THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) Democratic Socialist Republic of Sri Lanka Ministry of Highways Road Development Authority Inclusive Connectivity and Development Project ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) June 2021 1|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) Inclusive Connectivity and Development Project ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Sri Lanka will be implementing the Inclusive Connectivity and Development Project (the Project), with the involvement of the Ministry of Highways (MOH). The International Bank for Reconstruction and Development (IBRD) of the World Bank (hereinafter the Bank) has agreed to provide financing for the Project. 2. The Government of Sri Lanka 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 the material measures and actions, any specific documents, or plans, as well as the timing for each of these. 3. The Government of Sri Lanka 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), Resettlement Policy Framework (RPF), Labor Management Procedures (LMP) and Stakeholder Engagement Plans (SEP), and the timelines specified in those E&S documents. 4. The Government of Sri Lanka is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry, 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 Government of Sri Lanka 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 Government of Sri Lanka, 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 Ministry of Highways (MOH) and the Road Development Authority (RDA) 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 MOH and RDA. The MOH and RDA 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 Government of Sri Lanka 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) - Inclusive Connectivity and Development Project (P176164) Inclusive Connectivity Development Project ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN Summary of the Material Measures and Actions to Mitigate the Timeframe Responsible Entity / Project’s Potential Environmental and Social Risks and Impacts Authority/ and Resources/Funding Committed ESCP Monitoring and Reporting REGULAR REPORTING: Prepare & submit to the Bank regular Every three months during project Senior Environmental and Social monitoring reports on the environmental, social, health and safety implementation, within 7 days of the end of Specialists (SESSs) of the Project issues & performance of the Project, including but not limited to the the three-month period. Management Unit (PMU), implementation of the ESCP, status of preparation and Environmental and Social implementation of E&S documents required under the ESCP, Officers (ESSOs), Project stakeholder engagement activities, functioning of the grievance Throughout project implementation Engineers (PEs) from the RDA mechanism(s). and Project Director (PD) of the PMU. Collaborate with other agencies and third parties, such as the contractors, supervision consultants and field level RDA engineers who are responsible for managing specific risks and impacts and implementing mitigation measures to establish such mitigation measures to gather inputs for reporting. 3|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) Ensure that adequate institutional arrangements, systems, resources The RDAs ESD will lead all project preparatory PD of PMU, RDA, MoH and personnel are in place to carry out implementation of due activities as per the ESCP in the interim period . diligence, preparation of E and S instruments and monitoring of E&S and there are two designated SESSs and a team issues in line with all project ESF instruments and the ESCP. Including of Environmental and Social Specialists from the Environmental and Social field officers via secondment of staff from ESD focusing on project preparation. the RDAs Environmental and Social Division (ESD). All key positions indicated in the ESMF should be filled via secondment/hiring within three months of project signing in the Project Management Unit (PMU) within the RDA from the ESF. The E and S Specialists are expected to be part INCIDENTS AND ACCIDENTS NOTIFICATION: Promptly notify the of the PMU Within throughout 24 hours project implementation. of the incident taking place. SESSs, ESSOs, PEs, PD MoH Bank of any incident, including GBV, or accident related to the Project which has, or is likely to have, a significant adverse effect on the Throughout Project implementation environment, the affected communities, the public or workers including, inter alia, any COVID outbreak in the Project area. Provide sufficient detail regarding the incident or accident, indicating Within three days of the incident/accident SESSs, ESSOs, PEs, PD MoH immediate