The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) Combined Project Information Documents / Integrated Safeguards Datasheet (PID/ISDS) Appraisal Stage | Date Prepared/Updated: 11-Apr-2019 | Report No: PIDISDSA25658 Jan 03, 2019 Page 1 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) BASIC INFORMATION OPS_TABLE_BASIC_DATA A. Basic Project Data Country Project ID Project Name Parent Project ID (if any) Benin P167432 Benin Global Partnership for Education Project Phase 3 Region Estimated Appraisal Date Estimated Board Date Practice Area (Lead) AFRICA 19-Nov-2018 01-Jul-2019 Education Financing Instrument Borrower(s) Implementing Agency Investment Project Financing Government of Benin Ministry of Preschool and Primary Education Proposed Development Objective(s) The Project Development Objectives (PDO) are to: (i) improve the quality of teaching and learning in basic education with an emphasis on the early grades; and (ii) strengthen equity in primary education, particularly in four regions of the country. Components Component 1 : Improving the quality of basic education Component 2: improving equity in basic education Component 3: Strengthening the delivery of education services World Bank Supervision PROJECT FINANCING DATA (US$, Millions) SUMMARY -NewFin1 Total Project Cost 19.40 Total Financing 19.40 of which IBRD/IDA 0.00 Financing Gap 0.00 DETAILS -NewFinEnh1 Non-World Bank Group Financing Jan 03, 2019 Page 2 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) Trust Funds 19.40 EFA-FTI Education Program Development Fund 19.40 Environmental Assessment Category C-Not Required Decision The review did authorize the team to appraise and negotiate B. Introduction and Context Country Context 1. Benin is a small coastal country with a growing population of about 10.9 million people, of which approximately 43 percent are young people between the ages of 0-14 years old. Economic growth from 2012 to 2016 was around 4.9 percent, and further increased to 5.4 percent in 2017. This trend is expected to continue, with recent estimates suggesting that economic growth will increase to 6.3 percent for the 2018- 2020 period. Despite steady growth, Benin remains a low-income country with a per capita income of US$771 in 2016. Poverty decreased marginally from 2006 to 2015. In addition, given rapid population growth (about 3.2 percent per annum), the absolute number of poor individuals in Benin increased from 5.0 to 5.3 million. A substantial share of the population is highly vulnerable, especially in rural areas where 56 percent of the population, and 65 percent of the poor population, resides (World Bank Development Report, 2016). Benin also has poor human development outcomes, ranking 163th out of 189 countries on the United Nations Human Development Index (2017). 2. Benin’s economy is concentrated around agricultural production, informal transit trade to Nigeria and a few large formal enterprises. Most rural poor are smallholder farmers, cultivating maize and yams for their own consumption and selling cotton, oil-palm and fruits and vegetables as cash crops. Agricultural yields are low and below those of other countries in the region. Agricultural GDP growth has been the result of acreage expansion and increased labor effort as opposed to increases in productivity through the use of improved inputs and technologies. Benin also has a large and growing informal economy linked to the transit of goods to and from Nigeria by land and water. Economic growth in Benin has also shown to be negatively impacted by political cycles, with economic performance declining in 2005, 2010 and 2015 (during election periods). 3. Since 1991, transitions of power have been peaceful during and following each election. In 2016, the newly elected President adopted an ambitious reform program called “Programme d’Actions du Gouvernement, or Government Action Program (PAG) 2016-2021�, designed to improve the productivity and living conditions of the population. It should be noted that the Government of Benin (GoB) has affirmed its commitment to implementing the Sustainable Development Goals (SDGs) and has ensured consistency between these goals and the PAG. The program focuses, in large part, on improving human capital development. While the GoB has widespread support among citizens, expectations are high, and pressure is mounting to reduce high youth unemployment, accelerate economic growth, and improve the Jan 03, 2019 Page 3 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) quality of public services. In addition, the GoB faces political opposition to some of the proposed reforms in governance structures1. 4. Progress towards the education SDGs has been steady but attaining these will require more effort than in the previous decade. Improvement in the primary completion rate (PCR) has been slow in recent years (65 percent in 2005/06 vs. 71.3 percent in 2015/16) to put the country on track for achieving universal primary completion. Similarly, although there is progress on gender parity in lower secondary education, with the GPI increasing from 54.5 percent in 2005/6 to 68.4 percent in 2015/16, additional efforts are needed to achieve equal access for girls and young women to all levels of education. Both universal completion and gender parity are key parts of the SDG on quality education. Sectoral and Institutional Context 5. Benin’s general education system is divided into four levels: (i) a two-year preschool cycle for 4 and 5- year-olds; (ii) a six-year primary cycle beginning at age 6; (iii) a seven-year secondary education cycle, consisting of a four-year lower level leading to a college certificate, and a three-year upper level leading to a Baccalaureate diploma; and (iv) a higher education system that provides licenses2, masters and doctorate degrees (some private institutions provide 2-year certificate programs). Primary school enrollment and attendance are compulsory. 6. The education sector is managed by three ministries: (i) Ministry of pre- and primary school (Ministère des Enseignements Maternel et Primaire - MEMP); (ii) Ministry of Secondary Education, Technical and Vocational Training (Ministère de l’Enseignement Secondaire et de la Formation Technique et Professionnelle - MESFTP); and (iii) Ministry of Higher Education and Scientific Research (Ministère de l’Enseignement Supérieur et de la Recherche Scientifique - MESRS). The first two ministries each have 12 regional directorates. For the MEMP, at the decentralized level, there are 85 primary school districts consolidated into 45 sub-regional school inspectorates led by inspectors who are assisted by educational advisers. The number of students in the 2016-17 school year is about 2.3 million and 0.9 million in primary and general secondary schools respectively. Private schools’ students account for 23.2 percent and 17.2 percent in primary and secondary schools respectively. 7. The government has agreed on a new structure for basic education. In the new Education Sector Plan (ESP) 2018-30 developed collaboratively with Local Education Group (LEG) and approved by the Government in June 2018, a shift to having basic education encompass preschool to lower secondary with duration of 12 years in total (2 years in preschool, 6 years in primary school and 4 years of lower secondary school) is proposed. According to the ESP, basic education will also include non-formal basic education consisting of alternative education and apprenticeship schemes for pre-professionalization. 