources if needed (independent experts, NGOs, etc)) will design and implement training for targeted groups involved in the Project to improve their awareness of risks and mitigate the impacts. This ESCP proposes a preliminary training plan covering the following topics. This plan will be adapted to meet needs during Project implementation. ESF. Training on ESF and the 10 ESSs—including preparation of ESMP Personnel directly related with project Within 30 April 2021 (Given at the IAs effectiveness is on 31 March 2021) Issues Related to COVID-19 Officials of IAs, Trainers, Beneficiaries, Within 30 April 2021 (Given • Use and disposal of PPE (for all) Welfare Officers effectiveness is on 31 March 2021) • Working/training in COVID-19 environment (All workers and and if needed quarterly thereafter beneficiaries) • COVID-19 Infection Prevention and Control mechanism • Standard precautions for COVID-19 (social distancing etc) • Risk communication, prevention and community engagement (Administrative and operational personnel) • WHO and CDC guidelines on quarantine Occupational Health and Safety Module: Officials of IAs, Trainers and Within 30 April 2021 (Given • Workplace risk management Beneficiaries, Welfare Officers effectiveness is on 31 March 2021) • Prevention of accidents at work sites and continue half yearly throughout • Health and safety rules the project • Preparedness and response to emergency situations 8|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Labor and Working Conditions IAs Local officials, POs, Workshops/ Within 30 April 2021 (Given • Terms and conditions of employment according to national working Microenterprises, Welfare Officers effectiveness is on 31 March 2021) laws and regulations • Codes of Conduct • Worker’s organizations • Child labor and minimum age employment rules Grievance Redress Mechanism Module, design and production of a ES, SDS, HS, IAs’ Officials, POs, Welfare Within 30 April 2021 (Given training module addressing the following aspects: Officers effectiveness is on 31 March 2021) • Registration and processing procedure and thereafter once every twelve • Grievance redress procedure months • Documenting and processing grievances • Use of the procedure by different stakeholders GBV Risk Module IAs Local officials, Trainers, Within 30 April 2021 (Given Raising awareness and measures to prevent and mitigate GBV/SEAH Beneficiaries effectiveness is on 31 March 2021) risks. The topics and activities will be developed and included in the and thereafter once every twelve Project GRM. months 9|Page