measures taken or that are planned to be taken to taking place address it, and any information provided by any contractor and supervising entity, as appropriate. Throughout Project implementation Prepare a report on the incident or accident and propose any Within 7 days of the incident/accident taking SESSs, ESSOs, PEs, PD MoH measures to prevent its recurrence. place Throughout Project implementation SUPPLIERS/ CONTRACTOR’S MONTHLY REPORTS Ensure that Monthly, within 5 days of the end of the month Suppliers, Contractors and supplier/contractors/ who have signed agreements on carrying out investors with valid signed project works on construction or any consultancy services, submit Throughout Project implementation agreements with the monthly performance reports, including implementation of their MoH/RDA under the respective ESMP, to the PMU. operation, SESSs, ESSOs, PD Submit the contractor’s monthly reports to the Bank, upon request. Upon Request by the World Bank SESSs, ESSOs, PEs, PD MoH Throughout Project implementation SUMMARY ASSESSMENT 4|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE: Prior to the commencement of project Establish an organizational structure with qualified staff to support interventions. PD of PMU, RDA, MOH management of E&S risks of the Project. One (1) Senior Environment Specialist and 1 Senior Social Specialist (SESSs), three Environmental Throughout Project implementation Officers (EO) and three Social Officers (SO), Land Acquisition/R&R Officer, Database/MIS Officer to assist with social management and awareness to be recruited or seconded from respective RDA units at PMU level. One EO and one SO to be recruited or seconded from respective RDA units for each PIU. Environmental and Social Officers/Focal points in the form of Project Engineers working on project sites within the RDA (ESSOs/PEs) need to be identified from within the RDA and assigned key tasks and responsibilities. 1.2 UPDATE AND FINALIZE ALL OVERARCHING ENVIRONMENTAL AND SOCIAL FRAMEWORK DOCUMENTS. The project will prepare, and update when required, an Environmental and Social Management Framework (ESMF), Resettlement Policy The project’s ESMF and all associated Volumes Framework (RPF), Stakeholder Engagement Plan (SEP) and Labor of Annexes and guidance documents, RPF, SEP Management Procedures (LMP) in line with the World Bank’s ESF. and LMP will be updated in line with any These instruments will provide the overarching guidance on the due warranted changes in project scope and diligence process that will need to be carried out in line with the World implementing arrangements and disclosed by SESSs, PMU, RDA, MOH Banks 10 ESSs and National Environmental and Social (E&S) the RDA and all other implementing agencies Regulations of the Government of Sri Lanka. The ESMF and RPF will prior to close of project appraisal. include templates and generic formats to guide E&S screening, present guidance on project design on application of avoidance via design, and on management and monitoring of E and S risks and potential impacts during project implementation, requisite capacity development and implementing arrangements. 5|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) 1.3 SPECIFIC ENVIRONMENTAL AND SOCIAL ASSESSMENTS AND MANAGEMENT PLANS: ESIAs, ESMPs, RAPs and CESGPs acceptable to Carry out Environmental and Social screening as per the ESMF to the World Bank prepared before launching the identify, assess and manage the specific environmental and social risks bidding process for any civil works as Suppliers, Contractors, and and impacts of all the subprojects associated with civil works and appropriate, and thereafter implemented investors with valid signed operation of rural roads, community and agro-logistical infrastructure through the execution of works. Bidding agreements with the MoH/RDA as financed by the Bank. All minimum standards and guidance documents will include provisions for under the operation, SESSs, provided in the ESMF will be ardently followed during project contractors in line with ESMF and specific ESIA, ESOs, PE, PMU, RDA, MOH implementation, in the preparation of ESIAs//RAPs/ESMPs/CESGPs. ESMP or CESGP, RAP prepared for the particular sub-project. Subprojects or project interventions that fall within the negative list presented in Volume 2 of the ESMF will not be eligible for project Within the specified timeframe and throughout financing. Project implementation. 