8. In terms of resource allocation, the Government’s commitment to education has been strong. From 2010 to 2015, the national budget allocated to the education sector rose from 189.7 billion to 225.6 billion CFA francs (at constant prices of 2015), representing an increase of 19 percent. Total expenditures (recurrent and capital) for education have averaged 28 percent of government expenditures (excluding debt service). Education recurrent expenditures have represented on average 32 percent of the total government recurrent expenditures excluding debt service from 2010 to 2015, well above the 20 percent recommended by the international community and that of other Economic Community of West African States (ECOWAS) 1 His proposals to reform Benin’s political model to increase accountability and transparency (included within the PAG) were rejected by parliament in April 2017. 2 Equivalent to a Bachelor’s degree. Jan 03, 2019 Page 4 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) countries, which spend an average of 25 percent of their current non-debt service expenditures on education. This priority given to education is in line with the commitments made in the Ten-Year Education Plan, 2006-15 (Plan Décennal de Développement du Secteur de l’Education – PDDSE 2006-153). Despite the substantial budget allocation, as a percentage of GDP, GoB’s expenditures on education, which were stable at 4.6 percent from 2010 to 2013, declined to 4.3 percent in 2015. 9. In total education expenditures, recurrent expenditures are predominant. Over the 2010-2015 period, recurrent expenditures accounted for an average of 94 percent of total expenditures against an average of six percent for domestically financed investment expenditures. Within recurrent expenditures, staff expenditures are the largest item and represent an average of 74 percent over the period. 10. Donors continue to contribute to reducing financing gaps in the sector. All donor interventions are aligned to support the Government’s program. The contribution of each donor to the ESP 2018-2030 is in the Annex 4. 11. The PDDSE (2006-2016) provided a framework for achieving selected education outcomes, using a common set of measurable benchmarks to track progress. After ten years of implementation of the PDDSE (since 2005/2006), tangible progress has been made in increasing access to basic education as shown in Table 1 below. Table 1: Evolution of GER and Completion Rate in basic education (in %) from 2005 to 2016 Gross Enrolment rate (GER) Completion rate 2005/06 2010/11 2015/16 2005/06 2010/11 2015/16 Preschool 3.7 11.6 15.6 Primary school 95.4 114.5 115.4 66.8 69.6 71.3 Lower secondary school 43.6 62.9 70.0 27.5 40.8 44.4 Source: Statistical yearbooks of MEMP and MESTFP for the period 2006 to 2016 -Benin 12. The PDDSE was endorsed by local partners and was supported with two Global Partnership for Education (GPE) grants pooled with other donors’ funds. The two grants were signed in April 2008 and March 2014 in the amounts of US$76.1 and US$42.3 million, respectively and pooled with contributions from other partners: (Danish International Development Agency (DANIDA), Agence Française de Développement (AFD), the German Development Bank (Kreditanstalt für Wiederaurfbau -KFW) and The Netherlands for the first grant; and AFD and KFW for the second grant). The second grant contributed to a pooled fund called Common Budgetary Fund-Global Partnership for Education (Fonds Commun Budgétaire-Partenariat Mondial pour l’Education - FCB-PME). Education Sector Challenges Management 3Ten-Year Plan,adopted in 2006 (and updated in 2013). Jan 03, 2019 Page 5 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) 13. Governance and Administration of the education sector are poor, and inefficient. The following findings of the institutional and organizational audit of the education sector undertaken in 2011 are still valid today: (i) the heavy administrative structure paralyzes the sector and lowers staff morale; (ii) political decisions interfere too often with managerial decisions, and the extremely slow decision-making process reduces staff motivation; (iii) the division of sector roles and responsibilities across three Ministries, and the lack of coordination among them, limit adherence to and implementation of strategic directions for education policies; (iv) the distribution of roles and responsibilities in the administration is unclear and there is little accountability; (v) multiple staff changes do not encourage ownership and sustainability of actions; and (vi) effective instructional time is short despite an official commitment to 180 days/year in Benin, and absenteeism of teachers is high. In addition, although School-Based Management Committees (Comités de Gestion de l’Ecole Primaire - COGEPs and Comités de Gestion de l’Etablissement Secondaire - COGES) exist in most primary and secondary schools, their role is limited to monitoring disbursements of school budgets. 14. Management of teachers is weak largely due to inconsistency in teacher deployment. Government-paid teachers are not deployed according to need. For example, a primary school in Benin enrolling 300 students have between 2 and 10 teachers. The consistency in the number of students and teachers was evaluated at only 27 percent in 2015 (which is far below the African average of 67 percent). The lack of consistency in teacher deployment thus has a dramatic impact on the equity of schooling conditions. At the district level, the student-teacher ratios (not including community teachers) range from 44:1 in Grand Popo up to 116:1 in Kandi. Despite the political economy of teacher management, the reasons underpinning weak teacher management are not clear. 15. The monitoring and evaluation system generates information with delay. Basic statistical data systems are in place in the three ministries in charge of education. Education data is collected annually through a school census, supported by the Government budget. When available, the report is usually comprehensive because it includes information by region and district (commune) such as Gross Enrollment Ratio (GER), Net Enrollment Ratio (NER), PCR, student teacher ratio (STR), school infrastructure conditions, repetition and drop outs rate, etc. However, the annual reports are usually generated with delays averaging nine months after the end of the school-year, so that the system is unable to take full advantage of the information. 16. The monitoring of learning is very ad hoc, donor driven, and data is not used to guide policy and support schools. Monitoring of learning through the administering of regular learning assessments is not systematic and the initiative is always donor driven. Many learning assessments4 have been carried out since 2005 in key disciplines. However, the overall enabling environment for assessment activity in the country is still weak because policies, human and fiscal resources and the institutional setup are still inadequate to support assessment of learning outcomes in a sustainable way. In addition, though available to the MEMP, results of assessments are not used to review education policies and practices, in terms of (i) designing and implementing policies and programs to improve teaching and learning in classrooms; (ii) identifying lagging students so that they can get the support they need; and (iii) ensuring that low- performing teachers and schools receive adequate technical assistance and training and thus guaranteeing that all students have an equal opportunity to learn. 