PRESIDENCE ---------- Programme de Réformes pour l’Efficacité de l’Administration (PREA) ---------- Coordination Générale (CG) ---------- ________________________ Republic of Madagascar Madagascar Digital Governance and Identity Management Project – P169413 ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) Draft for Negotiations August, 2020 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Madagascar (the Recipient) will implement the PRODIGY Project (the Project), with the involvement of the following Ministries/agencies/units: the Program for Reform of the Efficiency of the Administration (PREA), the Ministry of Interior and Decentralization and the Ministry of Telecommunication. The International Development Association (hereafter the Association) 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 World Bank Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out 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 the Stakeholder Engagement Plans (SEP), the Electrical and Electronic Waste Management Plan (EEWMP), the Labor Management Procedures (LMP), and the grievance mechanisms (GM) for the workers and the project, 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 Ministry, agency or unit referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Association by the Recipient as required by the ESCP and the conditions of the legal agreement, and the Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Association and the Recipient through the head of COS-PREA, 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 Association and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the Association and the 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, which may include: - risks linked to the mobilization of consultants, civil servants and other entrepreneurs by the project: moral, sexual harassment and intimidation among employees; GBV, sexual abuse, abuse of power; - the risks associated with the introduction of digital governance: risk on the confidentiality of personal data collected, public incomprehension in the face of the proliferation of these new management tools, digital divide between the various segments of society: rural and urban areas , and between populations with access to the Internet and those who do not, between citizens, especially vulnerable groups; - Risks associated with the acquisition of IT equipment: end-of-life IT equipment, management of empty ink cartridges, risk on the physical component: soil pollution - water contamination - air pollution; biological component: fauna and flora; human health 2|Page 8. The table below presents the important measures and actions required, the responsibilities of the actors involved in the Project, and the deadlines for implementing the selected measures and actions. 3|Page P169413 – PRODIGY - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – August 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING: Prepare and submit to the Association regular monitoring reports on the Bi-annual report after Project effectiveness Responsible Entity: Project state of compliance with the actions set out in the ESCP and, particularly, date and maintained throughout Project Implementation Unit (PIU) of PRODIGY in relation to the implementation of (i) Electrical and Electronic Waste implementation Responsible: PIU Coordinator in Management Plan (EEWMP), (ii) environmental, social, health and safety collaboration with Environmental and (ESHS) performance of the Project, (iii) status of preparation and Social Specialist of the PIU implementation of SEP, (iv) implementation of LMP (v), functioning of the grievance mechanism(s), (vi) implementation of the GBV action plan. B INCIDENTS AND ACCIDENTS: Promptly notify the Association of any incident or accident related to the Notify the Association within 48 hours after Responsible Entity: PIU Project which has, or is likely to have, a significant adverse effect on the learning of the incident or accident Responsible: PIU Coordinator environment, the affected communities, the public or workers including without limitation any allegations of gender-based violence and/or Any incident report should be sent sexual exploitation, abuse and harassment (GBV/SEAH). Project-related promptly, within a timeframe acceptable occupational accidents or fatalities, or labor strikes and social unrest. and agreed upon with the Association, as requested. Provide enough detail 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 while ensuring confidentiality especially for GBV/SEAH related incidents. Subsequently, as per the Association’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. C CONTRACTORS MONTHLY REPORTS: Contractor monthly reports submitted to Responsible Entity: PIU In case contractors and sub-contractors are hired for the Project the Association upon request. Responsible: PIU Coordinator in activities or sub-activities, the PIU will require such contactors/sub- contractors to submit monthly monitoring reports to the PIU regarding collaboration with Environmental and OHS performance of the contracted work. Such monthly Social Specialist of the PIU monitoring reports would be submitted to the Association by the Recipient upon request. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 4|Page P169413 – PRODIGY - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – August 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 1.1. ORGANIZATIONAL STRUCTURE The PIU is already in place. Responsible Entity: PIU Establish and maintain an organizational structure, the PIU, with The PIU has already hired an Environmental Responsible: PIU Coordinator qualified staff and resources to support management of E&S risks & Social Specialist. including an Environmental &Social Safeguard Specialist and a Gender & The gender and communication specialist Communication Specialist, both with qualifications and experience will be in place 2 months after Project acceptable to the Association. effectiveness. The organizational structure, including the specialists, will be maintained throughout Project implementation. 1.2. ENVIRONMENTAL AND SOCIAL ASSESSMENT NOT RELEVANT AT THIS TIME 1.3. MANAGEMENT TOOLS AND INSTRUMENTS Develop, update, adopt, and implement the Environmental and Social SEP, LMP and EEWMP have been submitted Responsible Entity: PIU risk management tools, including but not limited to the following: to the Association and approved prior to o the SEP, Project appraisal, and disclosed both on the Responsible: PIU Coordinator / o the Communication plan, PREA and PRODIGY websites on June 16, and Environment & Social Specialist / Gender o the LMP, on World Bank website on June 17, 2020. and communication specialist o the Project Grievance Mechanism, o the GBV Action Plan, The GRM is already included in the LMP o the GBV Grievance Mechanism, and the SEP. o and the EEWMP The GBV action plan will be submitted to As and when needed, a screening for specific risks will be carried out, the Association for approval no later than and the Recipient will prepare, consult upon, adopt, disclose, and 60 days after Project effectiveness. implement the environmental and social documents required for the Project, in a manner acceptable to the Association and in line with the Any update of SEP and LMP, final ESSs. communication plan, EEWMP, GRM to be submitted to the Association for approval prior to implementation. Once approved, the instruments are maintained and implemented throughout Project implementation. 5|Page P169413 – PRODIGY - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – August 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 1.4 MANAGEMENT OF CONTRACTORS Prior to the preparation of procurement Responsibility: PIU Environment & Social In case contractors and sub-contractors are hired for the Project documents. Specialist activities or sub-activities, the PIU will incorporate the relevant aspects Accountability: PIU Coordinator of the ESCP, including the relevant environment and social documents Supervise contractors throughout Project and/or plans, such as the ESMP and the Labor Management implementation. Procedures, into the occupational health and safety (OHS) specifications of the procurement documents with contractors. Thereafter, the PIU will ensure that the contractors comply with the OHS specifications of their respective contracts. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES (i) The LMP (which include Code of conduct) has been prepared, (i) The LMP was adopted and published in Responsible Entity: PIU approved by the Association and disclosed both in-country and in the the PREA and PRODIGY websites on June 16, Association web site prior to Project appraisal. Thereafter, update, 2020 and on World Bank website on June 17, Responsible: Financial and Administrative adopt, and Implement the Labor Management Procedures (LMP) that 2020. Officer in collaboration with the have been developed for the Project, in line with ESS2. Environmental and Social Specialist of the Any update of LMP should be submitted for PIU approval to the Association prior to implementation. Approved LMP will be maintained and implemented throughout Project implementation (ii) Codes of Conduct including clauses and sanctions against the use of (ii) Prior to engaging Project workers and GBV/SEAH will be required for all contractors and subcontractors and contractors and maintained throughout their workers. All staff will be required to attend information and Project implementation. awareness sessions on GBV/SEAH throughout Project implementation. Induction sessions will be organized for temporary workers before they start work. 6|Page P169413 – PRODIGY - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – August 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY GRIEVANCE MECHANISM FOR PROJECT WORKERS Grievance mechanism operational prior to Responsible Entity: PIU 2.2 Establish, maintain, and operate a grievance mechanism (GM) for Project engaging Project workers and maintained Responsible: Environmental and social workers, as described in the LMP and consistent with ESS2. This will throughout Project implementation Specialist of the PIU in collaboration with include reporting and allegation procedures regarding GBV/SEAH and an Gender and Communication Specialist of accountability framework and response to complaints. the PIU ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT E-WASTE MANAGEMENT PLAN: Electrical and Electronic Waste EEWMP has been submitted to the Responsible Entity: PIU 3.1 Management Plan (EEWMP) that includes measures for the rational use Association and approved prior to Project Responsible: Environmental and Social of resources and pollution prevention and management of electronic and appraisal and disclosed both on the PREA Specialist of the PIU electric waste produced by the obsolete equipment has been prepared and PRODIGY websites on June 16, and on and approved by the Association prior to Project appraisal. Update, World Bank website on June 17, 2020. adopt, and implement EEWMP in accordance with ESS 3. Any update of EEWMP should be submitted The