1.3 ENVIRONMENTAL SCREENING AND MANAGEMENT PLANS FOR ALL All 22, E&S Screening Reports and respective FRONT RUNNER SUBPROJECTS. ESMPs/CESGPs prepared before launching the bidding process for the civil works as Suppliers, Contractors, and Carry out Environmental and Social screening as per the ESMF for all appropriate, and thereafter implemented investors with valid signed front runner subprojects, guide the design team as per screening through the execution of works. Bidding agreements with the MoH/RDA findings and prepare required ESMPs/CESGPs for inclusion in the final documents for these subprojects will include under the operation, SESSs, project bidding documents. provisions for contractors in line with ESMF and ESOs, PE, PMU, RDA, MOH specific ESMP or CESGP prepared for the particular sub-project. Prior to close of project appraisal. 1.4 ENVIRONMENTAL AND SOCIAL AUDITS: As per the timeline in the ESMF. Carry out E&S audits as per the timelines and guidance presented in PMU, RDA, MOH, SSESSs the ESMF. Audit reports should be prepared by an independent party Throughout Project implementation and be subject to Clearance by the Bank. 1.5 MANAGEMENT TOOLS AND INSTRUMENTS: Suppliers, Contractors and The following tools will be developed and implemented for each Before the commencement of civil works. investors with valid signed subproject site where civil works will be undertaken as part of the agreements with the MoH/RDA ESMP for projects screened and defined to have Moderate level risks For all construction activities will be preceded under the operation, SESSs, as per the ESMF.: by approved plans ESOs, PE, PMU, RDA, MOH. OHS management plan Site rehabilitation plan 6|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) 1.6 MANAGEMENT OF CONTRACTORS: For All Contracts Management by the PMU/RDA and MOH financed Development of procedures: Prior to project PMU, RDA, MOH, SSESSs via the project signing and commencement of any front Ensure that all suppliers/contractors have the necessary capacity to runner civil works activities. comply with the corresponding ESIAs/ESMPs/CESGPs in accordance with the ESMF and the Project’s Labor Management Procedures Implementation throughout the life of the throughout their contract. This includes ensuring that the project. procurement documents include the necessary technical specifications for the adequate handling of issues contained in the specific ESIAs/ESMPs/CESGPs and Labor Management Procedures. The RDA/MOH will also ensure that: a) All implementing partners to have in place Environment and Social Staff b) Ensure that GBV/SEA/SH codes of conduct are included in service providers tender documents in accordance with national laws and the Bank ESF requirements. 1.7 PERMIT, CONSENTS AND AUTHORIZATIONS: Obtain or assist in obtaining, as appropriate, the permits, consents ESIA/ESMP Clearance from the EPA and World Suppliers, Contractors and and authorizations that are applicable to the Project from relevant Bank Clearance: before the commencement of investors with valid signed national authorities. construction works subject to ESIA. agreements with the MoH/RDA Other permits, consents, and authorizations: under the operation, SESSs, The RDA and MOH shall obtain all relevant environmental and social before commencement of related project ESOs, PE, PMU/PIU, RDA, MOH clearances from relevant Government Authorities such as the CEA, activities. NBRO, CCD, Pradeshiya Sabhas, Local Authorities and or other Implementation and compliance: throughout respective authorizing agencies, prior to the commencement of any the project life construction activities. All construction materials shall be sourced from authorized sites or via Throughout Project implementation licenses vendors. 1.8 TECHNICAL ASSISTANCE: Ensure that terms of reference for studies, capacity building, training Throughout Project implementation. PMU, RDA, MOH, SSESSs and any outputs of technical assistance provided under the Project, are acceptable to the Bank and duly incorporate and take into consideration the requirements of the SESSs. 7|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) 2.1 LABOR MANAGEMENT PROCEDURES: Implement the labor management procedures (LMP) prepared in Throughout the project implementation period PMU, RDA, MOH, SSESSs accordance with the requirements of national law and ESS2, which clearly spells out the (i) terms and conditions of employment; (ii) Throughout Project measures to ensure nondiscrimination and equal opportunity; (iii) implementation. provisions to form workers’ organizations; and (iv) prevention of child and forced labor 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: The project will establish and operationalize a Grievance Mechanism Before start of civil works PMU, RDA, MOH, SESSs for workers as per the Labor Laws of the Government of Sri Lanka and as stipulated in the LMP. Applicable throughout project implementation 