4 The ABE/Link (project financed by US AID) and Projet d’Appui à la Gestion de l’Education (PAGE) CM2 evaluations done in 2007; the PASEC evaluation done in 2005 and 2014; the FTI-FCB assessment in 2011 and the FCB-PME in 2017 Jan 03, 2019 Page 6 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) Access and Retention 17. Despite achievements in terms of increased access to education, significant challenges remain in both access and retention in primary schooling. Improvements in coverage unfortunately have not meant that all children and youth are able to access schooling in Benin. A survey in 2015 found that 25 percent of people aged 5 to 17 years never went to school while 5 percent who did attend, dropped out. A significant proportion leave before the end of primary school. The transversal schooling profile in Figure 1 below shows a gradual decline in access rates from grade 1 to the final year of lower secondary education, which reflects a real retention problem. For example, in 2015, the gross access rate to CI (Grade 1) was 140 percent, but the same indicator for CM2 (Grade 6) was only 73 percent. This illustrates that a lot of children do not reach the end of primary school and therefore have very little chance of acquiring the skills necessary to become and remain literate during their adult life. This situation is essentially linked to repetition and dropouts, which remain high in the Beninese education system. In primary education, average repetition remained almost stable between 2011 and 2015 at around 12 percent. The drop-out rate increased from 12.3 percent in 2011 to 13.2 percent in 2015. Because of this situation, it takes on average 9 and 6 years to produce a graduate in primary and lower secondary education, respectively; this situation causes the system to commit more financial resources to produce a graduate. In addition, the pace of improvement of the PCR for the nine years (73 percent in 2015 vs. 67 percent in 2006) is too slow to put the country on track for achieving universal primary education (UPE) by 2030 (Figure 1). According to the World Bank’s Human Capital Index (October 2018), in Benin a child who starts school at age four can expect to complete 9.3 years of school by her 18th birthday. However, factoring in what children actually learn, expected years of school is only 5.7 years. Figure 1: Transversal schooling profile Transversal Schooling Profile 160% 140% 120% 100% 80% 60% 40% 20% 0% CI CP CE1 CE2 CM1 CM2 6eme 5eme 4eme 3eme 2nde 1ere Tle 2005-06 112% 97% 92% 80% 75% 66.8% 61% 38% 31% 27.5% 17% 13% 11% 2010-11 134% 115% 108% 98% 81% 69.6% 53% 51% 45% 40.8% 30% 26% 19% 2014-15 140% 112% 103% 93% 84% 73% 66% 54% 48% 45.3% 31% 27% 27.8% 2005-06 2010-11 2014-15 Source: Sectoral note of education 2017. Jan 03, 2019 Page 7 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) 18. Enrollment and retention among children with disabilities is even lower. Out of the estimated 26, 355 people with disabilities aged 5 to 24 years (2013 national census), fewer than 7 percent were enrolled in school in 2017. 19. There are persistent and considerable geographic and social disparities in the provision and quality of primary education services. The 12 regions of the country can be classified into four groups as shown in the map in Annex 7 with regards to Gross Intake Rate (GIR) and Primary Completion Rate (PCR). The first group includes the Alibori region where the primary GIR (35 percent) and PCR (24 percent)5 are particularly low. The second group includes the Atacora and Borgou regions, which have an average primary GIR of 68 percent and a PCR of 56 percent and 47 percent, respectively. The third group is comprised of Atlantique, Collines, Couffo, Donga, Plateau and Zou regions, where the primary GIR is between 80 and 90 percent and the PCR between 56 and 65 percent. The fourth group includes the regions of Littoral, Ouémé, and Mono, which had a relatively high primary GIR of 97 percent and a high PCR of 73 percent. According to the 2016 statistical yearbook, there are 20 deprived school districts (of which all 6 districts of Alibori region and 5 out of 8 districts of Borgou region) where the PCR is below 50 percent (see map in annex 7). For example, in the Alibori region, the PCR was 36 percent in 2016/17 vs. 114 percent in Atlantique region and 81 percent in Littoral region. 20. The gender gap widens as students move through the education system. Although the difference in enrollment rates and completion rates between boys and girls at the primary level is relatively small (PCR is 66 percent for female vs 71 percent for male), the gender gap widens as students move through the education system, with girls’ enrollment consistently lagging behind that of boys. Inde ed, while the intake rate for girls is 62 percent and 70 percent for boys in Lower Secondary Education (LSE), completion rates are only 39 percent for girls and 51 percent of boys. The difference between girls and boys becomes more pronounced in upper secondary education (USE) where girls’ enrollment rates are no more than 18 percent in the last grade (Terminale) against 37 percent for boys. Quality of education 21. Learning outcomes are low at the primary level. Most primary school students do not have the minimum learning outcomes in the core disciplines (French and Mathematics6), particularly in the early grades. The regional assessment for Francophone countries or Programme d’Analyse du Secteur de l’Education de la CONFEMEN (PASEC) carried out in the 2013-14 school year shows that: (i) only 6.3 percent of second grade students (CP) had the minimum competences required in French language and only 33.5 percent were above the threshold in Mathematics; and (ii) 51.7 percent of sixth grade students (CM2) had the minimum competences required in French and 39.8 percent in Mathematics. Consequently, Benin was ranked penultimate among the 10 countries7 evaluated for grade 2. By contrast, at the end of primary education (CM2), Beninese students were better ranked: 3rd in French and 4th in Mathematics among the same 10 countries evaluated. However, progress in Mathematics in grade 6 is considered insufficient for students to fruitfully partake in LSE. The World Bank’s Human Capital Index shows that Benin’s harmonized test score8 is 384 while the neighboring countries scored the following: Burkina Faso 404, Togo 384, Niger 305, Ghana 308, and Nigeria 329. 5 The source for access rates used here is EMICOV 2015. 6 PASEC assessments are limited to two core disciplines: French and Mathematics 7 Benin, Burkina, Burundi, Cameroon, Congo, Cote d’Ivoire, Niger, Senegal, Chad and Togo 8 This is on a scale where 625 represents advanced attainment and 300 represents minimum attainment. Jan 03, 2019 Page 8 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) 22. National exam results confirmed that student learning is low in reading/written expression and mathematics, both of which are core disciplines. For example, analysis of the results of the 2015 Primary School Certificate (Certificat d’Etudes primaires – CEP) exam shows that, while the official pass rate was 86 percent, only 32.5 percent of students who successfully passed the exam obtained the average score in reading; the average scores in written expression and mathematics were only 43.8 percent and 36.7 percent, respectively. The situation is similar in secondary education. The results of the 2015 exam for the LSE Certificate (Brevet d’études du Premier Cycle – BEPC) by discipline was very low (less than 50 percent), and extremely low in the scientific disciplines (Mathematics and Life and Earth Sciences), where pass rates did not exceed 10 percent. For the Baccalaureate exam (exam at the end of USE), results have varied over time – ranging from between 23.7 percent and 37.2 percent over the 2010-2016 period, indicating that the quality of education at all levels needs to be significantly improved. 