Government of Lebanon The World Bank Lebanon Emergency Crisis and COVID19 Response Social Safety Net Project STAKEHOLDER ENGAGEMENT PLAN (SEP) DRAFT June 2020 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft ABBREVIATIONS AND ACRONYMS CBO Community Based Organization CDC Community Development Center CMU Central Management Unit CSO Civil Society Organization ESCP Environmental and Social Commitment Plan ESF Environmental and Social Framework ESS Environmental and Social Standards EU European Union GOL Government of Lebanon GRM Grievance Redress Mechanism HBS Household Budget Survey IGO International Organization IMC Inter-Ministerial Committee IPF Investment Project Financing MEHE Ministry of Education and Higher Education MoPH Ministry of Public Health MoSA Ministry of Social Affairs NGO Non-Governmental Organization NPTP National Poverty Targeting Program OIP Other Interested Party PAP Project-Affected Parties PCM Presidency of the Council of Ministers PDM Post Distribution Monitoring PMT Proxy-Means Testing PMU Project Management Unit SDC Social Development Center SEP Stakeholder Engagement Plan SIA Social Impact Assessment SSN Social Safety Net WFP World Food Program 2 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Table of Contents 1 – Introduction/Project Description ...................................................................................... 4 1.1 – Stakeholder Engagement Plan ...........................................................................................4 1.2 – Project Overview and Description......................................................................................5 2 – Brief Summary of Previous Stakeholder Engagement Activities ......................................... 9 3 – Stakeholder Identification and Analysis ............................................................................ 9 3.1 – Identified Stakeholders and Affected Parties .....................................................................9 Table 1: Distribution of Households by Region ..........................................................................................10 Figure 2: Distribution of the Poorest 100,000 NPTP Households by Region ...........................................11 Figure 3: Distribution of Households by District .......................................................................................12 Table 2: Demographic characteristics of beneficiary households .............................................................14 3.2 – Other Interested Parties ................................................................................................... 15 Table 3: Other interested parties .................................................................................................................15 3.3 – Disadvantaged/Vulnerable Groups .................................................................................. 17 3.4 – Summary of Project Stakeholder Needs ........................................................................... 18 Table 4: Summary of Project Stakeholder Needs ......................................................................................19 4 – Stakeholder Engagement Program ......................................................................... 23 4.1 – Purpose and Timing of Stakeholder Engagement Program .............................................. 23 Table 5: Purpose and Timing of Stakeholder Engagement Program .......................................................24 4.2 Proposed Strategy for Information Disclosure .................................................................... 28 Table 6: Summary of Notification Plan throughout Project Cycle ...........................................................29 4.3 Proposed Strategy for Consultation .................................................................................... 30 4.4– Proposed Strategy to Incorporate the View of Vulnerable Groups .................................... 31 4.5 – Timelines ......................................................................................................................... 31 4.6 – Review of Comments........................................................................................................ 31 4.7 – Future Phases of Project .................................................................................................. 31 5 – Resources and Responsibilities for Implementing Stakeholder Engagement Activities ..... 32 6 – Grievance Mechanism .................................................................................................... 32 7 – Monitoring and Reporting .............................................................................................. 33 7.1 – Involvement of Stakeholders in Monitoring Activities...................................................... 33 7.2 – Reporting Back to Stakeholder Groups ........................................................................... 34 References........................................................................................................................... 35 Appendix 1 .......................................................................................................................... 36 3 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft 1 – Introduction/Project Description Lebanon is currently in a high-risk situation as it faces a combination of a balance of payments crisis, coupled with an economic and banking sector crisis, a 10-year humanitarian situation caused by an unprecedented influx of refugees, and most recently having to deal with the impact of the COVID19 pandemic. The situation in the country is further compounded by the outbreak of the COVID-19 pandemic and subsequent lockdown measures In response to the multiple crises, the GOL is launching the Emergency Crisis and COVID-19-Response Social Safety Net Program (ESSN), a multi-year $300 million program aimed at: (i) arresting the increase in extreme poverty; (ii) preserving human capital of children at risk of dropping out of schooling; and (iii) building resilience and peaceful coexistence between vulnerable Lebanese households and Syrian refugees. The ESSN will build upon successes of the NPTP and learn from challenges of the past 10 years by introducing new features and improvements to ensure a sustainable national social safety net system. 1.1 – Stakeholder Engagement Plan The Stakeholder Engagement Plan (SEP) lays out the strategies to be applied by the Government of Lebanon (GoL) as part of the 2016 World Bank’s Environmental and Social safeguard requirements. The SEP is recognized under the World Bank’s Environmental and Social Standard (ESS) 10: Stakeholder Engagement and Information Disclosure. According to ESS10: “Stakeholder engagement is an inclusive process conducted throughout the project life cycle. In consultation with the Bank, the Borrower will develop and implement a SEP proportionate to the nature and scale of the project and its potential risks and impacts. The Borrower will seek the views of stakeholders on the SEP, including on the identification of stakeholders and the proposals for future engagement. If significant changes are made to the SEP, the Borrower will disclose the updated SEP.� Therefore, the SEP shall remain a living document. This document seeks to define a technically and socially appropriate approach to consultation and information disclosure. The objective of the SEP is to raise awareness in relation to the proposed emergency crisis-response Social Safety Net (SSN) program, hereinafter the “Program� or the “Project�, to identify stakeholders, and to ensure that the stakeholders are provided sufficient opportunity to voice their opinions and concerns which are addressed in a timely manner. The objectives of the SEP are outlined as follows: • Understand stakeholder engagement requirements for the Project and identify key stakeholders that are affected, and/or able to influence the Project and its activities; • Outline the stakeholders’ consultation process and communication activities throughout the duration of the Project; • Identify the most effective methods, timing and structure through which to share Project information, and to ensure regular, accessible, transparent and appropriate consultation that meet standards of international best practice; 4 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft • Develop a stakeholders’ engagement process that provides external stakeholders with an opportunity to voice their opinions and concerns in a timely manner and take part in the decision-making process in accordance with and to the extent foreseen by the applicable laws & regulations; • Identify resources needed for stakeholder engagement activities and define roles and responsibilities for the implementation of the SEP; • Establish formal grievance redress mechanisms (GRMs); • Define reporting and monitoring measures to ensure the effectiveness of the SEP and define periodical reviews of the SEP. For the purpose of this SEP, “stakeholder� refers to individuals or groups who: i) are affected or likely to be affected by the Project (project-affected parties or PAPs); and ii) may have an interest in the project (other interested parties or OIPs). This preliminary SEP draft has been prepared and disclosed before appraisal. Inclusive stakeholder engagement could not be conducted due to the urgency of the project and COVID19 restrictions. However, the Government of Lebanon (GoL) will update the SEP during project implementation following inclusive stakeholder consultations within a timeframe agreed with the Bank. 1.2 – Project Overview and Description Lebanon is faced with an unprecedented economic crisis that has been further escalating since the recent COVID-19 pandemic outbreak. The shortage of dollars and the sharply accelerated average inflation since the beginning of 2020 have already led to de facto depreciation of the Lebanese pound and uncontrolled rises in prices, and are also likely going to exacerbate the economic situation by putting massive pressure on consumer prices, particularly given the country’s heavy reliance on imports. As a consequence, unemployment and poverty are rising fast, inflicting unbearable pain on the Lebanese population. In addition, a sharp decline in remittances and disruptions in global supply chains resulting from the pandemic are expected to exacerbate Lebanon’s food security vulnerabilities and place additional pressure on the economy. Already prior to the current crisis, poverty was on the rise with overall poverty increasing from 25.6 percent in 2012 to 37 percent in 2019, and extreme poverty increasing from 10 percent in 2012 to 16.2 percent in 2019, according to the World Bank. The Syrian crisis alone has increased overall poverty 7 percentage points between 2012 and 2017 through direct and indirect impacts that the mass refugee influx