2.3 OHS MEASURES: Prepare and implement appropriate occupational health and safety Before commencement of civil works. Suppliers, Contractors, and measures (OHS), including emergency preparedness and response investors with valid signed measures, as part of the development and implementation process of agreements with the MoH/RDA the corresponding ESMPs/CESGPs, in accordance with the guidelines Applicable throughout project implementation under the operation, SESSs, contained in the ESMF and the Labor Management Procedures and the ESOs, PE, PMU, RDA, MOH project specific Generic OHS plan presented in the ESMF. 2.4 EMERGENCY PREPAREDNESS AND RESPONSE: Prepare and implement appropriate Emergency Preparedness and Prior to initiating civil works. Maintained Suppliers, Contractors and Response (EPR), as part of the development and implementation throughout Project implementation. investors with valid signed process of the corresponding ESMPs, CESGPs in accordance with the agreements with the MoH/RDA guidelines contained in the ESMF and the Labor Management Applicable throughout project implementation under the operation, SESSs, Procedures ESOs, PE, PMU, RDA, MOH The emergence Preparedness and Response will include: a) engineering controls (such as containment, automatic alarms, and shut-off systems) commensurate with the nature and scale of the hazard. b) identification of and secure access to emergency equipment available on-site and nearby. c) notification procedures for designated emergency responders. d) Training program for emergency responders including drills at regular intervals. e) Public evacuation procedures f) Designated coordinator for ERP implementation 8|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) g) Measures for restoration and clean-up of the environment following any accidents h) Documentation of emergency preparedness and response activities, resources, and responsibilities. 2.5 PROJECT WORKERS TRAINING: Suppliers, Contractors and Training will be provided to workers in hygiene, health and safety, Prior to commencement of construction works, investors with valid signed communicable and sexual transmitted diseases, Gender based with regular and ongoing site training sessions. agreements with the MoH/RDA violence/ sexual exploitation and abuse and sexual harassment under the operation, SESSs, (GBV/SEA/SH) in all project construction sites. Throughout Project implementation ESOs, PE, PMU, RDA, MOH 2.6 WORKER’S CODE OF CONDUCT: Suppliers, Contractors and A Code of Conduct (CoC) will be prepared, and all project workers will Prior to commencement of construction works, investors with valid signed be required to sign the CoC prior to the start of their with regular and ongoing site training sessions. agreements with the MoH/RDA activity/involvement with the project. An awareness training on the under the operation, SESSs, content of the CoC will also be organized ESOs, PE, PMU, RDA, MOH ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 MANAGEMENT OF WASTE AND HAZARDOUS MATERIALS: Measures to effectively manage wastes and hazardous materials will PMU/PIU, RDA, MOH, SSESSs be identified and included as part of the specific ESIAs/ESMPs/CESGPs Throughout project implementation. to be prepared under action 1.2, managed as per the minimum standards stipulated in the project ESMF. 3.2 Resource Efficiency: Feasible measures (financial and technical) for Throughout project implementation. improving efficiency in consumption of energy and water, as well as PMU/PIU, RDA, MOH, SSESSs other resources and material inputs will be identified through the specific ESIAs, ESMPs and CESGPs to be prepared under action 1.2. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Appropriate measures will be identified, and plans prepared to Throughout project implementation PMU/PIU, RDA, MOH, SSESSs ensure road safety and minimize traffic accidents as well as in the design of the road subprojects. These will be part of the site specific ESMPs/ESIAs/CESGPs 4.2 COMMUNITY HEALTH AND SAFETY: The site specific ESMPs/ESIAs/CESGPs will incorporate appropriate Throughout project implementation PMU, RDA, MOH, SSESSs measures to effectively mitigate potential risks and impacts of the project to the community and ecosystems. 9|Page THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) 4.3 GBV AND SEA/SH RISKS: The site specific ESMPs/ESIAs/CESGPs will assess the risks of gender- Throughout project implementation PMU, RDA, MOH, SSESSs based violence (GBV) and sexual exploitation and abuse (SEA) sexual Harassment (SH) and incorporate appropriate measures to manage these risks applied as per the LMP, SEP and ESMF prepared for the project. The plans will also include awareness raising sessions to educate workers and local communities on GBV/SEA/SH issues. 