23. Low learning outcomes may be explained by, among others, the following factors, each of which is described in further detail below: ✓ Increased enrollment rates have led to overcrowded classrooms and have contributed to worsening learning conditions; ✓ Limited content knowledge of teachers at entry; ✓ Limited pedagogical skills of teachers; ✓ Outdated and inadequate curricula particularly at the LSE level; ✓ Inadequate impact of in-service trainings on teacher performance; ✓ Insufficient support to teachers from educational advisers and inspectors; and ✓ Weak management and governance of the sector as mentioned above. 24. The learning environment in post-primary education is deteriorating. Increasing primary enrollment coupled with improvements in the PCR has resulted in increased numbers entering higher levels of education. Since the expansion of access has not been accompanied by a proportional increase in public infrastructure and inputs, particularly for post-primary education, there has been a decline in the learning environment in schools, including a significant increase in class size (and student-teacher ratio) and the use of temporary teachers (who are often less qualified), and a lower level of public spending per student, etc. At the secondary education level, most of the teaching hours are covered by temporary teachers9 (given the insufficient number of government-paid teachers10): in 2015, government-paid teachers covered only 25.6 percent and 25.4 percent of the teaching time in lower and higher secondary education, respectively. To reverse this situation, particularly in primary education, the Development Policy Operation (DPO) series for the period 2018-2020 underway with the Government will trigger “recruitment of teachers�. The number of teachers to be recruited is about 3,600 teachers in the coming years. 25. The subject matter knowledge of teachers in the courses they are required to teach is very weak. As part of the teacher training program financed by the recently closed GPE project, in 25 districts, beneficiary teachers’ linguistic skills (grammar, conjugation, spelling, vocabulary) were evaluated. A little over half of the teachers participated in the specific evaluation carried by the MEMP. Only 33 percent of those teachers 9 Temporary teachers called “vacataires� have a maximum weekly hour load of 9 hours that can be completed in 2 secondary schools. This rule was put in place to prevent their claim from changing their status to contract teachers after a few years of service. 10 Government paid teachers include civil servants and contract teachers. In education sector there are no significant difference between civil servants and contract teachers. In other sectors, the contract may be suspended at the end of the stated period. Jan 03, 2019 Page 9 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) who participated had a minimum score of 10 out of 20 questions, and 27.2 percent answered fewer than 6 out of 20 questions correctly. 26. The 2015 final exam in the Primary Teacher Training Institute (Ecole Normale d’Instituteurs - ENI) identified a number of issues pointing to limitations in the curricula and the review of the entry profile. An analysis of the exam results (including in the 2017 Education Country Status Report) found: (i) a low pass rate in dictation11, ranging from 4 percent for the student teachers preparing the First Teacher Certification (Certificat Elementaire d’Aptitude Pédagogique-CEAP) to 23 percent for those preparing the Second Teacher Certification (Certificat d’Aptitude Pédagogique-CAP); and (ii) around half of the student teachers preparing for the CEAP could not correctly answer the dictation questions, indicating that by the end of training at the ENI, most student teachers do not have the ability to understand grade-level text suitable for each certificate stage. Considering this situation combined with the weak subject content knowledge of the majority of teachers, the MEMP has decided to review the entry and exit student teacher profiles together with the ENI benchmarks and curricula. 27. Teachers’ pedagogical skills are limited. As part of the recently closed GPE project, three rounds of classroom observations with reliable tools were carried out in 2016 and 2017 to assess teacher practices and abilities to promote learning in classrooms. The key findings were that: (i) most teachers use a "question and answer" method more than the "problem solving" method of instruction; (ii) most teachers lack knowledge of disciplinary procedures (how to effectively teach subjects in the curriculum) regardless of the teaching method used; (iii) multi-grade classes were particularly difficult for teachers to manage; (iv) effective time spent on learning was significantly reduced by poor time management; and (v) the instruction was rarely adjusted to the needs of the students. 28. The primary curriculum is dense, and the first findings of the LSE curricula evaluation suggest reducing the scope. An evaluation of the competency-based curricula12 in primary schools concluded that the curricula were too complex and teachers, who are not well trained, cannot effectively teach all of the content as currently presented. A deeper analysis of the learning outcome issue, particularly in the primary school early grades, confirmed that (i) early grade fundamental reading competencies are very low (PASEQ 2014 and National Assessments 2018); (ii) programs of French (both in teaching and reading the French language) and Mathematics, including student textbooks and other materials, are too dense and too ambitious for the early grades, not corresponding to the profile and needs of students; (iii) teacher guides are too dense, complex, opaque and not explicit, making it difficult for most teachers to understand and use them; and (iv) a systematic early grade reading instruction, based on phonics, including the immersion period (in grades 1 and 2), is, for the most part, poorly carried out by teachers in classrooms, because of a lack of appropriate training on Early Grade Reading and numeracy instruction. The evaluation recommended simplifying the curricula along with the teacher guides with urgent action in early grades considering the very low learning outcome. In LSE, competency-based curricula have been implemented for more than 10 years and are being evaluated in view of the poor results at the level of learning outcomes. The first findings show the urgency of revising the existing French, Mathematics and English curricula, in order to reduce the scope and better focus on the fundamental knowledge and competencies to be acquired by all students at this level of education. 11 School exercise of spelling and grammar 12 The competency-based approach is a teaching strategy that allows students to acquire long-lasting skills that can help them in their education and daily life. Jan 03, 2019 Page 10 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) 29. The impact of in-service training is weak. In-service training for primary school teachers took place through two channels: (i) group training in each District Education Office; and (ii) support and training at the level of pedagogical units that covers an average of five schools in which some 30 teachers gather twice a month. Throughout the previous GPE project, many sessions of in-service training were provided to all teachers of deprived districts supported by the project, but these were not reflected in the learning assessment carried out in 2017. A deeper analysis of these training sessions revealed that they were too theoretical and not focused on (i) specific methodologies that allow teachers to tackle the learning needs of classes; (ii) how to design lesson plans and pace activities to keep students engaged; and (iii) how to assess student progress continuously and target help to students falling behind. In addition, the pedagogical units did not operate properly because: (i) topics developed cannot immediately be used by all teachers (for example, topics developed for grade 1 and 2 teachers will not be immediately implemented by the teachers of other grades) and (ii) sessions were not compulsory. Furthermore, head teachers were not trained to coach teachers under their supervision. 