has put on public infrastructure and public finance. In response to the worsening living conditions for a large number of Lebanese citizens, a popular uprising erupted in October 2019 where large demonstrations demanded better standards of living and equal opportunities for all. More than 220,000 jobs had been temporarily or permanently lost between October 2019 and February 2020,1 even before the lockdown measures that the government had imposed and which are expected to further compound the economic situation. World Bank staff calculations estimate that a contraction of the Lebanese GDP per capita by 8.3 percent in real terms in 2020-2111 could result in more than a doubling of extreme (food) poverty to 22 percent, and an increase in 1 http://www.businessnews.com.lb/cms/Story/StoryDetails/7423/220,000-jobs-lost-estimated-by-InfoPro 5 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft overall poverty to 45 percent in 2020. This translates into approximately 1.7 million people (350,000 households) falling under the poverty line, of which 841,000 people (156,000 households) fall under the food poverty line. The Government of Lebanon (GoL) recognizes the urgent need to backstop the country’s current economic crisis which, if unmitigated, can lead to even higher levels of poverty and inequality, and can reverse hard- won gains in human capital investments in the country. The government hopes to create favorable conditions for a rebound by restoring social trust among citizens. As such, through much-needed structural reforms and extensive social safety nets, the GoL aims to protect the poorest segments of the population and reduce inequalities. In partnership with the World Bank and other donors including EU and Germany, the GoL has subsequently agreed to put in place an emergency and immediate Criris-Response SSN program, a multi-year $300 million program that will build upon the success of the existing National Poverty Targeting Program (NPTP). The objective of the project is to assist the poor and vulnerable population severely affected by the protracted economic and COVID-19 crisis in Lebanon.The ESSN will learn from challenges of the past, introduce new features and improvements to the NPTP, and ensure the provision of a sustainable SSN system and overall social protection. The proposed scale up will be conducted in a phased manner, beginning with verified beneficiaries from the NPTP database in Phase 1 (immediately), followed by fresh intake of new verified beneficiaries from the IMPACT database in Phase 2 and the larger set of NPTP applicants. The IMPACT database is an electronic platform launched by the Ministry of Interior and Municipalities (MOIM) in collaboration with the MOSA, the Central Inspection Office, and the PCM, to collect households applications interested in receiving social assistance. While in its infancy and pending assessment, the IMPACT platform could have the potential of becoming the basis of a “National Social Registry�. The current NPTP Central Management Unit (CMU) at the Presidency of the Council of Ministers (PCM), which was established in November 2008, will act as the Project Management Unit (PMU) in the first phase of the ESSN Project. The CMU is responsible for implementation of the program, including managing several key functions related to the targeting database, such as the validation of the data coming from MOSA’s SDCs, managing the M&E functions, financial and technical audit, and manage the fiduciary aspects of the project through the Fiduciary Operations Team (FOT). The NPTP unit at MOSA will simultaneously carry out the verification of beneficiaries through social workers, deliver social care services through SDCs, and implement and manage a robust GRM system. Finally, MEHE will be responsible for providing attendance and academic performance data of students supported by top-up cash transfers. The ESSN Project forms a core part of the GoL’s stimulus package and its Economic Reform Program, and aims to assist the poor and vulnerable population severely affected by the protracted economic and COVID19 crisis through four main components: Component 1. Provision of Cash Transfer for Basic Income Support (US$220 million). The objective of Component 1 is to help arrest the increase in extreme poverty by providing cash transfer to 140,000 Lebanese households, scaling up from the current 15,000 households who receive an e-card food voucher. The scale- up would result in an enhanced coverage of Lebanon’s targeted SSN from 1.5 percent to around 20 percent of the Lebanese national population. 6 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Component 2. Provision of Cash Transfer for Students-at-Risk (US$30 million). The objective of Component 2 is to preserve the human capital of poor households by supporting the retention of students who are at risk of dropping out of school due to socio-economic reasons. The component will provide a top-up cash transfer to eligible 140,000 poor and vulnerable Lebanese households with an estimate of 87,000 students between the ages of 13 and 18 years currently enrolled in school. The targeted students constitute 67 percent of the total number of children ages 13 to 18 years enrolled in public schools.2 The purpose of the cash transfer is to support continued investments in children’s schooling and reduce the extent of dropout and discontinuation of schooling that may be induced by the economic and financial crisis. The support received through this component will relief the families from the burden of bearing the education expenditure, and especially address the pressures that boys in the age group from poor families face viz. secondary school enrollment and completion. Component 3: Provision of Social Care Services for Vulnerable Lebanese and Syrian Refugees ($40 million). The objective of Component 3 is to (i) strengthen the capacity and systems of the Ministry of Social Affairs (MOSA) and the Social Development Centers (SDCs), and (ii) increase access to quality social services, for the vulnerable and disadvantaged Lebanese and non-Lebanese households. The Ministry of Social Affairs (MOSA) mandate is to provide social protection and assistance, and part of this is done by building resilience through social service provision, playing an integrated development role across humanitarian, development, private sector and government agencies. The scope of Component 3 will include (i) rapid needs assessments of priority social services among Lebanese and non-Lebanese households, (ii) capacity development of MoSA and the SDCs to (a) define and develop the package of (basic and specialized) social services to be provided to beneficiary groups; and (b) procure, manage and monitor service provision based on minimum service standards, and (iii) finance the provision of social services through SDCs and contracted service providers (details of the implementation plans will be outlined in the GoL project operations manual). Component 4: Enhanced Social Safety Nets Program Delivery (US$10 million). The objective of this component is to ensure an efficient and effective implementation of the ESSN program and lay the foundations for a sustainable SSN delivery, including the building blocks of a National Social Registry. To achieve this objective, the component will support the financing of: a. Development of a robust Grievance Redress Mechanism, and Communication and Outreach b. Monitoring and Evaluation (M&E), Verification System, External Technical Audit c. Building blocks of a National Social Registry and National Payment System d. Project Management and Implementation Support The scale-up components identified above address the current NPTP’s limited coverage characteristic and provide a reliable social safety net that effectively protects the most vulnerable segments of the population, in line with the GoL’s objectives. Furthermore, in order to conduct a solid identification of potential beneficiaries, the ESSN project will adopt a hybrid targeting methodology, combining Proxy 2 According to MEHE, the total number of children ages 13 to 18 years is 128,656 students enrolled in public schools. 7 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Means Test (PMT) to identify extreme poor households, and categorical targeting to prioritize socially vulnerable groups within the group of extreme poor households. Figure 1: Geographic Distribution of Social Development Centers In fact, the PMT mechanism has been administered to all 140,000 applicant households in the current NPTP database ever since the Program was launched in 2011. Of those, a large number of poor households currently do not receive benefits: in the NPTP, only around 15,000 households benefit from the e-card vouchers and around 43,000 households benefit from health and education services, representing no more than 2% and 5% of all Lebanese households respectively. As the cash transfer program will support extreme poor households severely affected by the economic and COVID-19 crises, beneficiaries will be selected from existing applicants in the existing NPTP database and from extreme poor households in the GoL IMPACT database. The PMT will be administered afresh to households in the NPTP that are not currently receiving cash benefits and to applicants from the IMPACT database alike. Both groups of potential beneficiaries will be subjected to the same PMT test, method of verification and eligibility cut-off. The socially vulnerable categories to be considered for targeting include: (i) households headed by women, (ii) households with any member aged 70 or above, (iii) households with any member that has a severe disability, and (iv) households with children (ages 0 – 17). Households will need to meet both criteria (PMT score below threshold and inclusion among the defined categories) to receive benefits. 8 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Source: NPTP Central Management Unit at the PCM, 2020 2 – Brief Summary of Previous Stakeholder Engagement Activities While no consultations with Project beneficiaries have taken place to date, previous stakeholder engagement activities that targeted beneficiaries from the NPTP program turned successful. These included several public hearing events and workshops that were held across different geographic regions in 2015 and in 2019 after the recertification of NPTP beneficiaries. Given the urgency of the project and COVID-19 constraints, limited stakeholder engagement was conducted during project preparation. However, the GoL will update the SEP during project implementation following inclusive stakeholder consultations with all stakeholders identified in this SEP, including project affected parties, other interested parties and disadvantaged / vulnerable groups. These consultations will take place within the timeframe proposed below and in line with the provisions of the Environmental and Social Commitment Plan (ESCP). 