4.4 GBV AND SEA/SH RISKS DURING PROJECT IMPLEMENTATION: Throughout Project implementation. Part 4.3 aimed at addressing GBV/SEA/SH issues under this Project, PMU, RDA, MOH, SSESSs which will support gender sensitive consultations, preparation, and adherence to the CoCs and awareness raising activities and trainings. 4.5 EMERGENCY RESPONSE MEASURES: PMU, RDA, MOH, SSESSs Emergency response measures will be carried out in line with the Prior to commencement of construction and plan and processes laid out in action 2.4 maintain during the project timeline ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT ACTION PLAN: Within 3 months period once the engineering Where required, prepare site-specific RAPs in accordance with the design is finalized PMU, RDA, MOH, SSESSs RPF, submit to the World Bank for clearance, translate into local languages and disclose the draft. Submit the updated RAPs for World Prior to commencement of civil works Bank review and clearance, translate the updated RAPs into local languages and redisclose (see below for re-disclosure requirements) Applicable throughout project implementation 5.2 Translate the updated RAPs into local languages and disclose in the Within 1 month once the instrument is cleared official website of the Ministry of Roads and Highways, project site by the World Bank PMU, RDA, MOH, SSESSs office, and other relevant public domain accessible to project affected parties and other stakeholders. Applicable throughout project implementation 5.3 COMMUNITY ENGAGEMENT: Extend the existing process throughout the Engage all project affected parties in continuous consultations and project period PMU, RDA, MOH, SSESSs disclose relevant information in decision-making processes related to their resettlement and relocation, livelihood restoration, and Applicable throughout project implementation monitoring and evaluation. 5.4 COMPENSATION AND BENEFITS FOR AFFECTED PERSONS: Prior to possession of site Monitor RAP implementation to ensure that all project affected PMU, RDA, MOH, SESSs parties are paid compensation at replacement cost and provided with Applicable throughout project implementation any other assistance to help them improve or at least restore their standards of living or livelihoods. 10 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) 5.5 Strengthen the livelihood restoration program implemented for Prior to possession of site displaced persons with continuous support, training, linkages to PMU, RDA, MOH, SESSs resource institutions and monitoring and ensure that displaced Applicable throughout project implementation persons have restored and improved their livelihood activities. 5.6 GRIEVANCE REDRESS MECHANISM: Prior to possession of site (see under ESS10) PMU, RDA, MOH, SESSs As part of the RPF as stipulated establish a grievance redressal Applicable throughout project implementation mechanism for potentially affected people as a result of land acquisition. ESS 6 BIODIVERSITY RISKS AND IMPACTS: 6.1 Measures to effectively screen, identify and manage risks and Prior to commencement of each sub-project impacts on biodiversity will be identified and included as part of the and maintained during construction PMU, RDA, MOH, SESSs specific E&S Screening procedures presented in the ESMF, avoidance measures are to be applied via respective designed where possible Applicable throughout project implementation and all ESIAs/ESMPs/CESGPs to be prepared under action 1.2 will include measures in line with the management of risks and impacts to biodiversity presented in the ESMF. As defined in the projects Negative List in Volume 2 of the ESMF, no Subprojects can be undertaken within designated Protected Areas as per National Regulations. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 Carry out site-specific environmental and social screening as per the Prior to commencement of each sub-project PMU, RDA, MOH, SESS ESMF to determine the presence of IP/SSAHUTLC. If relevant, develop an IP/SSAHUTLC Plan as per the requirements under ESS 7 ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS: The ESMPs/ESIAs/CESGPs to be prepared (action 1.2) will incorporate Prior to commencement of each sub-project PMU, RDA, MOH, SESSs chance find procedures in case valuable artefacts or culturally and maintained during construction valuable materials are found during project implementation. 