Republic of Uganda Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) 26/10/2020 1|Page 1. The Republic of Uganda is planning to implement the Investment for Industrial Transformation and Employment (the Project), with the involvement of the following Ministries/agencies/units: Ministry of Finance and Economic Development, the Bank of Uganda, Uganda Development Bank and Private Sector Foundation Uganda The International Bank for Reconstruction and Development/International Development Association hereinafter the Bank/the Association has agreed to provide financing for the Project. 2. Ministry of Finance Planning and Economic Development shall ensure that the Private Sector Foundation Uganda and Uganda Development Bank, implements material measures and actions so that the Project is implemented in accordance with the World Bank Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out a summary of the material measures and actions. 3. Where the ESCP refers to specific plans or other documents, whether they have already been prepared or are to be developed, the ESCP requires compliance with all provisions of such plans or other documents. In particular, the ESCP requires compliance with the provisions set out in Environmental and Social Management Framework, UDB’s Environment and Social Management System (ESMS), Stakeholder Engagement Plan (SEP), Labor Management Procedures, and where applicable Resettlement Action Plans, will be developed as part of the project concept. 4. The table below summarizes the material measures and actions that are required as well as the timing of the material measures and actions. Ministry of Finance Planning and Economic Development is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Project Implementation Units in 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 Ministry of Finance Planning and Economic Development 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 Ministry of Finance Planning and Economic Development, 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, Ministry of Finance Planning and Economic Development 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 Ministry of Finance Planning and Economic Development. The Ministry of Finance Planning and Economic Development will promptly disclose the updated ESCP. Depending on the project, the ESCP may also specify the funding necessary for completion of a measure or action. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the Ministry of Finance Planning and Economic Development shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include risks and impacts that are relevant to the Project, such as environmental, health, and safety impacts, labor influx, gender-based violence. 2|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts ESCP Monitoring and Reporting REGULAR REPORTING: Quarterly reports throughout MFPED, PSFU and UDB The Project Implementation Units (PIUs) shall project implementation. prepare and submit regular monitoring reports on the implementation of the ESCP. INCIDENTS AND ACCIDENTS NOTIFICATION: Within 24 hours of occurrence MFPED, PSFU and UDB In case of occurrence of an accident, the PIUs shall of the incident of accident inform the bank within 24 hours of the occurrence of the incident /accident providing sufficient detail and indicating immediate measures taken to address it. SUMMARY ASSESSMENT ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE: Prior to and maintained MFPED, PSFU and UDB The Ministry of Finance Planning and Economic throughout project Development shall constitute a project team that implementation. shall be comprised of the Project Coordinator/ Senior Management representative that shall be accountable for E&S performance. The representative shall be supported by E&S Specialists. In addition, the Project Coordination Unit at the Private Sector Foundation Uganda shall be maintained to provide the overall coordination of 3|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts the project. Additionally, PSFU will also designate at least two E&S specialists that shall be responsible for the day to day E&S performance during project implementation. The Environment and Social Coordinator at Uganda Development Bank (UDB) shall be accountable for E&S performance. UDB will also designate at least two E&S specialists that shall be responsible for the day to day E&S performance during project implementation. This is further addressed under ESS9 section of the ESCP. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT: Ongoing, during MoFPED and UDB UDB: Ensure that project sponsors prepare and implementation disclose all risk assessment and management instruments (ESIA/ESMPs, RAPs, ESA etc.) for factories/ structures/ facilities and other infrastructure financed under component 2 in line with relevant national laws, ESMS and WB ESSs PSFU: (i) Prepare and disclose an Environmental Before disbursement MoFPED and PSFU and Social Management Framework (ESMF) for project activities under components 3 and 4 that 4|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts includes all aspects in Project ESRS including the following: (ii) Prepare an E&S screening tool for grant proposals for component 3 under PSFU (iii) ESMF must adopt UDB’s exclusion list as well as incorporate the following list of additional exclusions under the project: -Activities involving adverse impacts on critical habitats (in line with definitions provided in ESS6) -Activities that would require Free, Prior, and Informed Consent (in line with definitions provided in ESS -Activities in legally protected cultural heritage areas (in line with definitions provided in ESS8) 1.3 PERMIT, CONSENTS AND AUTHORIZATIONS: Prior to project MFPED, PSFU and UDB The PIUs shall obtain or assist subproject owners/ implementation entities, as appropriate, in obtaining, as appropriate, the permits, consents and authorizations that are applicable to the Project from relevant national authorities. The PIUs shall comply or cause to comply, as appropriate, with the conditions established in 5|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts these permits, consents and authorizations throughout Project implementation. 1.4 THIRD PARTY MONITORING: Annually after commencement MFPED, PSFU and UDB An independent individual or firm shall be of project implementation identified to undertake annual Environmental and Social Audits, intended to complement and verify the monitoring of environmental and social risks and impacts of the Project. 1.5 PSFU: Incorporate appropriate environment and Ongoing, during PSFU social clauses in all legal agreements with implementation between UDB and PFIs to ensure that grant recipients adopt and implement the E&S tools, as appropriate, and develop and/ or strengthen their ESMF, as appropriate. 1.6 PSFU: Conduct quarterly monitoring and Ongoing, during PSFU reporting on compliance of grant recipients with implementation environmental and social requirements and provide annual E&S reports to the World Bank. 6|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES: Before disbursement MoFPED and PSFU UDB: Update the existing Human Resources Policy to address identified gaps with ESS2 PSFU: Prepare the Labor Management Plan (LMP) consistent with national legislation and ESS2 that will cover relevant provisions associated with the project components managed by PSFU, as well as refer to UDB’s existing / updated policies and Before disbursement procedures, as appropriate. PSFU: Develop and maintain a grievance redress mechanism (GRM) for direct project workers, including contracted workers as part of the LMP. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: Before disbursement MFPED, PSFU and UDB The project GRM shall be developed as part of the ESMF (PSFU) and ESMS (UDB). 7|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 2.3 OHS MEASURES: Prior to project MFPED, PSFU and UDB implementation The PIUs shall develop and implement Occupational, Health and Safety (OHS) mitigation measures for their staff 2.4 EMERGENCY PREPAREDNESS AND RESPONSE: Prior to project MFPED, PSFU and UDB The PIUs shall prepare an Emergency implementation and Preparedness and Response Plan (EPRP) for their implemented for all project staff, to address potential applicable natural and components man-manmade risks 2.5 PROJECT WORKERS TRAINING: Capacity building Prior to and during project MFPED, PSFU and UDB component shall be included in the ESMS to implementation provide awareness to the PIUs (Project staff) on ESMS. PIUs will also commit to providing training to their clients (further addressed under ESS9 for UDB) ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 UDB: Strengthen resource efficiency and pollution Prior to sub-project MoFPED, PSFU and UDB prevention and management measures in the implementation and ESMS as well as the instruments and tools to be implemented throughout required from the PFIs as per the E&S Integration project life Plan. 8|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts PSFU: Ensure adequate resource efficiency and pollution prevention and management measures in the ESMF. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY: Prior to sub-project MFPED, PSFU and UDB The PIUs will include in the adequate labor force commencement and management, HIV/AIDS, and stakeholder maintained throughout project engagement measures (as appropriate) to ensure implementation that specific community health and safety risks and impacts arising from project activities are effectively managed, as follows: - UDB will make such measure part of the tools prepared under the E&S Integration Plan - PSFU will include such considerations in the ESMF 4.2 GBV AND SEA RISKS: Prior to sub-project MFPED, PSFU and UDB Where necessary, the PIUs shall conduct GBV risk commencement assessment and develop a GBV/ SEA Action Plan to manage the risks of gender-based violence (GBV) and sexual exploitation and abuse (SEA). 9|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 4.3 GBV AND SEA RISKS DURING PROJECT MFPED, PSFU and UDB IMPLEMENTATION: The PIUs shall commit funds to implement Throughout project measures to address GBV and SEA risks, and implementation impacts that may arise during Project implementation. UDB: Strengthen the ESMS provisions to mitigate Before disbursement GBV/SEA risks as appropriate as well as the instruments and tools to be required from the PFIs as per the E&S Integration Plan. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 LAND ACQUISITION AND RESETTLEMENT: Private Sector Foundation Uganda and UDB Before disbursement Before disbursement 10 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts The PIUs shall prepare, where feasible, a Resettlement Policy Framework that shall guide the assessment of the expected land acquisition and involuntary resettlement. UDB: Ensure that project finance sponsors prepare and disclose all relevant instruments (RAPs, ARAPs, etc.) for factories/ structures/ facilities and other infrastructure financed under component 2 in line with relevant national laws and WB ESSs 5.2 RESETTLEMENT PLANS: Prior to initiating activities that Private Sector Foundation Uganda and UDB If the need for the development of a RAP arises, involve involuntary the PIUs will ensure that RAPs consistent with the resettlement requirements of RPF and ESS5 and, relevant to national laws, are prepared and implemented by those entities responsible for undertaking Ongoing during involuntary resettlement activities. implementation UDB: Ensure that project finance sponsors Ongoing during prepare and disclose all relevant instruments implementation (RAPs, ARAPs, etc.) for factories/ structures/ facilities and other infrastructure financed under component 2 in line with relevant national laws and WB ESSs 11 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 5.3 MONITORING AND REPORTING: Throughout project Private Sector Foundation Uganda and UDB The PIUs will develop and implement a implementation monitoring and reporting framework. 5.4 GRIEVANCE MECHANISM: Prior to commencement of Private Sector Foundation Uganda and UDB The PIUs will develop the Grievance Redress Compensation and Mechanism. Resettlement of PAPs. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 12 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 6.1 BIODIVERSITY RISKS AND IMPACTS: Develop and implement measures and actions to assess and manage risks and impacts on biodiversity, including identification of different types of habitat and circumstances in which offsets will be used. UDB: Strengthen measures to protect and Before disbursement conserve biodiversity in the ESMS as well as the instruments and tools to be required from the PFIs as per the E&S Integration Plan PSFU: Ensure adequate measures to protect and conserve biodiversity in the ESMF. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 13 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 7.1 VULNERABLE AND MARGINALIZED GROUPS PRESENT OR COLLECTIVELY ATTACHED TO PROJECT AREA: UDB: Prepare and disclose Vulnerable and Before disbursement UDB Marginalized Groups for factories/ structures/ facilities and other infrastructure that might impact Batwas and Iks and financed under component 2 in line with relevant national laws and WB ESSs. The project will exclude activities that would require FPIC – i.e. that would (i) have adverse impacts on land and natural resources subject to traditional ownership or under customary use or occupation; (ii) cause relocation (or have caused relocation) of IP; or (iii) have significant impacts on IP cultural heritage that is material to their identity 7.2 VULNERABLE AND MARGINALIZED GROUPS: Prior to sub-project UDB UDB shall develop a VMGP where vulnerable implementation people are to be affected consistent with ESS7 14 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 7.3 GRIEVANCE MECHANISM: Prior to sub-project UDB UDB will ensure that the established grievance implementation management committees are accessible to members of the vulnerable and marginalized groups. ESS 8: CULTURAL HERITAGE 15 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 8.1 CHANCE FINDS: Before disbursement UDB, PSFU UDB: Incorporate requirements for chance finds procedures in the ESMS and include these considerations in the PFI’s instruments and tools as appropriate with the support of Ministry of Tourism, Wildlife and Antiquities and the Department of Culture and Family Affairs at the Ministry of Gender Labor and Social Development PSFU: Incorporate requirements for chance finds procedures in the ESMF and include these considerations in the PFI’s instruments and tools as appropriate with the support of Ministry of Tourism, Wildlife and Antiquities and the Department of Culture and Family Affairs at the Ministry of Gender Labor and Social Development ESS 9: FINANCIAL INTERMEDIARIES 16 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 9.1 UDB: ESMS Before disbursement UDB Review and update UDB’s ESMS to reflect all aspects as stated in the Project ESRS including: i. changes in the National Environment Act, 2019; ii. integrate specific policies and procedures for financing extended via financial intermediaries; iii. improved stakeholder engagement provisions in line with WB ESS10; iv. E&S Integration Plan (as described below) v. Other thematic areas