3 – Stakeholder Identification and Analysis This section of the SEP identifies the PAPs, the OIPs, and other disadvantaged or vulnerable group. The project-affected parties include those likely to be affected by the Project because of actual impacts or potential risks to their physical environment, health, security, or well-beings. OIPs include individuals, groups, or organizations with an interest in the Project, which may be because of the Project location, its characteristics, its impacts, or matters related to public interest. The disadvantaged or vulnerable are defined as individuals or groups who may be disproportionately impacted by the Project, who may have been unfairly excluded from the Project, or who may have limitations in participating and/or understanding project information due to lack of understanding of a consultation process or a lack of means to access Project information. The following stakeholders will be informed and consulted about the project accordingly. 3.1 – Identified Stakeholders and Affected Parties Within the scope of this Project, the main categories for PAPs are identified as follows: • Beneficiaries of basic income support through cash transfers: The Emergency SSN Project’s first component will scale up the NPTP from its current coverage of 15,000 households to 140,000 households... The scale-up would result in an enhanced coverage of Lebanon’s targeted SSN from 1.5 percent to around 20 percent of the Lebanese national population. Simulations conducted by the WB using nowcasted HBS 2011/12 data show that the scale up will reduce the extent of extreme poverty from 21.8 percent in the post-crisis simulation for 2020 to 12.9 percent, reflecting 8.9-percentage points decrease in the extreme poverty rate 9 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft The proposed scale up will be conducted in a phased manner, beginning with verified beneficiaries from the NPTP database in Phase 1 (immediately), followed by fresh intake of new verified beneficiaries from the IMPACT database in Phase 2 and the larger set of NPTP applicants. As the NPTP already has around 43,000 households with scores corresponding to extreme poverty levels, these eligible beneficiaries will be verified and then included in the immediate (Phase 1) expansion of the program, subject to belonging to the agreed categories. In parallel, the IMPACT database will be analyzed to isolate potential beneficiaries using: (i) eligible categories defined earlier, and (ii) asset filters to exclude visibly richer households (filters could include vehicle and home ownership, public sector employment, insurance coverage). In Phase 2, after applying asset filters and eligible categories on the IMPACT database, the pool of potential beneficiaries from IMPACT, as well as applicants in the NPTP beyond the initial 43,000 (Phase 1) beneficiaries will be verified. Those found eligible using the hybrid targeting methodology will begin receiving benefits. In order to understand this stakeholder group and identify any special needs that they may have with respect to their engagement in the Project, a geographic and demographic analysis of the 43,000 households with scores corresponding to extreme poverty levels in the NPTP database is provided below. The sample population is comprised of 42,931 households, or 237,936 individuals. The data finds that the sample population is scattered across the country (table 1 and figure 2) and has diverse demographic characteristics (table 2), and therefore distinct information disclosure and communication needs (table 4). Table 1: Distribution of Households by Region Region/Governorate Number of Households Percentage of total Beirut 190 0.45 Mount Lebanon 6,893 16.05 North Lebanon 17,776 41.4 Bekaa 12,700 29.6 South Lebanon 3,428 8.00 Nabatiyeh 1,944 4.5 Total 42,931 100 Source: NPTP Database 2020 10 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Figure 2: Distribution of the Poorest 100,000 NPTP Households by Region 11 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Furthermore, within each of the governorates represented, households are scattered over districts. Figures 3 and 4 lay out the distribution of those households by district from the total sample population and from households within each region, respectively. Figure 3: Distribution of Households by District 25% 23% Figure 2: Distribution of 42,931 beneficiary households by district 20% 15.06% 15% 9.93% 7.74% 10% 6.28% 5.30% 5.03% 4.67% 4.22% 3.64% 3.02% 2.33% 1.73% 1.60% 1.41% 5% 1.16% 0.71% 0.70% 0.49% 0.44% 0.35% 0.32% 0.30% 0.25% 0.16% 0.12% 0% Akkar Tyre Metn Bsharri Baalbek Zahle Bent Jbeil West Bekaa Rachaya Koura Keserwan Aley Saida Zgharta Beirut Byblos Batroun Tripoli Hasbaya Baabda Jezzine Minyeh Donieh Nabatiyeh Hermel Chouf Marjeyoun Percentage of total beneficiary households Source: NPTP Database 2020 12 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Figure 4: Distribution of Households by Region and District Figure 3: Distribution of beneficiary households in regional districts Rachaya Byblos Batroun Jezzine 3.90% 1.90% Bshari 0.40% Koura Keserwan 0.60% Zgharta0.80% 1.50% Metn 2% Hasbaya West Bekaa 4.30% 10.90% 3.40% 10.20% Minyeh Donieh Chouf 15.20% 14.50% Marjeyoun Hermel 15.60% Tyre 17% 45.60% Tripoli Aley 24% Zahle 29.10% 17.90% Bent Jbeil 35.40% Beirut 100% Akkar Saida Baalbek Baabda 55.60% 52.90% 50.90% 48.20% Nabatiyeh 38.10% Beirut Bekaa Mount Lebanon Nabatiyeh North Lebanon South Lebanon Source: NPTP Database 2020 While it is normal for some districts to have a larger number of poor and vulnerable households given the contrasting patterns of poverty in the country, the figures highlight underrepresentation among households in some regions (both on the governorate and district levels). As such, those groups may need additional action with respect to stakeholder engagement activities moving forward. For instance, according to the HBS 2011/12 survey, Mount Lebanon has the largest share of extreme poor Lebanese households3 of 31.8% yet only 19% of households in the NPTP database are from the governorate.4 With respect to demographic indicators, table 2 depicts the structure of this stakeholder group. 3 At the 10% extreme poverty line. New extreme poverty line in 2020 is 22%. 4 During NPTP, only 16% of beneficiaries were from Mount Lebanon, 13 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Table 2: Demographic characteristics of beneficiary households Region Number of Number of Percentage Number of Number of Number of beneficiary beneficiarie of female- HH HH HH HH s headed members members members households above the below the below the age of 64 age of 18 age of 5 Beirut 190 1,142 27.89 57 503 96 Bekaa 12,700 62,664 19.09 3,713 27,296 6,489 Mount Lebanon 6,893 31,700 27.25 2,676 12,179 2,182 Nabatiyeh 1,944 9,907 21.3 716 4,080 721 North Lebanon 17,776 115,270 12.45 3,244 57,664 11,796 South Lebanon 3,428 17,253 22.32 1,024 7,012 1,248 Total 42,931 237,936 18.05 11,430 108,734 22,532 Source: NPTP Database 2020 In addition to these households, the Project will be supporting beneficiaries who meet the eligibility criteria from the IMPACT database. It is expected that following the first phase of the Project, where 43,000 extreme poor households from the NPTP database will be identified, verified, and receive first disbursement, 90,000 extreme poor households from IMPACT and other households from NPTP (beyond the original 43,000) will receive support during the second phase. The GoL has received around 467,000 applications to the IMPACT database, of which 112,876 households belong to the following categories: (i) female-headed households (18-64) with at least 1 child (0-18) and no civil servants; (ii) at least a member with disability and no civil servants; (iii) Families with no adults (all members are above 64 and/or below 18) and no civil servants; (iv) Any child under 18 with high dependency ratio (above 0.66) and no civil servants; (v) more than 4 children under 18 and no civil servants. • Students aged 13-18 in households under component 1 enrolled in public schools: Component 2 will provide a top-up cash transfer to eligible 140,000 poor and vulnerable Lebanese households with an estimate of 87,000 students between the ages of 13 and 18 years currently enrolled in school. The targeted students constitute 67 percent of the total number of children ages 13 to 18 years enrolled in public schools. • New applicants: The identification of eligible new beneficiaries using computed PMT scores will take place in phase 2 of the Project. An identification of those beneficiaries will be provided throughout implementation and in future updates of this SEP. 14 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft • Social Workers: A successful implementation of the SSN Project and all its components would require building capacity of all staff involved in the project, and particularly the social workers at MoSA. As the social workers benefit from trainings on case management, GRM, Gender Based Violence or Sexual Exploitation and Abuse and Sexual Harassment (SEA/SH), and communication under the Project’s component 4, they will be directly affected. The size of this stakeholder group is estimated at around 462 individuals. • Syrian Refugees: Component 3 of the Project involves Syrian refugees who will benefit from social services provided through Community Development Centers (operated by NGOs) and/or MoSA’s SDCs. The final number of refugees who will benefit from this program has not been determined. 