8.2 CULTURAL HERITAGE: Measures to effectively screen, identify and manage risks and Prior to commencement of each sub-project PMU, RDA, MOH, SESSs impacts to tangible and intangible cultural heritage will be identified and maintained during construction and included as part of the specific E&S Screening procedures presented in the ESMF, avoidance measures are to be applied via Applicable throughout project implementation respective designed where possible and all ESIAs/ESMPs/CESGPs to 11 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) be prepared under action 1.2 will include measures in line with the management of risks and impacts to cultural heritage presented in the ESMF. ESS 9: FINANCIAL INTERMEDIARIES 9.1 This standard is not relevant to the Project. Not applicable ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN (SEP) PREPARATION AND IMPLEMENTATION: Develop and implement a Stakeholder Engagement Plan (SEP), to SEP Will be implemented throughout Project PMU, RDA, MOH, SESSs ensure engagement with the project-affected communities and other implementation. stakeholders throughout Project implementation. Within the specified timeframe throughout . As committed in the SEP, annual reports of stakeholder engagement Project implementation activities undertaken by the project will be prepared and disclosed publicly through the website of the Ministry. The SEP will be reviewed during mid-term and revised if necessary. 10.2 Implement the SEP and engage with identified stakeholders (project Continuous through project implementation PMU, RDA, MOH, SESSs affected parties, other interested parties, and vulnerable groups) in meaningful manner throughout the project life cycle. Conducted continues consultations in a culturally appropriate manner, and provide with timely, relevant, understandable, and accessible information to all stakeholders. 10.3 Maintain and disclose records of stakeholder engagement, including Continuous through project implementation PMU, RDA, MOH, SESSs a description of the stakeholders consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account, or the reasons why it was not. 10.4 Submit bi-annual report to the Bank on SEP implementation Every six month, within 15 days of the end of PMU, RDA, MOH, SESSs the six-month period Throughout Project implementation 10.5 PROJECT GRIEVANCE MECHANISM: The grievance mechanism will be established Establish, maintain, and operate a grievance mechanism to ensure prior to commencement of the Project PMU, RDA, MOH, SESSs reception and timely response to any complaints made about the activities. For contract specific GRMs a month Project (including those from members of the communities, local prior to Contractors Mobilization and will be businesses, and other stakeholders), as described in the SEP. maintained and operated throughout Project 12 | P a g e THE WORLD BANK ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) - Inclusive Connectivity and Development Project (P176164) implementation. 10.6 Appoint a focal point (e.g. contractor’s office) closer to the Prior to mobilization of contractors in construction sites to oversee the GRM (receive, register, and respond individual project sites. to public grievances, complaints, and feedback). PMU, RDA, MOH, SESSs Within the specified timeframe, throughout Project implementation. 10.7 Monitor the grievances registered to ensure that all grievances As per the service standards of GRC reported including those outstanding are resolved and that decision- mechanism. making processes demonstrate transparency, accountability, and PMU, RDA, MOH, SESSs efficiency and that grievance redress processes are conducted in a culturally appropriate manner. 11. CAPACITY SUPPORT 11.1 Provide training to environmental and social staff on (i) Within 1.5 month of project effectiveness and PMU, RDA, MOH, SESSs, The environmental and social standards and management procedures as repeated as needed. World Bank per ESF; (ii) preparation of environmental and social management documents and screening processes (iii) environmental and social Throughout Project Implementation risks and impacts monitoring; and (iv) record-keeping, documentation and reporting, including on the GRM. Specifies in line with training programs are presented in the Capacity Building Plan in the projects ESMF. 11.2 Provide training to contractors and project workers on (i) At contract mobilization and repeated during PMU, RDA, MOH, SESSs occupational health and safety (OHS); (ii) labor management project implementation as needed. procedures (LMP); (iii) emergency prevention and preparedness and response arrangements to emergency situations; and (iv) prevention Throughout Project Implementation of gender-based violence and sexual exploitation and abuse, sexual harassment and the associated CoCs (v) Chance find procedures for archaeological assets 13 | P a g e