REPUBLIC OF SIERRA LEONE Ministry of Basic and Secondary School Education (MBSSE) FREE EDUCATION PROJECT ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) May 2019 1|Page World Bank MBSSE/ FREE Education Project ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Ministry of Basic and Secondary School Education (MBSSE) of Sierra Leone is planning to implement the FREE Education Project (the Project). The International Development Association hereinafter the Bank/the Association] has agreed to provide financing for the Project. 2. The MBSSE 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 a summary of the material measures and actions. 3. Where the ESCP refers to specific plans or other documents, whether they have already been prepared or are to be developed, the ESCP requires compliance with all provisions of such plans or other documents. In particular, the ESCP requires compliance with the provisions set out in the Environmental and Social Management Plan and Resettlement Action Plan that have been developed for the Project. 4. The table below summarizes the material measures and actions that are required as well as the timing of the material measures and actions. MBSSE 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 Bank/Association by MBSSE as required by the ESCP and the conditions of the legal agreement, and the Bank/Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank/Association and MBSSE, 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, MBSSE will agree to the changes with the Bank/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 Bank/Association and the MBSSE. The MBSSE will promptly disclose the updated ESCP. Depending on the project, the ESCP may also specify the funding necessary for completion of a measure or action. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the MBSSE shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include environmental, health, and safety impacts, labor influx, gender-based violence. 2|Page [FREE Education Project] ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Date of Completion Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed ESCP Monitoring and Reporting REGULAR REPORTING: Quarterly throughout MBSSE, through the Throughout the Project life time. MBSSE will prepare and submit regular monitoring reports on the project FREE Education implementation of the ESCP. The report will among others implementations Project Secretariat be include (i) status of implementation of the ESCP; (ii) conditions, if responsible for any, which interfere or threaten to interfere with the funding and submitting implementation of the ESCP; and (iii) corrective and preventive updated ESCP for measures taken or required to be taken to address such conditions. review, discussion and agreement with the Bank INCIDENTS AND ACCIDENTS NOTIFICATION: Within 48 hours and Project Contractors Throughout the Project life time. project will promptly notify any incident or accident related or no later than 72 hours will be responsible for having an impact on the Project which has, or is likely to have, a after occurrence of the submitting significant adverse effect on the environment, the affected incident or accident. incident/accidents communities, the public or workers including situations of reports to the FREE fatalities or serious bodily harm and incidents of Gender Based Education Project Violence. The report will include sufficient detail regarding the Secretariat of MBSSE incident or accident, indicating immediate measures taken to address it, and include information provided by any contractor and FREE Education supervising entity, as appropriate. Incidents and accidents include Project Secretariat of kidnapping, GBV, communicable diseases, violence, fatalities, MBSSE will submit infectious, all fires, and occupational injuries. incident reports to the Bank 3|Page SUMMARY ASSESSMENT ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE: The FREE Education The MBSSE/FREE The E&S Specialists at the Free FREE Education Project Secretariat of MBSSE shall establish an Project Secretariat of Education Project are Education Project Secretariat EHS desk with qualified E&S experts (Environmental Specialist, the MBSSE with E&S responsible for will be at post until project social and Gender Specialist) Specialists will be set funding the setting up completion The FREE Education Project Secretariat E&S Specialists will be up prior to and operations of the supported by Environment and Social Officers at the Regional and commencement of the EHS Unit District levels to implement the project. This structure will be project. maintained throughout Project implementation. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT: Prior to commencing FREE Education Prior to commencing of the Subprojects will be screened per the procedures outline in the of the Subprojects Project Secretariat of Subprojects activities ESMF as sites are identified. Based on the screening results, activities. MBSSE to supervise detailed environmental and social assessments may be conducted the impact assessment and accompanied by the relevant ESMPs to address any risks studies. Funding for identified during the process. The ESIA will include the consultancy services assessment of GBV risks. shall be covered by the FREE Education Project 1.3 MANAGEMENT TOOLS AND INSTRUMENTS: Develop, The ESMF, RPF, and MBSSE/ through Prior to commencing of the adopt, consult on and disclose an Environmental and Social SEP will be completed consultants / funding Subprojects activities Framework (ESMF), Resettlement Policy Framework (RPF), prior to project from the Project Stakeholder Engagement Plan and Environmental and Social appraisal budget Commitment Plan (ESCP) satisfactory to IDA. Secure environmental permits for all new construction and rehabilitation under the FREE Education Project MBSSE/ through E&S Develop sub Subprojects Screening Forms and Impacts Checklist consultants Forms as part of the ESMF to be used to screen all sub-project to Thought out project Before project appraisal determine requirement for follow ESHIA, ESMPs, RAPs etc implementations MBSSE/ through consultants Environmental and Social Management Plans (ESMPs) and Prior to Prior to commencement of civil Resettlement Action Plan will be prepared and disclosed. commencement of works. Environmental and Social Assessment process for subprojects will works be done after Subprojects screening. 4|Page FREE Education Draft Labor Management Procedures to be included in ESMF. Throughout project Project E&S Prior to commencement of civil Contractor is required to Update this into a Labor Management implementation specialists. works Plan and ensure compliance during implementation. MBSSE/ through Prior to consultants. Prior to commencement of Implement ESMP, RPF, SEP commencement of works work MBSSE/ FREE Throughout project Education secretariat/ Throughout project implementation funding from project implementation Detailed GBV Assessment to be carried out during ESHIA studies budget. action plan to be developed by contractor as part of contractor ESMP. MBSSE/ consultant/ Prior to contractor/ funding Throughout project commencement of civil from project budget. implementation works 1.4 MANAGEMENT OF CONTRACTORS: prepared together MBSSE /FREE Throughout the Project MBSSE shall develop and implement Labor management Plan for with C-ESMP before Education Project managing contractors and subcontractors: commencement of civil Secretariat, E&S • environmental and social requirements will be included in works. specialist, procurement the procurement and contracting process including bidding officer. Funding from documents, for potential civil works. the project budget. • relevant requirements are included in contracts and subcontracts (reflecting ESSs and ESCP); • codes of conduct are required of contractors and subcontractors and their workers to prohibit sexual harassment and exploitation and training of workers on their obligations under the CoC. • Contractor to prepare a costed GBV Action Plan as part of the contractor ESMP. • Preparation of a detailed contractor ESMP (C-ESMP) that is costed, with sufficient budget to mitigate E&S risks • Monitor Contractor commitment and compliance • Ensure contractors provide details on contractor’s oversight on environmental, social, health and safety (ESHS) performance 5|Page • Contractor to develop a grievance redress mechanism to handle concerns of their employees • MBSSE has developed a Labor Management Procedure Which Contractors shall update into a plan and comply with during Implementation. 1.5 PERMIT, CONSENTS AND AUTHORIZATIONS: All authorization shall MBSSE is responsible Permits will be renewed as MBSSE shall facilitate the issuance of the environmental permits be obtained prior to for obtaining stipulated in the permit and all necessary authorization from ministries, departments and mobilization of Environmental condition until the end of the agencies (MDA), such as EPASL. contractors licenses. The cost of project obtaining the licenses MBSSE shall ensure that the contractor complies with the Renewal of permits shall be covered by the conditions established in these permits, consents and will be the project. Contractor authorizations throughout Project implementation. responsibility of the shall obtain any other MBSSE relevant license during implementation. 1.6 THIRD PARTY MONITORING: a third party shall be engaged third party monitoring MBSSE to hire the Monitoring continues until to complement and verify the monitoring of environmental and will be done annually. services of a completion and social risks and impacts of the Project. consultant. Payment decommissioning of project RAP completion audit for monitoring is to be Project will also conduct RAP completion audit following done after RAP covered by the project completion of RAP implementation and ESMP audit 3 months implementation and before completion of civil works. ESMP Audit done 3 months before completion of works. 