30. Classroom visits and remediation training for teachers are insufficient. The number of educational advisers and inspectors in basic education is low13. The decision by the MEMP to use partially retired pedagogical staff has not been approved by the teachers’ union, despite the high ratio of teachers to pedagogical support staff14 (about 180:1). In addition, resources allocated to School Inspectorates are insufficient to provide effective support to teachers. Many teachers teach for several years without a visit from an inspector or educational adviser. Further, remediation training for selected teachers with pedagogical shortcomings, as determined by classroom visits, are limited. 31. Finally, at the lower secondary level, it should be noted that a bilateral partnership through the French Development Agency (Agence Française de Développement – AFD) supports an LSE reform called "reform of colleges". The ongoing reform recommended creating small size lower secondary schools close to the communities. A prerequisite to achieve this goal is training teachers to teach two subjects, which involves reform in the Secondary Teachers Training Institutes (Ecoles Normales Supérieures - ENS). Relevance to Higher Level Objectives 32. The proposed project is closely aligned with the 2019-2023 Country Partnership Framework (CPF) and contributes to the development of human capital by improving the quality of student learning, reducing regional disparities and developing education services. The proposed project will contribute directly to the 2019-2023 CPF’s strategic Focus Areas 2 “building human capital�, one objective of which is to improve relevance of education and professional training for strengthened job creation. The first step towards this CFP objective is to improve the quality of basic education. The Project will contribute to human capital development by providing better quality public education services and improving equity for children in the most deprived educational region as well as children with disabilities. It will also contribute to enhancing education service delivery by supporting capacity building of teachers for effective teaching practices and the monitoring of learning outcomes. 33. The project is aligned with the Education Sector Plan (ESP) 2018-30 endorsed by the Local Education Group (LEG) and approved by the Government in June 2018. This ESP which represents an integral 13 The number of inspectors and educational advisers at the decentralized level are 43 and 160 respectively. A pre-service training is underway for 17 inspectors and 50 educational advisers. 14 The pedagogical staff encompasses inspectors and educational advisers. Jan 03, 2019 Page 11 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) part of the broader Government vision for 2030 is built around the following four main priorities: (i) establishing a twelve-year universal basic education under SDG4 that aims at "ensuring inclusive and equitable quality education for all and promoting lifelong learning opportunities"; (ii) developing a vocational training system adapted to the needs of economic development in partnership with the private sector; (iii) improving the quality of teaching and learning; and (iv) developing more effective, efficient and inclusive governance. Strategic actions of the ESP include, among others: i) development and implementation of an integrated school feeding program; (ii) delivery of school kits to children from disadvantaged areas; (iii) development and implementation of a repetition and drop-out reduction strategy in basic education; (iv) development and implementation of a support program for school girls' education and training; (v) inclusion of children with disabilities and/or special needs in schools and (vi) review of pre- and in-service training systems for education sector stakeholders including but not limited to teachers, head teachers, trainers and supervisors, at all levels of the education system but mainly for basic education. C. Proposed Development Objective(s) 34. The Project Development Objectives (PDO) are to: (i) improve the quality of teaching and learning in basic education with an emphasis on the early grades; and (ii) strengthen equity in primary education, particularly in four regions of the country. Key Results D. Project Description 35. The proposed project, which will support the implementation of the Government’s ESP 2018-30, is a US$19.4 million Investment Project Financing Grant from the GPE. The resource of the proposed project may be pooled with other donors’ funds as in the two previous GPE projects if the donors wish to have pooled funds. The project comprises three components and includes a results-based approach using Disbursement Linked Indicators (DLIs). These DLIs include the GPE variable part (30 percent of the funding in accordance with the GPE guidelines) which will be disbursed based on results. After the DLIs have been achieved, the MEMP will use the DLI funds to support other activities under all three components. The results-based activities seek to establish incentives to carry out these activities that are critical to strengthen governance and administration of the education sector including management of teachers and institutional structure for systemic assessment of student learning. 36. The PDO-level indicators for improving the quality of teaching and learning in schools are: (a) Percentage of grades 1 (CI) and 2 (CP) primary teachers rated satisfactory by an external agency in the use of the new educational kit developed under the project15 (b) Percentage of students in grade 2 (CP) who attained defined minimum standards on national learning assessment tests in reading, total and of which % female (c) Percentage of students in grade 2 (CP) who attained defined minimum standards on national learning assessment tests in mathematics, total and of which % female 15 Classroom observation tools have been developed under the closed GPE project and successfully used for all primary grades in the deprived districts. This was used to estimate the targets. Jan 03, 2019 Page 12 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) 37. The PDO level indicators for strengthening equity in primary education, particularly in four regions of the country.are: (d) Improve intake rate in grade 3 in the deprived districts of Alibori and Borgou regions, total and of which % female. (e) Percentage of children with disabilities enrolled in primary school in Zou and Collines regions. Component 1: Improving the quality of basic education (US$ 12.0 million) 38. This component aims to improve: (i) the curricula to enhance the quality of basic education; (ii) teachers’ content knowledge and teaching practices in primary and lower secondary schools; and, (iii) the system of initial teacher training in teacher education institutions (ENI and ENS). Sub-component 1.1: Improving the curricula for a better quality of education (US$5.1 million) 39. The objective of this sub-component is to improve Primary and LSE level curricula in order to enhance students’ learning. 