as specified in this ESCP under other ESSs. 9.2 UDB: Disclose the full updated ESMS, as well as Before disbursement UDB it’s summary on UDB’s website UDB: Recruit one environmental and one social specialist to UDB’s E&S team 17 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 9.3 UDB: UDB will ensure that, in addition to its Ongoing, during UDB corporate exclusion list already contained in its implementation ESMS, the following activities will be excluded from INVITE financing, both direct from UDB (as relevant) and the PFIs via adequate clauses in UDB’s financing agreements with PFIs: - Activities involving adverse impacts on critical habitats (in line with definitions provided in ESS6) - Activities that would require Free, Prior, and Informed Consent (in line with definitions provided in ESS - Activities in legally protected cultural heritage areas (in line with definitions provided in ESS8) 18 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 9.4 UDB: Prepare an E&S Integration Plan containing Before disbursement UDB specific provisions for incorporating E&S due diligence, monitoring, and reporting under each INVITE project component (such as E&S provisions for the MSME application web-based platform under component 1, ESMS at the PFI level under component 2). The E&S Integration Plan will contain specific time-bound actions and practical steps for integrating E&S risk management into the activities supported by INVITE, including the specific tools to be integrated into the deal flow for each financial transaction type supported under INVITE (e.g. receivables financing). 9.5 UDB: Based on the E&S Integration Plan Before disbursement UDB approved by the World Bank, prepare specific tools for implementation by PFIs to screen and mitigate E&S risks in transactions supported by the World Bank and require application of such tools by PFI in the legal agreements between UDB and PFIs related to WB-supported financing under the project. 19 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 9.5 UDB: Prepare, consult upon, disclose and Before disbursement UDB implement an E&S Capacity Building Plan to include, at a minimum: i. assessment of capacity and resources for E&S management by PFIs (once identified) ii. awareness training on E&S requirements and tools under the project for PFIs) and iii. one-on-one support to PFIs on implementation of the required tools. 9.6 UDB: Incorporate appropriate environment and Ongoing, during UDB social clauses in all legal agreements with implementation between UDB and PFIs to ensure that PFIs adopt and implement the E&S tools (including environmental and social clauses in legal agreements) and specific assessment instruments, as appropriate, as per the E&S Integration Plan and develop and/ or strengthen their ESMS, as appropriate. 20 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 9.7 UDB: Conduct quarterly monitoring and Ongoing, during UDB reporting on compliance of PFIs with implementation environmental and social requirements and provide annual E&S reports to the World Bank. Such reporting will be made possible by mandating that PFIs do routine monitoring of their subprojects, and subsequent reporting to UDB and PSFU to allow for adequate data/information on subprojects. 9.8 UDB/PSFU: Commission an annual audit of the 12 months from the date of UDB, PSFU implementation of E&S requirements under the first disbursement project ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 21 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 Investment for Industrial Transformation and Employment (INVITE) – P171607 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE 7/06/2020 Summary of the Material Measures and Actions to Timeframe Responsibility / Authority and Date of Mitigate the Project’s Potential Environmental and Resources/Funding Committed Completion Social Risks and Impacts 10.1 SEP PREPARATION: Before disbursement MFPED, PSFU and UDB PSFU: Prepare and disclose a Stakeholder Engagement Plan (SEP) cover relevant provisions associated with the project components managed by PSFU, as well as refer to UDB’s existing / updated policies and procedures, as appropriate 10.2 SEP IMPLEMENTATION: Prior to and implemented MFPED, PSFU and UDB The PIUs shall update and disclose the throughout Project life Stakeholder Engagement Plan to confirm roles and responsibilities of responsible Financial Intermediaries. The PIUs shall subsequently implement the SEP. 10.3 PROJECT GRIEVANCE MECHANISM: The project Prior to sub-project MFPED, PSFU and UDB GRM will be developed as part of the relevant implementation and safeguards instruments to be prepared prior to maintained throughout project implementation of the project e.g. the ESIA, life. VMGP, RAP, etc. Capacity Support Specify Training to be provided Specify Targeted Groups and Specify Training Completed Timeframe for Delivery  Training to be provided, as well as targeted groups and timeframes, will be specified as part of the E&S Capacity Building Plan as required by this ESRS 22 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 1.0 - OCTOBER 2018 23 | P a g e