1.7 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES: MBSSE/ E&S Effective throughout the project Labor management procedures (LMP) has been developed by the Prior to the specialists shall ensure life, and reviewed on a quarterly MBSSE. The LMP set out the way in which project workers will preparation of that the selected basis be managed, in accordance with the requirements of Sierra Leone procurement contractor meets these national law and ESS 2. The plan will address the way in which documents. requirements ESS2 will apply to different categories of project workers, Maintain procedures including direct workers, and the way in which the Borrower will throughout Project require third parties to manage their workers. The contractor will implementation. 6|Page be required to update the Labor Management Procedure into a Plan during implementation and comply with its requirement. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: Grievance mechanism MBSSE shall ensure Effective throughout the project The contractor shall develop and implement a GRM for their staff, operational prior to that the mechanism is life, and reviewed as and when and this shall be approved by the FREE Education Project Secretariat recruitment and in place before necessary of MBSSE and the Bank. implemented recruitment of staff is throughout Project conducted by implementation. contractor; 2.3 OHS MEASURES: Prior to initiating MBSSE/ FREE Effective throughout the project Contractors working on the Project shall develop and implement construction, and Education Project life, and reviewed as and when approved occupational, health and safety (OHS) plan/measures. implemented Secretariat / E&S necessary throughout Project life Specialists/ Contractor’s Health and safety officer and MBSSE E&S specialists Contractors shall train/orient employees of Project Contractors on various aspects of OHS relevant to the project 2.4 EMERGENCY PREPAREDNESS AND RESPONSE: Prior to initiating MBSSE/ FREE Effective throughout the project Emergency Preparedness and Response measures incorporated in construction. Education Project life, and reviewed as and when OHS measures guideline as part of subproject screening Maintained Secretariat / E&S necessary ESIAs/ESMPs prior to commencement of works. throughout Project Specialists/ implementation. Contractors. This is covered by the project 2.5 PROJECT WORKERS TRAINING: Prior to initiating MBSSE/ FREE Periodically throughout the Health and Safety training shall be provided to employees of construction, with Education Project project life, and revisited as and Project Contractors by the contractor Health and Safety officer. regular refresher and Secretariat / E&S when necessary task-specific training Specialists/ are sessions during the responsible for entire construction providing oversight of phase compliance with Health and Safety Requirements 7|Page 2.6 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 MANAGEMENT OF WASTE AND HAZARDOUS Wastes management Contractor/ MBSSE Effective throughout the project MATERIALS: plan as part of ESMP FREE Education life, and reviewed as and when Project Contractors shall develop and implement a general waste and applied Project Secretariat/ necessary management plan including hazardous materials and chemicals. throughout Project Project Environmental The plan could be annexed to the ESMP. implementation. specialist. funding covered by the project 3.2 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Prior to initiating MBSSE/ FREE Effective throughout the project Project Contractors shall be required to develop and implement construction. Education Project life, and reviewed as and when measures and actions in the sub project ESMPs to assess and Maintained Secretariat / E&S necessary manage traffic and road safety risks. throughout Project Specialists/ implementation. 4.2 COMMUNITY HEALTH AND SAFETY: Prior to initiating MBSSE/ FREE Effective throughout the project The Project ESMF shall guide the Contractors to develop and construction and Education Project life, and reviewed as and when implement adequate measures and actions to assess and manage employee recruitment. Secretariat / E&S necessary specific risks and impacts to the community and beneficiary Maintained Specialists/ shall schools arising from project activities. throughout Project ensure that the Contractors measures, and work methods shall be validated by the implementation. document is approved local authorities and SMCs and approved by the FREE Education and available prior to Project Secretariat MBSSE commencement of construction activities as well as supervise implementation of the CHS by the contractor. 4.3 GBV AND SEA RISKS: services of the NGO MBSSE/ FREE Effective throughout the project GBV and SEA risks to be assessed as part of social assessment (service provider) Education Project life, and reviewed as and when and ESHIA. Project to hire a local NGO to assist in GBV sought prior to Secretariat / project necessary response including supporting the design of GBV sensitive GRM, contractor E&S Specialists/ training and awareness raising on GBV for the local communities mobilization. Contractors. Funding and MBSSE, ensure that care seeking behaviors and knowledge of Maintained as part of project cost. how and where to report GBV cases are known and support throughout Project survivors to receive appropriate support services implementation. 