40. This sub-component will support: For Primary Education: (i) reviewing and revising French (Early Grade Reading and immersion) and Mathematics curricula for Grades 1 (CI) and 2 (CP), and supplemental teacher’s guides with lesson plans and student booklets and other materials for CI and CP with the assistance of technical experts; (ii) printing and distributing Early Grade Reading booklets for CI and CP, posters and supplemental teacher’s guides with lesson plans for CI and CP; and (iii) monitoring the implementation of teaching-learning materials in a classroom setting. For Lower Secondary Education: (i) reviewing and revising the French, Mathematics, physics and English curricula, and developing teacher’s guides for each of these subjects for all Grades; (ii) printing and distributing the curricula and the guides including their electronic form (flash drives, online) for all Grades; and (iv) monitoring the implementation of the revised curricula through teaching and learning materials in classroom situations. Sub-component 1.2: Improving teachers’ knowledge on curricula and teaching practices (US $6.4 million) 41. The objectives of this sub-component are to prepare, test and implement the changes in teacher training that aiming at improving teachers’ understanding of the new curricula, content knowledge and teaching practice skills in basic education, including management of time on task. It aims to contribute to higher effectiveness of in-service training and support for teachers, at CI and CP, and at LSE in view of improving student learning outcomes. The training and support programs will cover the entire country and will be closely monitored and reported through regular evaluations. This sub-component will support: 42. For Primary Education: (i) designing and testing grades CI and CP teacher training modules; (ii) training grades CI and CP teachers and school directors on Early Grade Reading and Mathematics instruction Jan 03, 2019 Page 13 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) programs; (iii) training school directors on coaching; and (vi) the data collection, consultant services and the dissemination of the evaluation of classroom teaching and learning practices. The overall implementation and monitoring will be included in the performance contracts of the Head of the Regional School Inspectorates (Chef de Region Pédagogique) and the departmental directorates. 43. In-service training program will cover (i) curricula content knowledge of French Early Grade Reading and Mathematics; and (ii) how to practically implement the Early Grade Reading and Mathematics Programs in the classroom and effectively use the teaching and learning materials (the supplemental teacher’s guide with lesson plans and student booklets for reading and other materials) developed in sub-component 1.1 for Early Grade Reading programs. 44. For Lower Secondary Education: (i) designing and testing training modules in French; Mathematics, Physics and English; (ii) training the discipline leaders on 4 modules (curricula, subject content, teaching/learning practices and coaching); and (iii) support school-based coaching. 45. In-service training program will cover (i) curricula of key subjects: French, Mathematics; Physics and English; and (ii) teacher’s guides prepared in the framework of the curriculum review (see sub-component 1.1). In-service training will focus on teacher’s guides in French, Mathematics, Physics and English developed in sub-component 1.1. Sub-component 1.3: Improving Initial Teacher Education (ITE) in teacher education institutions (US$ 0.5 million) 46. The objective of this sub-component is to strengthen the capacity of ENI trainers to better prepare future teachers towards the exit student-teacher professional profile. A prerequisite of the above will be a Government action to increase the number of ENI trainers through new recruitments to fill the gap identified in these institutions. 47. This sub-component will support: (i) revising the curricula of ENI and ENS; (ii) reviewing the entry and exit professional profiles of ENI and ENS student teachers; (iii) capacity-building of trainers and tutors of traineeships; (iv) additional equipment for the ENI and ENS resource centers; and (v) study tours of the ENI and ENS technical team. 48. For Primary Education: revise teacher education curricula in ENI focusing on including modules on Early Grade Reading and Early Grade Mathematics Instruction programs, as they are designed, implemented and revised during the life of the proposed project. 49. For Lower Secondary Education: a bilateral partnership through the AFD has been supporting an LSE reform called "reform of colleges". The reform has recommended creating small size lower secondary schools close to the communities. A prerequisite to achieve this goal is to train teachers for teaching two subjects. The implementation of this reform requires, among other things, a revision of the training program in ENSs, devoted to the initial training of secondary education teachers. Component 2: Improving equity in basic education ($3.1 million) Jan 03, 2019 Page 14 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) 50. This component aims to promote equitable access to schooling through support to (i) CI and CP students in public primary schools in the deprived districts of Alibori and Borgou regions; (ii) children with disabilities in the regions of Zou and Collines and children in specialized education and training centers. Sub-component 2.1: Promoting equity in the deprived districts of Alibori and Borgou Regions (US $1.7 million) 51. To encourage children, especially girls, to attend and stay in school by reducing household spending on education, the closed FCB-PME project provided school kits consisting of school supplies, other didactic materials (excluding textbooks), a school bag; and school uniforms to CI and CP female students in the 25 deprived districts in the country. In view of progress made in student enrollment in these districts, this intervention has been considered cost-effective in improving access to school. Given the limited resources of the project, it has been agreed with the LEG to focus this intervention in all the districts in the Alibori and 5 out of 8 districts in the Borgou16 regions, which are the two regions with the most deprived districts in the country. 52. The proposed project will finance the following in the deprived districts of Alibori and Borgou regions: (i) communication, awareness and mobilization campaigns to convey the benefits of education to village and religious leaders, villagers and parents in the communities and to better understand community needs; (ii) uniforms for all public CI and CP students; and (iii) provide incentives to primary schools with the greatest improvement in enrollment rates. 53. Due to limited resources of the project, the project will finance uniforms to all CI and CP students in public primary schools in the deprived districts of Alibori and Borgou regions, while UNICEF Benin will finance stationery and backpacks in these districts. Given the bottlenecks in the Government procurement process17 which did not allow the distribution of the school kits in due time during the implementation of the closed GPE project, the MEMP has decided to delegate this activity to UNICEF which has demonstrated its capacity to arrange the provision of the package consisting of uniforms, stationery and backpacks to students early at the start of the school-year. The distribution of school uniforms and school kits will start in year 2 of the project because this activity will use the DLI funds after the Year 1 targets have been achieved. 