3.2 – Other Interested Parties Other parties interested in the Project are identified as individuals, groups, or organizations who may not be directly affected by the Project but who can help play a role in identifying potential risks, impacts, and opportunities for the Borrower to consider and address in the assessment process and throughout project preparation. The following OIPs have been identified as stakeholders in the Project: Table 3: Other interested parties Category Institution Interest Government agencies CMU at the Presidency of the Overseeing the implementation of the Council of Ministers Project, acting as the Project’s Management Unit (PMU) of the ESSN. The CMU will be responsible for the implementation of the Project, including managing several key functions related to the targeting database (verification, new intakes, cross-checking, data validation) and managing the GRM system and other M&E activities. Ministry of Social Affairs MoSA Responsible for delivery of the social care services and linkages with the households receiving the cash transfers via its SDCs and/or community centers/NGOs; assign GRM focal point who will be in charge of overlooking the 15 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft GRMs at the local level in SDCs and coordinate with both the GRM firm and the CMU. Ministry of Education and Higher Implementing and monitoring Education MEHE component 2, coordinating with CMU on operations, responsible for providing attendance data of the students supported by top-up cash grants; assign GRM focal point who will be in charge of overlooking the GRMs at the local level in schools and coordinate with both the GRM firm and the CMU. The schools are expected to be the first avenue to receive grievances. However, there will be 87,000 beneficiary students. This will require a robust roll- out program including training for principals and teachers to manage grievances. International World Food Program Implementing cash-based assistance of organizations, donors, components 1 and 2, and monitoring investors matters related to food security European Union Donor – providing grants Germany Donor – providing grants UNICEF Implementing component 2 and monitoring for children. NGOs (MoSA will hire NGOs to Implementing component 3 and support SDCs) monitoring for refugees. Implementing entities Contracted schools Collecting school registration fees, enrolling children in schools. Monitor enrollment, attendance, and attainment. Banks and financial Provide assistance to beneficiaries in intermediaries cash and coordinate with the GOL on policy guidelines. Communication and outreach Designing and implementing a firm comprehensive communication strategy for the Program 16 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Monitoring and evaluation firm Monitor and evaluate components 1, 2, 3, 4. GRM firm Assigning a GRM manager; assigning a GRM coordinator; developing a logging protocol and MIS program, setting up a GRM operational manual, establishing an automated tracking system, developing FAQs, ensuring timely response system, collection of information, monitoring, providing multiple channels to report SEA/SH that include anonymous reporting and referral to GBV support services Verification/new intake firm Conducting verification, recertification, and accepting new applications for beneficiaries. External auditing firm Perform auditing activities and reporting to stakeholders NGO Partners MoSA’s NGO partners, namely: May have in-depth knowledge about the Anera, Oxfam, Save the Children environmental and social characteristics International, Secours Islamique of the beneficiaries in some areas and France, Caritas Lebanon, Caritas the nearby populations. They can play a Swtitzerland, Action Contre la role in identifying risks, potential Faim ACF, Relief International, impacts, and opportunities to be Mercy Corps addressed Other potential contracted NGOs Interaction with the public through involved in social support community development centers services that will contribute to (CDCs) component 3 of the Project Press and Media All communication channels Inform the public about project identified in section 4 of this SEP implementation and planned activities including TVs, radios, and GRM newspapers 3.3 – Disadvantaged/Vulnerable Groups While the Proxy-Means Testing (PMT) formula used for targeting of the NPTP has strong analytic foundations, possible measurement errors during initial intake, changes in households’ composition and the economic conditions between the Household Budget Survey (HBS)’s date (2011-12) and the time of scale- up, and inflation could have potentially led to a certain extent of exclusion errors. 17 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Based on a screening for the Project and discussions with key stakeholders, the disadvantaged/vulnerable groups identified in the Emergency Social Safety Net Program are: • Elderly and disabled groups who may have additional needs for care and support and who may not be captured by the existing PMT formula. The PMT eligibility cut-off score for such households can be increased to allow some intake from non-extreme poor households that belong to these categories • Small-sized families that are typically excluded under the current PMT mechanism which determines households’ eligibility for assistance; • Extreme poor Lebanese households who may not be able to afford some necessary paperwork required for the application; • Extreme poor Lebanese households who come from certain regions in which contrasting patterns of poverty exist, leading to the lack of appropriate communication. • Syrian refugees: The influx of Syrian refugees in Lebanon since 2011 led to one of the world’s highest concentration of refugees in any country, themselves affected by high poverty. The total population of Lebanon increased by more than 38 percent between 2010 and 2019, rising from 4.9 million to 6.6 million. As of early 2020, 16.5 percent (914,648) of the registered Syrian refugee population are in Lebanon. The socio-economic situation of Syrian refugees has been deteriorating over the years with close to three-fourth of the population falling below the poverty line (less than USD$4 per day per person) and over 50 percent below the extreme poverty line (less than USD$3 per person per day), as per data collected in April 2019 for the annual UNHCR, UNICEF and WFP Vulnerability Assessment of Syrian Refugees (VaSyR). While female-headed households do not seem to be disadvantaged by the current PMT system, and while more than half of the project beneficiaries are female, the current system does not take into account social pressure on females heading households just above the extreme poverty line, especially when a member of those household or the spouse is deceased or incarcerated. Additional “filters� may need to be integrated in order to ensure that the engagement process is inclusive. Throughout the Project’s preparation and implementation, the Project’s central management unit (CMU) at the PCM will coordinate with the stakeholders and make efforts to provide all means necessary to best engage the disadvantaged or vulnerable groups identified in this document through proper communication means and additional selection filters. 3.4 – Summary of Project Stakeholder Needs Table 4 below summarizes the stakeholder categories identified in this SEP and reviews the preferred means of communication with these stakeholders and the frequency of engagement. 18 Table 4: Summary of Project Stakeholder Needs Stakeholder group Key characteristics Preferred notification means Language needs Specific needs (accessibility, large print, daytime meetings) Affected Parties Beneficiaries of Group includes the targeted Normal notification channels include: Official language As needed per household. basic income extreme poor beneficiaries SDCs (in person), schools (for education (Arabic) support through from the existing NPTP component), mass and social media, call Some individuals from this group: cash transfers database and the IMPACT centers, website, emails (generated by - May not know how to read; database: i) 15,000 communication firm), word of mouth, and - May not have access to the households benefiting from mail boxes set up at SDCs, schools, and internet; e-card vouchers; ii) other mail address also provided by the firm. - May not have access to TV; existing NPTP applicant - May not have the means to buy While the initial Project design planned to households from the NPTP newspaper conduct face-to-face interviews at the database. households’ dwellings using a defined survey instrument provided by the survey Size of the stakeholder firm, such process would have to be group is estimated at adjusted amidst the outbreak and spread of 140,000 households the COVID-19 coronavirus. In line with (over 781,000 individuals). Bank requirements (see: technical note on Group engages in public consultations and stakeholder providing feedback about engagement), stakeholder consultation and the Project. engagement activities should not be deferred but rather designed to be fit for purpose to ensure effective and meaningful consultations to meet project and stakeholder needs. As such, the CMU is required to review the country COVID- 19 spread situation in the project area and to include public hearings, workshops, and meetings between Project agencies and beneficiaries while avoiding public gatherings. Additionally, the task team is required to diversify the means of communication and rely more on social media and online channels where possible The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft and appropriate. When stakeholders do not have access to online channels or do not use them frequently, the task team is required to employ traditional channels of communications. Students aged 13- 87,000 students from TBC Official language TBC 18 in households 140,000 households (Arabic) under component 1 receiving top-up cash enrolled in public transfers. schools Social workers Around 416 social worker Through MoSA Official language N/A spread over 114 SDC (Arabic) Other Interested Parties Government PCM; MoSA; MEHE. Written information, emails, telephone, fax. Official language N/A stakeholders (Arabic) Those include ministers, Amidst the COVID-19 coronavirus director generals, advisors, outbreak, stakeholders meet virtually in staff, personnel at the line with WHO requirements to reduce CMU, technical team at the risks of transmission by limiting social IMC. interactions and large gatherings. IGOs, donors, and EU; WFP; Germany; Written information, emails, telephone, fax. Language alternative N/A investors UNICEF, NGOs (hired by (English) MoSA for component 3). Amidst the COVID-19 coronavirus outbreak, stakeholders meet virtually in Stakeholders engage in line with WHO requirements to reduce technical and non-technical risks of transmission by limiting social (operational management) interactions and large gatherings. assistance. Implementing Contracted schools, banks Written information, emails, telephone, fax. Official language N/A entities and financial (Arabic); language Amidst the COVID-19 coronavirus alternative (English) outbreak, stakeholders meet virtually in 20 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft intermediaries, grocery line with WHO requirements to reduce stores. risks of transmission by limiting social interactions and large gatherings. Third party Third party firms for: Written information, emails, telephone, fax. Official language N/A implementation communication and (Arabic); language firms outreach, monitoring and Amidst the COVID-19 coronavirus alternative (English) evaluation, GRM, external outbreak, stakeholders meet virtually in audit, verification. line with WHO requirements to reduce risks of transmission by limiting social interactions and large gatherings. Partnering NGOs who may have in- Written information, emails, telephone, fax. Official language N/A organizations, depth knowledge about the (Arabic); language CBOs, CSOs, social characteristics of the alternative (English) NGOs project and can help in Amidst the COVID-19 coronavirus identifying potential risks, outbreak, stakeholders meet virtually in impacts, and opportunities. line with