8|Page (medical/physical-social counseling and legal aid as agreed with the survivor). While the services of a gender-based NGO working in the project area is solicited to handle GBV and SEA, the contractor shall develop a well costed GBV action Plan and strictly abide by the measures provided. 4.4 GBV AND SEA RISKS DURING PROJECT Monitoring of MBSSE/ FREE Effective throughout the project IMPLEMENTATION: GBV action plan will be required by the compliance to Education Project life contractor as part of C-ESMP with adequate funding for contractor GBV Secretariat / project implementation. Action Plan E&S Specialists/ throughout the Contractors/ GBV implementation period service provider. of the project Funding as part of contractor cost for ESMP implementation 4.5 EMERGENCY RESPONSE MEASURES: ESMPs will be MBSSE/ FREE Effective throughout the project The contractor shall implement emergency preparedness and available prior to Education Project life, and reviewed as and when response plan in project ESMPs. initiating construction. Secretariat / project necessary Maintained E&S Specialists/ throughout Project Contractors. implementation. 4.6 SECURITY PERSONNEL: Not relevant for this The project and its contractors will not use military or paid project security forces for site security. 4.7 TRAINING FOR THE COMMUNITY: Prior to initiating MBSSE/ FREE Periodically throughout the MBSSE through the consultant shall conduct training for the construction, with Education Project project life, and revisited as and community designed to heighten awareness of risks and to regular refresher Secretariat / project when necessary mitigate impacts specified including: training sessions E&S Specialists/ • communicable diseases/HIV-AIDS/STI awareness and Contractors. cost prevention covered by the project • community grievance redress mechanism as described in the Stakeholder Engagement Plan/ ESMF/RPF • process for resolving conflicts between workers and community members • GBV and SEA and Child protection. 9|Page 4.8 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 LAND ACQUISITION AND RESETTLEMENT: Prior initiating MBSSE/ FREE Before commencement of The Project has prepared a Resettlement Policy Framework activities that involve Education Project construction works (RPF) which will be disclosed prior to appraisal. The RAP will be involuntary Secretariat / project prepared as required when subproject locations are identified resettlement. E&S Specialists/ will ensure that the RAP has been done consistent with ESS 5 before mobilization of contractor 5.2 RESETTLEMENT PLANS: RAPS will be MBSSE/ FREE Before commencement of A RAP shall be developed by a consultant, appointed by MBSSE implemented prior Education Project construction works or consultancy firm as appropriate and implemented by MBSSSE initiating activities Secretariat / E&S and the consultant, when subproject locations are identified, and it that involve Specialists/. Cost is determined that activities will involve involuntary resettlement. involuntary internalized as part of resettlement. project cost 5.3 MONITORING AND REPORTING: part of project MBSSE through the Throughout project life MBSSE shall ensure that monitoring and reporting on land quarterly reports project E&S acquisition and resettlement activities are conducted throughout specialists and the project as part of project regular reporting channels and independent third- separately as requested by the World Bank. party monitors shall ensure that the RAP has been implemented, monitored and documented according to ESS5 before mobilization of contractor 5.4 GRIEVANCE MECHANISM: Prior to MBSSE shall ensure a Throughout project life A Grievance Redress Mechanism (GRM) is being developed as commencement of GRM has been set up part of the ESMF and RPF will be completed before project activities/ and is being commencement of project activities. The GRM will incorporate implementation implemented before existing GRM systems in place at the MBSSE and the local level. 