54. An information and awareness campaign in local languages on the importance of education will precede the distribution of the kits. The campaign will include (i) a communication strategy, including the development and implementation of an action plan and key messages including the information on the distribution of the school kits and textbooks; and (ii) the establishment of a partnership with community radio stations to convey the importance of schooling on the radio broadcast. 55. At the primary school level, it is also planned to provide incentives to schools with the greatest improvement in enrollment rates based on data collected during the school census and validated by the head of sub- regional school inspectorate (CRP). 16 All six districts in Alibori and five out of eight districts in Borgou are considered deprived (see map in the Annex 7). 17 This was mainly because before and after the bidding process, various clearances by the government were required. Jan 03, 2019 Page 15 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) Sub-component 2.2: Promoting the school integration of children with disabilities in the regions of Zou and Collines (US $ 1.4 million) 56. The pilot phase of the previous FCB-PME program, implemented by the NGO Equilibre Bénin through the component "School integration of 300 Disabled Children (ISEH)" in the Zou region showed tangible results in terms of improving school performances andthe life skills of beneficiary students, and brought positive change in student's perception of disability. The pilot phase will continue in Zou and will be expanded to Collines, (two adjoining regions which were under the same regional administration until two years ago), with specific support to specialized institutions for children with disabilities. This will contribute to the sustainability of the pilot’s achievements regarding the access and integration of students with disabilities in the school system and better coverage of students’ needs. 57. This sub-component will support in the Zou and Collines regions (i) community awareness and mobilization campaign on schooling for children with disabilities targeting opinion leaders, political and administrative officials, mass media, Parent Teacher Association (PTA), teachers and pedagogical advisory body; (ii) strengthening partnership among education stakeholders and improving teacher training and mentoring on inclusive education; (iii) medical consultations and care for children with disabilities; (iv) provision of school kits, specialized equipment and specific technical aids for children with disabilities18; (v) training for community facilitators and itinerant teachers; (vi) purchase of 2 buses to transport visually impaired children from and to schools; and (vii) system strengthening for implementation, coordination and monitoring of the teaching activities for the students with special needs, in both primary and lower secondary schools. In addition, children with a severe visual handicap in the project-targeted municipalities will be identified and enrolled in specialized schools in other regions with strengthened capacities by the project. Implementation of the above-mentioned activities will help to collect data on children with disabilities in the 2 regions. Lessons learned from the results of this sub-component will inform policy development and be shared with other countries. Component 3: Strengthening the delivery of education services (US $3.8 million) 58. The aim of this component is to strengthen the institutional capacity and the Monitoring and Evaluation (M&E) system. Specifically, the component will support: (i) capacity-building of Ministries of Education (MEMP and MESTFP), including M&E; and (ii) project management. Sub-component 3.1: Strengthening the capacity of the MEMP and MESTFP, and the M&E system (US $2.7 million) 59. This sub-component will support (i) grants to sub-regional inspectorates, linked to performance-based contracts (PBC) to improve teachers’ pedagogical support; (ii) electronic tablets to pedagogical advisers and inspectors to record data on-the-go19; (iii) capacity building for the monitoring of learning outcomes; (iv) building capacity of project implementation staff; (v) the full use of the first phase of the Education 18 This includes orthopaedical equipment, canes, tricycles, wheelchairs, orthoses, crutches, and glasses etc. 19 The Project Implementation Manual (PIM) will provide more details in the use of the tablets as well as the PBC grant, which will be annually audited by the MEMP’s directorate of general inspection. Jan 03, 2019 Page 16 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) Management Information System (SIGE), developed and supported by the recently closed GPE project; (vi) the extension of the SIGE to also cover secondary education; (vii) the data collection, analysis and production of statistical yearbooks for primary and secondary schools; (viii) the preparation and implementation of the necessary protocols/tools to strengthen the human resources management system in order to improve teacher deployment; (ix) the dissemination of existing studies in the sector. The PBCs aim to strengthen: (i) inspections’ impact on the overall quality improvement at the school level, including teachers’ pedagogical support, following inspectors’ and educational advisors’ class visits; (ii) incentives for school enrolment, especially for girls in communes where the GERs substantially deviate from the national average; and (iii) the repetition and drop-out reduction in both Primary and Lower Secondary Education. A performance/results-based contract will be signed by each head of the educational region as a recipient of a project grant. Within the framework of the PBC, each regional inspectorate will prepare a detailed action plan towards the achievement of the results set forth in the contract. Sub-component 3.2 Ensuring effective project management (US$1.1 million) 60. The objectives of this sub-component are to ensure the effective implementation of the daily operations of the project and to build knowledge and competencies to improve services delivery. Key activities related to project management include: project coordination, technical coordination, financial management, contracting processes, archiving data management and support to the secretariat. Finally, the project will support a study on the underlying challenges, opportunities, budgetary implications, as well as the strategy and implementation of the entire basic education according to the ESP covering pre-school, Primary and Lower Secondary Education, including non-formal education. E. Implementation Institutional and Implementation Arrangements 61. The project’s institutional and implementation arrangements build on the implementation of the recent closed GPE project with resources pooled with other donors’ funds. Due to the good collaboration between donors and the reduction of the number of transactions as well as the mobilization of all actors around the pooled fund program, resources of this proposed project can be pooled with those of donors’ funds. All project implementation arrangements are based on existing Government systems and procedures although some of these existing systems will be strengthened through the GPE project to improve their effectiveness. Therefore, the project’s activities will be implemented by the relevant ministries involved in the project. The responsible agency will be the MEMP with the Secretary General (SG/MEMP) as the responsible person and a Steering Committee will be set up to play the oversight and backstopping role. The SG/MEMP will work in close collaboration with the SGs of the MESTFP and MASMF. 