WHO requirements to reduce risks of transmission by limiting social interactions and large gatherings. Press and media TV and radio channels, Written information, press releases, emails, Official language N/A newspapers, online blogs telephone, websites, direct communication (Arabic); language between firm and media outlets alternative (English) Disadvantaged/Vulnerable Groups 21 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Disadvantaged Poor and extreme poor All channels identified in the Official language As needed per households: and vulnerable Lebanese households who communication strategy targeting extreme (Arabic) Some individuals from this group: groups might be eligible poor households and the program’s - May not know how to read; beneficiaries but are beneficiaries. - May not have access to the currently excluded from the internet; Program, such as the - May not have access to TV; elderly, small-sized May not have the means to buy families, extreme poor newspaper Lebanese households from certain regions; and female-headed households just above the extreme poverty line. No data is currently available to estimate the size of this stakeholder group. Vulnerable Effective and meaningful consultations are Official language May need female representatives women and needed to ensure that the views of women (Arabic) to coordinate consultations. groups advocating are sought and incorporated. for women, children, and adolescent girls 22 4 – Stakeholder Engagement Program 4.1 – Purpose and Timing of Stakeholder Engagement Program The main goal of the stakeholder engagement program is to ensure inclusive engagement of all relevant stakeholders that have been identified in this document. This is important because it allows the stakeholders and partners in the Project to feel consulted, which can help promote better development outcomes, mitigate potential risks and impacts, and lead to long-term sustainability. In addition, having discussions with the stakeholders throughout the Project will allow the relevant parties to provide input and agree upon the best way to move forward so that actions are unified. As such, the stakeholder engagement program would lay out a map that the staff and partners can refer to throughout the Project’s development stages. Provided below are the stakeholder engagement program activities through which the stakeholders will be informed of forthcoming opportunities to review information and provide their views. While decisions on the specific type of communication, locations, and timing of meetings have not yet been finalized and highly depend on decisions that are in discussion as of this writing, in addition to Lebanon’s status in fighting the COVID19 outbreak, that information will be incorporated in future versions of this document. Table 5: Purpose and Timing of Stakeholder Engagement Program Project Stage Target Stakeholders Topic(s) of engagement Method(s) used Frequency Responsibilities Launch of - 140,000 beneficiary Announcing the launch All communication One-time campaign Communication and component 1: households from the of the scale-up and channels identified during launch, for 4 outreach firm, MoSA, Provision of extremely poor providing details on the including mass media, weeks WFP, CMU food support Project social media, websites, brochures, SMS Implementation - 140,000 beneficiary Provision of cash for Through direct Continuous engagement MoSA, PCM, WFP, of component 1| households from the basic income support. engagement Banks and financial extremely poor institutions - 140,000 beneficiary Communication and Communication Periodic engagement Communication and households from the outreach channels, virtual and in- (frequency of each outreach firm, MoSA, extremely poor person consultations communication activity CMU depending on COVID19 can vary) public health guidelines - 140,000 beneficiary GRM Communication Periodic engagement GRM Firm and focal households from the channels TV, radio, point at MoSA CMU extremely poor leaflets, flyers, websites, - word of mouth, virtual and in-person consultations depending on COVID19 public health guidelines - Vulnerable Groups GRM and SEA/H Communication Periodic engagement: MoSA, GRM Firm, including women and channels, mass media, monthly or quarterly CMU, other identified groups advocating for social media, websites, reporting women NGO groups and women, children, and SMS, virtual and in- associations adolescent girls person consultations depending on COVID19 public health guidelines The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Launch of - 87,000 Lebanese Announcing the launch All communication One-time campaign Communication and component 2: students between the of the scale-up and channels identified during launch, for 4 outreach firm, MEHE, Provision of age of 13 and 18 providing details on the including mass media, weeks CMU education cash Project social media, websites, grants brochures, SMS Implementation - 87,000 Lebanese Provision of education Through direct Continuous engagement MEHE; UNICEF of component 2| students between the cash grants and support engagement age of 13 and 18 - 87,000 Lebanese Communication and Communication Periodic engagement Communication and students between the outreach channels, virtual and in- (frequency of each outreach firm, MoSA, age of 13 and 18 person consultations communication activity MEHE, CMU depending on public can vary) health guidelines - 87,000 Lebanese GRM Communication Periodic engagement CMU, GRM Firm, and students between the channels TV, radio, focal points at MoSA age of 13 and 18 leaflets, flyers, websites, andMEHE, word of mouth, virtual and in-person consultations depending on COVID19 public health guidelines - Vulnerable Groups GRM and SEA/SH Communication Periodic engagement: CMU, MoSA, MEHE, including women and channels, mass media, monthly or quarterly GRM firm, other groups advocating for social media, websites, reporting identified women NGO women, children, and SMS, virtual and in- groups and associations adolescent girls person consultations depending on COVID19 public health guidelines 25 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Launch of - Syrian refugees5 Announcing the launch All communication One-time campaign Communication and component 3: - Lebanese beneficiary of the scale-up and channels identified during launch, for 4 outreach firm, MoSA, Access to crisis- households providing details on the including mass media, weeks CMU, NGOs hired by relevant social Project social media, websites, MoSA, other support brochures, SMS international NGOs services dealing with Syrian refugees Implementation - Syrian refugees Providing crisis-related Through direct Continuous engagement NGOs hired by MoSA; of component 3| - Lebanese beneficiary social support services engagement (at SDCs MoSA (through SDCs); and CDCs) any NGO involved in households CDCs - Syrian refugees Communication and Communication Periodic engagement Communication and outreach channels, virtual and in- (frequency of each outreach firm, MoSA, - Lebanese beneficiary person consultations communication activity CMU, NGOs hired by households depending on public can vary) MOSA, and other health guidelines international NGOs dealing with Syrian refugees - Syrian refugees GRM Communication Periodic engagement GRM Firm and focal channels TV, radio, point at MoSA, CMU, - Lebanese beneficiary leaflets, flyers, websites, NGOs hired by MOSA, households word of mouth, virtual and other international and in-person NGOs dealing with consultations depending Syrian refugees on COVID19 public health guidelines Vulnerable Groups GRM, SEA/SH Communication Periodic engagement: GRM Firm and focal including women and channels, mass media, monthly or quarterly point at MoSA, CMU, groups advocating for social media, websites, reporting NGOs hired by MOSA, 5 While Syrian refugees are identified as stakeholders/vulnerable groups in this SEP, engagement, communication campaigns and consultations with this group under component 3 of the project will be through international NGOs – the CMU will document details of these engagements in their progress reporting 26 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft women, children, and SMS, virtual and in- and other international adolescent girls person consultations NGOs dealing with depending on COVID19 Syrian refugees public health guidelines 27 4.2 Proposed Strategy for Information Disclosure Throughout the preparation and implementation phases, the outcomes of the Project and any unforeseen changes or updates will be disclosed to the stakeholders in a technically and socially appropriate approach and in a timely manner. The preliminary list of information and documents that will be disclosed by the GOL about the project includes, but is not limited to, the following: - General information about the Project; - Overview of the services and benefits; - The Program’s eligibility requirements; - Instructions on the application process; - Information on recertification process; - Locations and contact information of SDCs and application points, municipalities, and MoSA; - Application timeline; - Information on the post-application process; - Information on meetings and consultation sessions; - Information on GRMs; - Relevant environmental and social systems assessment reports to CMU; - Other due diligence and tasks to be completed in the appraisal period; - Distribution of project responsibilities among GOL and parties involved in technical assistance; - The Project’s timeline and key dates (to relevant stakeholders); - Monitoring and Reporting (M&E) information; - Social safeguards documents including the Environmental and Social Commitment Plan (ESCP), the Social Impact Assessment (SIA), the Gender-Based Violence (GBV) Action Plan, and the Labor Management Procedures (LMP); - This SEP document, and to welcome any comments or suggestions for improvement. The channels through which information disclosure will take place include: - MoSA’s website (www.socialaffairs.gov.lb) and NPTP website (www.nptp.pcm.gov.lb) - PCM website (www.pcm.gov.lb) - MEHE website (www.mehe.gov.lb) - Emails, fax, and telephone - Short Message Service (SMS) - Social media platforms: WhatsApp, Facebook, Instagram, Twitter - Traditional/Mass media platforms: TV, radio, newspapers and magazines - Online blogs - Print media: brochures, posters, and leaflets - If safe, household visits if and when recertification process is going to take place - Outreach through third-party stakeholders Other documentation will be provided to the appropriate stakeholders upon availability and as needed. Part of the information disclosure strategy will also include means necessary to consult with project-affected stakeholders if any significant changes to the project resulting in additional risks and impacts arise. The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft It is very important to understand how target stakeholders usually receive important information and how this information is interpreted. As such, the communication team should tailor the message to the beneficiaries in order to potentially reach all individuals in a family so that a family member above the age of 18 can easily apply to the Program. Table 6: Summary of Notification Plan throughout Project Cycle Project Stage List of information to be Target Responsibilities Methods proposed disclosed stakeholders Pre-application General information about Potential and MoSA; MEHE; MoSA website; outreach the Project; overview of the existing CMU at PCM; NPTP website; services and benefits; beneficiaries; SDCs; MEHE website; application timeline; Government communication PCM website, information on meetings stakeholders; firm emails, fax, and consultation sessions; IGOs, donors, telephone, SMS, relevant environmental and and investors. word of mouth, social systems assessment social media, reports; distribution of traditional media, Project responsibilities; the online blogs, print Project’s timelines and key media. dates; M&E information; environmental and social systems assessment report, GRM procedures. Implementation Program’s eligibility Potential and MoSA; social MoSA website; phase: opening requirements; instructions existing workers; SDCs; NPTP website; applications for on the application process; beneficiaries. third-party PCM website, beneficiaries information on stakeholders MEHE website; recertification process; (NGOs, IGOs, WFP, UNICEF and locations and contact CSOs, CBOs) NGOs websites; information of SDCs and including WFP emails, fax, application points as well as on component 1, telephone, SMS, schools. UNICEF on word of mouth, component 2, social media, and NGOs hired traditional media, by MOSA on online blogs, print component 3. media. Future phase: Information on post- Applicants and Social workers; Household visits. household visits application process; beneficiaries. SDCs; third- and post- timelines; guidance on next party application steps. stakeholders (NGOs, IGOs, CSOs, CBOs), 29 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft verification firm. 4.3 Proposed Strategy for Consultation Consultations with stakeholder groups were initially planned to take place through face-to-face interviews and through meetings and workshops with the CMU, in collaboration with the World Bank and other donors, investors, and interested stakeholders. However, with the outbreak and spread of COVID19, people have been advised by the Government to exercise social distancing, and specifically to avoid public gatherings to prevent and reduce the risk of the virus transmission. The general public has also become increasingly aware and concerned about the risks of transmission particularly through social interaction. These restrictive measures will affect the World Bank’s requirements for public consultation and stakeholder engagement in the Project. As such, and as per the World Bank’s “technical note on public consultations and stakeholder engagement when there are constraints on conducting public meetings�, all stakeholder consultation and engagement activities should not be deferred, but rather designed to ensure effective and meaningful consultations to meet project and stakeholder needs. Moreover, depending on how the coronavirus situation develops in Lebanon, the task team and the CMU should review this draft SEP, particularly its approach, methods, and forms of engagement proposed, and assess the associated potential risks of virus transmission in conducting the engagement activities. With respect to component 3 of the Project and the engagement of Syrian refugees, the involvement of the NGOs hired by MOSA to support SDCs and their coordination in conducting consultations with refugees remains in discussion. Best practice in line with the Bank’s requirements will be ensured during implementation of this component.. Also depending on how the coronavirus situation develops in Lebanon, public hearings, workshops, and community meetings should be avoided, and direct interaction between project agencies and beneficiaries / PAPs should be minimized. If permitted, consultations should be conducted in small-groups, such as focus group meetings. With respect to means of communication, they should be diversified with more reliance on social media, online channels, and possibly chatgroups, in addition to the traditional channels of communication like TV, newspaper, radio, public announcements and mail. Such channels can be highly effective in conveying relevant information to stakeholders, and would allow them to provide their feedback and suggestions. Where large meetings are essential, online communication and virtual workshops through WebEx and Skype are recommended. The format of such workshops could include the following steps: • Virtual registration of participants • Distribution of workshop materials to participants, including agenda, project documents, presentations, questionnaires, and discussion topics • Review of distributed information materials • Discussion, feedback collection and sharing 30 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft • Conclusion and summary If online interaction is challenging, information can be disseminated through digital platforms like Facebook, Twitter, WhatsApp groups, Project websites, etc. 4.4– Proposed Strategy to Incorporate the View of Vulnerable Groups In addition to overlooking a proactive and well-targeted communication outreach campaign (see sections 4.1 and 4.2), CMU will ensure that the views of vulnerable or disadvantaged groups will be sought during the consultation process. These measures may include engagement through proactive communication and outreach campaigns (by the channels identified in this SEP). In addition, filters to include some disadvantaged groups who might have been excluded in the initial screening process but who may be eligible for the Program will be implemented by the CMU. This can potentially address the issue of exclusion of vulnerable groups identified in this SEP to a certain extent. The CMU at the PCM will also continue to carry out data re-checking procedures for vulnerable groups that submit complaints to through the GRM system put in place.. 4.5 – Timelines Information on timelines for project phases and key decisions will be disclosed to the appropriate stakeholders as soon as possible and once available. The deadline for comments will also be determined and shared with the stakeholders by the CMU. 4.6 – Review of Comments The CMU, MoSA, and MEHE will identify staff within each organization to help develop a team who will be responsible for addressing complaints, concerns, and suggestions. The team will be comprised of staff members that will be specified at a later stage and who will be trained to respond to all incoming complaints, concerns, and suggestions in a technically and socially adequate and efficient manner, and who will have knowledge of the appropriate departments or authorities to divert the complaints to as necessary. All complaints, concerns, and suggestions must be reviewed, and all cases must be closed within a reasonable timeframe that will be communicated in advance, but that will not exceed 7 days. A summary of the review of comments must be disclosed and reported back to stakeholders periodically. 4.7 – Future Phases of Project All stakeholders will be kept informed of key Project decisions and phases as it develops. The relevant GOL authorities, including the Project’s CMU at the PCM, MEHE, and MoSA, will regularly report to stakeholders on specific matters, and disclose any changes or updates in a timely manner and in a technically appropriate approach that will be determined in the project preparation/appraisal phase. 31 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft 5 – Resources and Responsibilities for Implementing Stakeholder Engagement Activities The CMU will allocate all necessary resources including staff and budget for the management, implementation, and monitoring of the SEP during the duration of the Project. Once available, the CMU will disclose a description of those resources to the relevant stakeholders, including the names and contact information of the staff in charge and specifying who will be responsible for carrying out each of the stakeholder engagement activities. This information will be reflected in this SEP and updated as soon as it is disclosed by the Borrower. The CMU at the PCM will need to hire a social safeguards specialist who will follow up and monitor the successful implementation of this SEP including the review of all comments and in coordination with the focal points at the respective organizations. The stakeholder engagement activities are the responsibility of the MoSA in coordination with the CMU, the social safeguards specialist and the communications firm. All need to have a minimum of 7 years’ experience and the relevant qualifications in their respective fields. The CMU in coordination with the social safeguards specialist will ensure that the stakeholder engagement activities as outlined in this SEP are adhered to and will report accordingly the outcomes of these consultations in their progress reports. 