10 | P a g e mobilization of contractor 5.5 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: Prior to commencing MBSSE/ FREE prior to civil works The project will screen subproject activities using the screening sub-project activities. Education Project tool developed under the ESMF to determine potential Secretariat, E&S biodiversity risks and impacts and make recommendations. specialist. funding from project budget Sites within one (1) kilometre radius of natural and critical habitats or environmentally sensitive areas shall be declared ineligible for construction during the screening and site selection Work shall not be carried out in sensitive ecosystems/habitats/species, such as protected areas, forests, wetlands and IUCN listed species to avoid elaborate offsets and project delays. The Project will also consider the views, roles, and rights of groups, including local non-governmental organizations (NGOs) and local stakeholder communities, and involve such in planning, designing, implementing, monitoring, and evaluating the project. Involvement may include identifying appropriate conservation measures, managing protected areas and other natural habitats, and monitoring and evaluating specific actions 6.2 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.3 GRIEVANCE MECHANISM: N/A NA 7.4 Add other measures and actions that have been agreed, as per the specific risks and impacts of the Project N/A ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS: During design of sub- MBSSE/ FREE Throughout project life The contractor shall implement a Chance Find procedure in line projects Education Project with the ESMF/ESMP in preparation for any ‘chance’ or Secretariat / E&S accidental finds during the project. specialists 11 | P a g e In the event of a find, the Monuments and Relics Commission (MRC) that is entrusted with the protection of cultural heritage in Sierra Leone shall be contacted. 8.2 CULTURAL HERITAGE: Prior to the FREE Education Throughout project life The project will take cognizance of tangible and intangible Commencement of Project Secretariat cultural heritage sites and items, including potential archaeological Works as part of the MBSSE/ Contractors heritage within the project’s area of influence. The Project will sub project screening adopt measures such as undertaking meaningful consultations with and Site Selection stakeholders regarding cultural heritage and implementing basic mitigation measures at the construction phase, such as a chance find procedure. 8.3 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project ESS 9: FINANCIAL INTERMEDIARIES 9.1 ESMS: Not relevant Not relevant to this project since there are no FIs involved in this project. However, the project will be guided by this standard when applicable. 9.2 FI ORGANIZATIONAL CAPACITY: Not relevant Not relevant 9.3 SENIOR MANAGEMENT REPRESENTATIVE: Not relevant Not relevant 9.4 Add other measures and actions that have been agreed, as per the None specific risks and impacts of the Project ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 SEP PREPARATION: Prior to appraisal MBSSE/ FREE SEP is ready at the project MBSSE has prepared and shall disclose a Stakeholder Education Project design stage but will be Engagement Plan (SEP) for the design and implementation of the Secretariat. Cost is reviewed and updated quarterly project prior to appraisal. covered by the project 10.2 SEP IMPLEMENTATION: Implement the SEP. Throughout Project MBSSE/ FREE Throughout project life MBSSE resources, such as the communications office and the implementation Education Project control room shall be leveraged in engaging stakeholders. 12 | P a g e Stakeholder engagement has commenced and shall continue Secretariat. Cost is throughout the life of the project covered by the project 10.3 PROJECT GRIEVANCE MECHANISM: Develop and Grievance Mechanism MBSSE/ FREE Continuously throughout project implement the arrangements for the grievance mechanism. in place prior to Education Project duration See sections 2.2 and 5.4 appraisal, to be Secretariat and updated and grievance committee. maintained Cost is covered by the throughout the Project project implementation. 10.4 Add other measures and actions that have been agreed, as per None the specific risks and impacts of the Project Capacity Support Specify Training to be provided Specify Targeted Groups and Specify Training Completed Timeframe for Delivery Contractor Training may be required in: MBSSE, District Engineers and World Bank ESF • Stakeholder engagement Environmental Health Officers, Community Entry and Mobilization • Subproject Environmental and Social screening SMCs, Project Consultants, Handling Grievances • Specific aspects of environmental and social Contractors and workers. this will be Basic Health and Safety Procedures assessment done before commencement of civil Environmental and Social Reporting • Occupational Health and Safety works. • Emergency preparedness and response • Community health and safety • Monitoring and Reporting • Gender-Based Violence Risk Mitigation • Disability inclusion training • GRM • Waste management (domestic solid wastes and sewage) • Documentation and reporting • Labor management procedures Training for community people shall include: Regional and district representatives, Training shall commence at project implementation • Traffic safety and Road signage a cross section of chiefdom and • Grievance redress and conflict resolution community people • Environmental, social and safety impacts of the project and their mitigation • Community Health and Safety • GBV and child protection 13 | P a g e • All trainings cost will be costed as part of project and contractor costs as appropriate. 14 | P a g e