62. The existing Technical Support and Monitoring Unit (Unité d’Appui Technique et de Suivi - UATS), which is a technical assistance provider as well as the day-to-day coordinator of the project, has experience of project implementation with the Bank’s procedures and standards. It will, notably, provide support to: (i) ensure that the grant resources are taken into account in the annual budgeted action-plan of the recipient’s ministries; (ii) reinforce planning, programming and budgeting of project activities; (iii) reinforce the project’s procurement, monitoring and evaluation and financial management aspects; (iv) prepare project’s reports; (v) facilitate internal and external; and (vi) carry out the evaluation and assessment of project activities. The UATS comprises: a coordinator, a financial analyst, and specialists in procurement, monitoring and evaluation, along with support staff. However, the procurement specialist has been recently Jan 03, 2019 Page 17 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) recruited as a civil servant and will be replaced by the approval of the project by the Bank Board of Directors. 63. At the operational level, apart from the UATS, the STP and the Disbursement and Procurement Monitoring Committee (Comité de suivi des décaissements et des Marchés - CSDM) will play an important role in the effective implementation of the activities. Their respective responsibilities are detailed in Annex 1. 64. Technical departments of the three ministries involved in the project will be in charge of the implementation of their respective activities. Under the authority of the Secretary General of the MEMP, the departments implementing the Project Components and Sub-components are described in Annex 1. Three Directorates will play a key role in coordination: (i) the National Institute for Training and Research in Education, for activities related to quality (component 1); the Directorate of Primary Schools (DEP) for activities related to equity (component 2); and (iii) the Directorate of Programming and Planning (DPP) for component 3 activities. 65. In each of the 12 regions, project activities will be coordinated by the regional directorates under the supervision of the Secretary General of each of the 3 ministries involved in the project. For primary schools, the Sub-Regional School Inspectorates under the supervision of the Regional Directorates will be the key entities for overseeing project activities and compiling the data supplied by the schools for M&E. 66. At the school level, the school head is responsible for all the project activities taking place in the school, including the distribution of students’ uniforms in primary schools and distribution of girls’ kits and textbooks in lower secondary schools. At the community level, the COGEPs and COGES, composed of representatives of parents, school staff and local resource persons will be in charge of supporting schools to deliver the agreed results, and to monitor and report on the functioning of schools. 67. The above arrangements are detailed in Annex 1 and will be complemented by the Project Implementation Manual (PIM), which describes how the project activities will be implemented. PIM also defines the relations, roles and responsibilities of each contributing unit or institution. Implementation will be guided by the approved PIM and the annually approved work program. . F. Project location and Salient physical characteristics relevant to the safeguard analysis (if known) The proposed project will cover the entire country. Due the nature and the scope of future investments, no particular safeguards matters were identified to date. G. Environmental and Social Safeguards Specialists on the Team Abdoulaye Gadiere, Environmental Specialist Gertrude Marie Mathilda Coulibaly Zombre, Social Specialist Jan 03, 2019 Page 18 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) SAFEGUARD POLICIES THAT MIGHT APPLY Safeguard Policies Triggered? Explanation (Optional) The project is composed of capacity building activities, improvement of the curricula to enhance the quality of basic education; awareness campaigns for bringing children with disability to schools; the Environmental Assessment OP/BP 4.01 No financing of stationery and backpacks in the targeted districts. So the planned activities under the project are associated with very minor adverse impacts both on environment and communities. Performance Standards for Private Sector No The project does not trigger this policy. Activities OP/BP 4.03 The project does not involve or affect natural Natural Habitats OP/BP 4.04 No habitats. Forests OP/BP 4.36 No The project does not involve or affect forests. Pest Management OP 4.09 No The project does not involve pest management. Physical Cultural Resources OP/BP 4.11 No The project does not trigger this policy. There are no Indigenous People as defined by the Indigenous Peoples OP/BP 4.10 No policy in the project areas. Involuntary Resettlement OP/BP 4.12 No .The project does not trigger this policy. Safety of Dams OP/BP 4.37 No The project will not finance dams nor rely on dams. Projects on International Waterways The project is not expected to affect international No OP/BP 7.50 waterways. Projects in Disputed Areas OP/BP 7.60 No The project will not be located in a Disputed Area. KEY SAFEGUARD POLICY ISSUES AND THEIR MANAGEMENT A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: Activities under the project are associated with very minor adverse impacts both on environment and communities. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: Not applicable 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. Not applicable 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower Jan 03, 2019 Page 19 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) capacity to plan and implement the measures described. Not applicable 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. Not applicable B. Disclosure Requirements C. Compliance Monitoring Indicators at the Corporate Level (to be filled in when the ISDS is finalized by the project decision meeting) OPS_ PDI_ COMP_TA BLE The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank for disclosure? NA Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups and local NGOs? NA All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been prepared for the implementation of measures related to safeguard policies? NA Have costs related to safeguard policy measures been included in the project cost? NA Does the Monitoring and Evaluation system of the project include the monitoring of safeguard impacts and measures related to safeguard policies? NA Have satisfactory implementation arrangements been agreed with the borrower and the same been adequately reflected in the project legal documents? NA CONTACT POINT Jan 03, 2019 Page 20 of 21 The World Bank Benin Global Partnership for Education Project Phase 3 (P167432) World Bank Yacinthe Gbaye Senior Economist Borrower/Client/Recipient Government of Benin Alban BESSAN General Director of Caisse Autonome d’Amortissement (CAA) besalbanos@yahoo.fr Implementing Agencies Ministry of Preschool and Primary Education Alain Dossou UNLEYI General Secretary of the Ministry of Preschool and Primary E ahluimadji@yahoo.fr FOR MORE INFORMATION CONTACT The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects APPROVAL Task Team Leader(s): Yacinthe Gbaye Approved By Safeguards Advisor: Practice Manager/Manager: Scherezad Joya Monami Latif 17-Apr-2019 Country Director: Pierre Laporte 18-Apr-2019 Jan 03, 2019 Page 21 of 21