6 – Grievance Mechanism The GOL discussed the importance of developing a solid GRM both at the central and local levels with the World Bank, and will seek to expand the scope of the GRM system and address weaknesses in the current informal complaint resolution mechanism at MoSA. The proposed new GRM structure for the ESSN Project entails the establishment of a GRM at the national and local levels that can be used by project beneficiaries, PAPs, and the broader public. Workers will use a separate GRM system. While the overall monitoring of the GRM would remain under the responsibility of the CMU that sits at the PCM, the CMU will outsource a third-party GRM firm that will set up the GRM at the national level. The CMU will also appoint a GRM officer who will serve as a central focal point and handle the liaison of all parties involved in the GRM including third parties, and who will provide regular feedback on the effectiveness of the GRM to the Inter-ministerial Committee (IMC). As part of the communication and outreach activities, the CMU will also be responsible of ensuring that the public is aware of the existence of the GRM and other relevant details (such as the uptake locations). At the Ministries’ level, MEHE and the NPTP unit at MoSA will each assign GRM focal points who will be in charge of overlooking the GRMs at the local levels (at SDCs or in schools) and coordinating with both the third-party firm and the CMU. At the local level, social workers (at SDCs), principles and teachers (in schools) will play an essential role in receiving complaints and feedback from beneficiaries, and will ensure reporting cases through the MIS system within 24 hours of the submission of a grievance form (filled by the complainant or the worker). The public and the beneficiaries will be notified about the existence of the GRM at different stages, and as of the Project’s earliest stages, through different means of communication including TV, radio, 32 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft leaflets, flyers, websites, word of mouth, brochures, posters, and through communication and outreach activities and consultation processes. The uptake channels that will be available for beneficiaries and the public include a dedicated email address, a toll-free number, the third-party GRM firm’s website, the NPTP’s website, feedback boxes located at SDCs and at schools, a designated mailbox, and physical centers (schools/SDCs) which will ensure flexibility in the channels available and provide the public with enough means to file their complaints or provide their feedback. In order to keep track of grievances, the contracted firm will develop and operate a “complaint management system� that will be accessed by all parties involved in the GRM to ensure harmonization of the format of GRM forms submitted across all uptake channels. The firm will also be in charge of sorting/categorizing the complaints which are later referred by the GRM manager to a GRM coordinator at the CMU, who will determine the investigation process, timeframe (that does not exceed 7 days), and appropriate course of action. Where feasible, complainants will be notified through logged communication about the process before any action is taken by the entity receiving the complaint and handling the investigation. This entity will carry out verification tasks including site visits, verification of documents, and meetings with complainants. No investigations will be conducted for cases of GBV-related complaints. As required by the World Bank guidelines, such cases should be referred to an NGO procured under the project (component 3) to manage GBV cases for referral to the appropriate service providers. Finally, complainants will be notified about the results of the investigation and the proposed action through the same channel their complaint was received within a specified timeframe and will be informed of the appeal process in the event they are not satisfied with the response. The CMU will supervise the GRM regularly and ensure its efficiency, while the GRM focal point will work with an M&E specialist to provide quarterly reporting of GRM results. All quarterly and annual reports that will be submitted to the World Bank will include a GRM section that includes various information and indicators about the GRM. The CMU will also ensure that an independent review/audit of the GRM is conducted prior to the project mid-term review to assess the effectiveness of the GRM system. The detailed description of the GRM system is provided in Appendix 1. 7 – Monitoring and Reporting 7.1 – Involvement of Stakeholders in Monitoring Activities 33 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft The CMU will publish reports about activities associated with the Emergency SSN project in general on the existing PCM and NPTP websites (www.pcm.gov.lb; and www.nptp.pcm.gov.lb) and will include in its reporting any additional coverage needed by the scale-up Project.. 7.2 – Reporting Back to Stakeholder Groups As suggested in this document, periodical reporting will be published by the CMU and the Project’s management in a technically and socially appropriate manner during the course of the project. Results of all stakeholder engagement activities will be disclosed by the PMU to both affected stakeholders and broader stakeholder groups through the channels identified in this document. In addition, stakeholders will always be reminded of the availability of a grievance mechanism through which they could address any complaints or concerns. 34 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft References • World Bank, March 2020 poverty update • World Bank, Implementation Support Missions, Aide-Mémoire, May-August 2019 • World Bank, technical note on public consultations throughout pandemic outbreak • NPTP Database (2020) • World Bank, ESS10 Guidance Note • World Bank, Project Preparation Documents (components 1, 2, 3, 4; distribution of responsibilities and tasks; institutional arrangement chart) • World Bank, NPTP Reforms and Expansion, August 2019 • MoSA, NPTP Communication Strategy, March 2020 Consultations and meetings (all virtual): - Dr. Bashir Osmat, March 19th, 2020 - Ms. Marie Ghiya and Ms. Abou Jaoudeh, March 20th - Dr. Bashir Osmat, March 21st, 2020 - Mr. Ramzi Fanous and Ms. Abou Jaoudeh, PCM, March 23rd, 2020 - Mr. Ramzi Fanous and Ms. Marielouise Aboujaoudeh, PCM, April 6th, 2020 35 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft - Appendix 1 Outline of the proposed GRM for ECRSSN Scope: A Grievance Redress Mechanism (GRM) is a system whereby stakeholders can submit their complaints, queries, suggestions, and feedback, about the project. Effective project GRMs are intended to address issues and complaints in an efficient and timely manner. They should be widely accessible to the full range of project stakeholders, including project-affected parties, community members, vulnerable groups, civil society, media, and other interested parties, through multiple uptake channels. The mechanism focuses not only on receiving and registering complaints and feedback from beneficiaries, but also on how complaints are resolved. GRMs are usually supported by an information campaign and training. No Social Safety Net project is successful without a robust GRM that ensures social accountability and builds trust with communities. Accordingly, the success of the Emergency Crisis Social Safety Net Project would rely heavily on the existence of a strong and functional GRM. Who Can Use this GRM? Project beneficiaries (Households/individuals receiving assistance), project affected people (i.e. those who will be and/or are likely to be directly or indirectly affected, positively or negatively, by the project), as well as the broader public who can use the GRM for the purposes of making complaints and providing feedback. Workers will use a separate GRM. The types of grievances that can be submitted through the GRM would include the following: - Fraud and corruption - Eligibility - GBV/SEA complaints - Lost cards/payment issues/withdrawal/etc. - Misconduct of staff - Misuse of funds The Public Awareness and Communication: The public and beneficiaries will be notified about the existence of the GRM and the way to access it at the earliest stages of the project through communication and outreach activities and the consultation process. The communication campaign shall include information on the scope of the GRM, the procedure to submit grievances (where, when and how), the investigation process, the timeframe for responding to the complainant, principle of confidentiality and right to make anonymous complaints. Multiple means of communication will be used including TV, radio, leaflets, flyers, website, and word of mouth. Brochures will be distributed during consultations and public meetings, and posters will be displayed in public places such as in Municipalities, Public Schools and Social Development Centers. 36 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Information on complaints received and resolved will be also reported as part of the project’s routine quarterly reporting. Also, a summary of implementation of the GRM will be provided to the public on an annual basis. Organizational structure: Component 4 of the project will support the establishment of a GRM at the national and local levels in Lebanon. The overall monitoring of the GRM would be the responsibility of the Central Management Unit (CMU) sitting at the Presidency of Council of Ministers (PCM). The CMU will outsource a firm which will be in charge of setting up the GRM at the national level. The Ministry of Social Affairs and Ministry of Education and Higher Education will play a role each in their own capacity in operating the GRM at the local levels. A separate mechanism will be used for workers’ grievances. The PCM CMU will appoint a GRM officer who will serve as a central focal point by providing regular feedback on the effectiveness of the GRM to the Inter-ministerial Committee (IMC). The responsibilities of the GRM officer will consist of liaising with all parties involved in the GRM including third parties, UN agencies and service providers, and monitoring the efficiency and functionality of the GRM. As part of the communication and outreach activities, the CMU would also ensure that the public is aware of the existence of the GRM, and particularly of the uptake locations to request information or complain. Development and management of Central GRM will be outsourced to a firm. The responsibilities of the firm would include: • Assigning a GRM manager which will be in charge of ensuring complaints are logged and sorted. • Assigning a GRM coordinator which would determine which complaint should be investigated and escalated to the CMU. • Developing a protocol and MIS program to manage and record all complaints and responses/feedback. • Setting up a GRM Operational Manual which would include standardized processes, timelines and procedures at each level. The OM needs to be formulated and disseminated among all staff as well as teams in direct contact with beneficiaries or non-beneficiaries. • Establishing an automated tracking system, FAQs, call centers with a Toll free hotline available to the public, email address and website that communities can access to submit complaints and receive information about the GRM • The firm will report to the GRM officer at the CMU. The uptake locations would be established at the central level through a call center, website and email. At the local levels, the uptake locations will be distributed throughout the regions in the SDCs, and public schools. At the Ministries’ level, MOSA NPTP Unit and MEHE will each assign GRM focal points who will be in charge of overlooking the GRMs at the local levels, ensuring they’re operational and following the established standards. They will also be responsible for liaising and coordinating with the firm and CMU. The social workers will play an essential role in receiving face to face complaints and feedback from beneficiaries. It is also expected that school principals and teachers would gather information and feedback from beneficiaries at the school level. 