Project will take appropriate mitigation measures to minimize the for approval to the Association prior to impact of the Project on the environment and the natural resources, in Project implementation. accordance with ESS 3, in compliance with the EEWMP approved by the Association Once approved, maintained and implemented throughout Project implementation RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND Same timeframe as for the EEWMP. Responsible Entity: PIU 3.2 MANAGEMENT: Resource efficiency and pollution prevention and Responsible: Environmental and social management measures have been covered under the EEWMP prepared Maintained and implemented throughout Specialist of the PIU under action 3.1. above. Project implementation ESS 4: COMMUNITY HEALTH AND SAFETY 7|Page P169413 – PRODIGY - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – August 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 4.1. GBV AND SEA RISKS: The Recipient will prepare, adopt and implement a The GBV Action Plan, and GBV GM will be Responsible Entity: PIU Coordinator/ standalone GBV Action Plan to assess and manage the risks of gender- prepared by the Recipient and submitted for Gender specialist based violence (GBV) and sexual exploitation and abuse (SEA). the approval of the Association prior to being finalized, and no later than 60 days after The GBV Action Plan includes mitigating measures such as the signing of Project effectiveness. a code of conduct for all Project staff (including the PIU, contractors and workers). This code of conduct, along with clauses on workers’ Once approved, the GBV Action Plan and conditions and management, child protection, and GBV prevention, will GBV GM are implemented throughout be included into all bidding documents and all worker’s contracts. Project implementation, and will be updated, as needed, throughout Project Establish and ensure that an accessible and accountable GM related to implementation. GBV (GBV GM) is operationalized for the Project, to ensure that any GBV incident related to workers and communities will be addressed in an effective manner with sufficient social sensibility. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT NOT RELEVANT AT THIS TIME ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES NOT RELEVANT AT THIS TIME ESS 7: INDIGENOUS Peoples/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES NOT RELEVANT AT THIS TIME ESS 8: CULTURAL HERITAGE NOT RELEVANT AT THIS TIME ESS 9: FINANCIAL INTERMEDIAIRIES NOT RELEVANT AT THIS TIME ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 8|Page P169413 – PRODIGY - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – August 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 10.1. STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND The SEP was adopted and published both in Responsible Entity: PIU IMPLEMENTATION the PREA and PRODIGY websites on June 16, Responsible: Environmental and social A draft Stakeholder Engagement Plan (SEP) have been prepared and 2020 and on World Bank website on June 17, Specialist of the PIU approved by the Association before Project appraisal. 2020. The SEP will be implemented following Update, adopt, and implement Stakeholder Engagement Plan (SEP). Project effectiveness and throughout Project implementation. Ensure that SEP is incorporated into the Project’s management system, SEP to be updated periodically, as required, and adequate staffing and budget is allocated to implementing the SEP throughout Project implementation. in accordance with ESS10. Any update of SEP should be submitted for approval to the Association prior to implementation. 10.2. PROJECT GRIEVANCE MECHANISM: GM has been be submitted for prior GM submitted prior to Project appraisal. Responsible Entity: PIU review and approved by the Association as part of the SEP prior to Responsible: Environmental and social Project appraisal. GM to be updated periodically, as required, Specialist of the PIU throughout Project implementation. Any Update, adopt, maintain and operate a GM, as described in the SEP. update of GM should be submitted for approval to the Association prior to implementation. Once operational, monitored throughout Project implementation. CAPACITY SUPPORT (TRAINING) 9|Page P169413 – PRODIGY - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 3.0 – August 2020 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY CS1 The PIU will need training in the following areas: Prior to commencement of Project activities (i) development and implementation of the Stakeholder Engagement and throughout Project implementation. Responsible Entity: PIU Plan (SEP) and in its monitoring & evaluation, Responsible: PIU Coordinator (ii) the development and implementation of the Labor Management Procedures (iii) first aid courses to employees/contractors and communities interested (iv) GBV, including SEAH, mitigation, prevention and response measures and the development and implementation of a GBV measures. (v) Inclusive Project implementation to ensure non-discrimination of socially vulnerable populations such poor, illiterate people, sexual and gender minorities…. (vi) Capacity building in other specific aspects of assessment and implementation of environmental and social risk management practices as identified through needs assessments of key Project actors during Project preparation and implementation. (vii) Training within GBV action plan (viii) Training to the Recipient and awareness raising on GBV among all contractors, workers including civil servants involved in the Project 10 | P a g e