37 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft CMU/ GRM Focal Point GRM Firm MOSA NPTP MEHE GRM Unit/GRM focal WFP UNHCR focal point point SDC Regional offices BLF Schools/principals Social workers /teachers Figure 1- Proposed GRM organizational structure It is important to note that the GRM would need to be tailored to address any potential GBV/SEA grievances. Accordingly, staff managing the GRM would need to receive appropriate training to ensure protocols are established including confidentiality and referral to service providers. GRM Process: The overall process for the GRM will be comprised of six steps, as shown and described below. Figure 2- GRM Value Chain Uptake channels: It is suggested that the project will establish the following channels through which citizens/beneficiaries can make complaints or provide feedback. a. A dedicated email address TOLL FREE NUMBER] b. On the GRM website c. On the NPTP website d. Feedback boxes located at SDCs and Public Schools 38 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft e. Letters sent to a defined Mailbox f. Verbal or written complaints to social workers (directly or through walk ins to SDCs). (If project stakeholders provide verbal feedback/complaint, social workers will lodge the complaint on their behalf, and it will be processed through the same channels. g. Project meetings/consultations set up throughout project implementation. The project shall ensure flexibility in the channels available, making sure that different contact points are available for a person to make a verbal complaint, and that complaints addressed to the wrong person or entity are redirected to the central GRM. It is also important to ensure that uptake channels are culturally sensitive and accessible to vulnerable groups, particularly in remote areas. Confidentiality: Complaints may be made anonymously, and confidentiality will be ensured in all instances, including when the person making the complaint is known, and when GBV related grievances are submitted. Collection and Registration of complaints: The firm would be in charge of developing a “complaint management system� which can be accessed by all parties involved in the GRM. The management system will have different registration databases at each level. Complaints can be received at the local levels through the Social Development Centers and Public Schools, or through the central GRM. Assigned staff from the central GRM/ MOSA/MEHE should be using the system to register complaints and feedback received by the community. The system would be managed and maintained by the firm which will ensure harmonization of the format of the GRM submission forms across the different uptake channels. The person receiving the complaint whether at the SDC level, the school, the call center, etc. will need to complete a grievance form, or make the form available to the complainant to fill out directly and submit it through the MIS system without delay (within 24 hours). The complaints for the project will be collected and compiled by the firm on a regular basis. Sorting/categorization Once received and filed in the system, the firm will be in charge of sorting the complaints/feedback into the following categories: Category Classification No. Category 1 Grievances regarding eligibility of the beneficiaries, scoring, PMT formula Category 2 Grievances regarding the ecard, loss of cards, inability to retrieve cash, or other technical issues linked to the Bank ATM/POS Category 3 Grievances regarding violations of policies, guidelines and procedures Category 4 Grievances regarding the misuse of funds/lack of transparency, or other financial management concerns Category 5 Grievances regarding abuse of power/intervention by project or government officials 39 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Category 6 Grievances regarding staff performance Category 7 GBV grievances Category 8 Suggestions Category 9 Appreciation Follow-up and Acknowledgment: The GRM firm would develop in coordination with the CMU/MOSA and MEHE, an automated tracking system, FAQs, processes and service standards including timeline for resolution, to ensure follow up to all complaints across agencies and at different levels. Accordingly, once the complaints have been categorized, the GRM Manager logs the details regarding the complaint into the tracking system as part of the MIS system. Once a complaint has been logged and sorted, the GRM Manager refers the case to a GRM Coordinator at the CMU. The latter will be responsible of the following: • The person responsible to investigate the complaint. • The timeframe within which the complaint should be resolved. • The agreed course of action (e.g. investigation, reply not requiring investigation, escalating to CMU, liaising with MOSA, MEHE, WFP, etc.). The investigation process is determined based on the nature and gravity of the complaint, however regardless of type/category complaints all complainants should be assured of receiving feedback within a timeframe communicated in advance. The timeframe should not exceed 7 days. • For local level complaints, the investigation will be conducted by the social workers at the SDC level. • For complex complaints, the investigation will be conducted by an assigned investigation officer as described in the GRM Operational Manual When determining who will be the investigating officer, the CMU will ensure that there is no conflict of interest, i.e. all persons involved in the investigation process should not have any material, personal, or professional interest in the outcome and no personal or professional connection with complainants or witnesses. Once the investigation process has been established, the person responsible for managing the GRM records (GRM manager) and enters this data into the system. The number and type of suggestions and questions should also be recorded and reported to the CMU on a regular basis, so that they can be analyzed to improve project communications. Notification to the complainant If the complainant is known, the entity receiving the complaint will be responsible for communicating the timeframe and course of action to her/him by phone, email or mail, within a specified deadline of receipt of the grievance. 40 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Where feasible, the communication should be provided in writing with a tracking number and the deadlines by which they will hear back from the Project GRM. Investigation The person responsible for investigating the complaint will be in charge of gathering facts in order to generate a clear picture of the circumstances surrounding the grievance. Verification normally includes site visits, review of documents, a meeting with the complainant (if known and willing to engage), and a meeting with those who could resolve the issue. It is important to note that with the COVID19 situation, measures of social distancing should be respected when determining the means of verification. More importantly, no investigation will be conducted for cases of GBV related complaints. As required by the World Bank guidelines, such cases should be referred to an NGO procured under the project (component 3) to manage GBV cases for referral to the appropriate service providers. The results of the verification and the proposed response to the complainant will be logged in the system and communicated to the GRM coordinator at the firm who will in turn communicate it to the GRM focal point at the CMU, if need be. Once the decision has been made on the course of action and on the response to provide to the complainant, the actions to be, along with the details of the investigation and the findings, are also entered it into the MIS system. Response to complainant If the complainant is known, the GRM communicates the proposed action to her/him via letter, email, verbally, as received within a specified timeframe. The complainants will also be informed of the appeal process. Feedback from the complainants should be collected as to whether s/he deems the action(s) satisfactory, and this will be recorded along with the details of the complaint and the response taken. Appeal process: In the event the complainant is not satisfied with the response, he/she should be able to appeal. The project will ensure an appeal process is established and communicated to the complainants. Complainants are not precluded from appealing outside the project GRM or from using the judiciary system if they are not satisfied with the proposed response. Regular internal monitoring and reporting The CMU will assess the functioning of the GRM and supervise it regularly. The GRM focal point will work with the M&E Specialist at the CMU and with the GRM firm to: - Ensure accurate entry of GRM data into the management information system or other system. Produce compiled reports to the CMU coordinator and IMC. - Provide a quarterly report of GRM results including any suggestions and questions, to the CMU. - Review the status of complaints to track which are not yet resolved and suggest any needed remedial action. On a periodical basis, the CMU and GRM focal points in each ministry shall discuss and review the effectiveness and use of the GRM and gather suggestions on how to improve it. Reporting in quarterly and annual progress reports submitted to the Bank 41 The World Bank Lebanon Emergency Crisis and COVID19 Response SSN Project, Stakeholder Engagement Plan Draft Quarterly and annual progress reports shall include a GRM section which include information and indicators on the following: - Status of establishment of the GRM (procedures, staffing, training, awareness building, budgeting etc). - Quantitative data on the number of complaints received, the number that were relevant, and the number resolved - Quantitative date on the number of complainants, and number of female complainants - Qualitative data on the type of complaints and answers provided, issues that are unresolved - Time taken to resolve complaints - Number of grievances resolved at the local level, escalated to the central levels. - Satisfaction with the action taken - Any other issues faced with the procedures/staffing or use - Problems that may be affecting or delaying the use of the GRM/beneficiary feedback system GRM audit: The CMU will ensure that an independent review/audit of the GRM is conducted prior to the project mid-term review to assess the effectiveness and use of the GRM and recommend introduce improvements as necessary. Capacity building: Finally, all teams should receive a GRM training once the tasks and responsibilities of each entity are clarified. Dedicated trainings should be provided as part of component 4 activities, to staff directly engaging with beneficiaries, those handling the system, and those involved in the management and oversight of the system. The training shall include all aspects of the GRM and its management. Training and awareness building dedicated to handling GBV related grievances would be conducted separately and would target all staff particularly the social workers. A key focus at the outset will be shifting from informal complaint resolution as is the case currently in MOSA, to the logging of all complaints/feedback into the developed GRM system 42