KINGDOM OF CAMBODIA Nation Religion King National Committee for Sub-National Democratic Development Secretariat (NCDDS) Integration of Social Accountability into National and Sub-National Systems Project ID: P173527 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 14 February 2020 National Committee for Sub- National Democratic Development Secretariat (NCDDS) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NCDDS 1. NCDDS will implement the Integration of Social Accountability into National and Sub-National Systems Project, with the involvement of the following Ministries/agencies/units such as Ministry of Interior (MOI), Ministry of Education, Youth and Sport (MOEYS), Ministry of Health (MOH), Ministry of Public Works and Transport (MPWT), Ministry of Industry and Handicraft (MIH), Sub-National Administrations (SNAs) and civil society organizations. The International Bank for Reconstruction and Development/International Development Association (hereinafter the Bank) has agreed to provide financing for the Project, primarily through its Cambodia Social Accountability and Service Delivery Trust Fund (SASD-TF). 2. NCDDS will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out a summary of the material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. NCDDs will also comply with the provisions of any other E&S documents required under the ESF referred to in this ESCP and the timelines specified in those E&S documents. 4. NCDDS 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 by NCDDS as required by the ESCP and the conditions of the legal agreement, and the Bank will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank and NCDDS, 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, NCDDS will agree to the changes with the Bank and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the Bank and the NCDDS. NCDDS will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the NCDDS shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NCDDS RESPONSIBILE MATERIAL MEASURES AND ACTIONS TIMEFRAME ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Six monthly reports M&E Officer, NCDDS NCDDS will prepare and submit regular environmental and social monitoring reports as a section of the semi-annual project reports regarding compliance in accordance with the requirements of ESCP. B INCIDENTS AND ACCIDENTS Promptly after taking notice of the incident or HR Officer and reporting accident. through M&E Officer, NCDDS NCDDS will promptly notify the Bank of any incident or accident related or having an impact on the Project which has, or is likely to have, a significant Such a mechanism has already been developed adverse effect on the communities and workers. The following will be given by NCDDS and will be updated as required. Ref.: ultimate priority: OPP Manual, 2019.  A list of emergency phone numbers at national level and at site specific locations will be shared to relevant workers, and communities in order to access primary support when there has been an incident or accident.  NCDDS will notify the Bank within 24 hours of any incident or accident related to the project or that has an impact on its implementation, and that has or could have a significant impact on affected communities, workers including, for example, health accidents that could result in death or serious injury, cases of gender based violence or violence against minors, vehicle accidents and electrocution.  NCDDS will provide sufficient details regarding the incident or accident, and indicate immediate measures taken to address it following NCDDS’ HR policy. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NCDDS ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Team will be in place right after the project M&E Officer, NCDDS NCDDS will ensure staff with appropriate skills are in place to support project becomes effective and will be kept in place to E&S risk management, monitoring and reporting of incidents, including: follow up on results during project  National level team support will be coordinated by M&E Officer, implementation. monitoring accidents, incidents, and environmental and social standard compliance (in line with ESF) with assistance from consultants who support the project and facilitate with line ministries, Sub-National Authorities, and Civil Society;  At the sub-national level, the project focal person in each SNAs (Municipal/Provinces, Khan /districts, and commune/sangkat) will work closely with relevant stakeholders and NCDDS;  At the community level, the project will support community facilitators including volunteers and interns that will regularly monitor social risks and report on the project. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NCDDS ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES The OPP/SOP Manual has been developed and HR officer, NCDDS Labor and working condition provisions as per Standard Operating Procedures implemented under NCDD/RGC agenda. This (SOP) of the NCDDS OPP manual will be implemented for all direct workers. OPP/SOP will be reviewed prior to hiring any new These provisions include the following: workers (direct, contracted, intern, community  Labor management procedure under Labor law of Ministry of Labor and workers) for this project. Vocational Training of Cambodia, and NCDDS policy on Environmental and  Labor Law of 1997 Social Safeguards for Sub-national Democratic Development;  RGC ratified ILO C. 138, Minimum Age and  Management and responsibility for labor and working conditions between ILO C. 182, Worst Forms of Child Labor, and the employer and employee such as informed worker’s rights, ensuring MOSAVY Prakas (proclamation) No. 106 on safety and welfare, non-discrimination, equality, and equity, not constraining the rights and freedom, grievance mechanism, and the Prohibition of Children Working in preventing the exploitation of children and forced labor based on labor law Hazardous Places (28 April 2004). and child protection. The OPP/SOP will be reviewed to identify gaps to be met for meeting Bank requirements in particular for contractors, interns and community facilitators and provisions will be added if any gaps are identified. The SOP and any additional provisions will be implemented for this project. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS The grievance mechanism for workers for the project shall be implemented as The NCCDS OPP Manual is in place which may be HR Officer, NCDDS follows: required to update before hiring staff.  Independent contractor/consultant/Direct NCDDS policies and procedures will be used for Workers/internship/community facilitator have the right to submit direct workers, contractors, interns and complaints to NCDDS at the National level and Sub-national level; volunteers to ensure they are fully aware of, and  Project workers using the grievance mechanism will follow the NCDDS understand their rights before they start working on the project. OPP manual;  NCCDS will conduct orientation on its existing policies including worker grievance procedures with all project staff, contractors/sub-contractors, interns and volunteers to ensure that they aware of their rights and benefits before they sign their contracts. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NCDDS ESS 2: LABOR AND WORKING CONDITIONS 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES The review and amendment of existing M&E, HR, Officer, NCDDS NCDDS will review existing occupational, health and safety (OHS) procedures procedures will be undertaken for all categories and amend them to meet the required standards of the Bank, especially travel of workers to ensure that they well understand safety for workers. and are aware of them before they start work on this project. Measures will be implemented, in accordance with cambodian labor law (Kram March 13, 1997 Labor Code), NCDDS policy on environmental and social Once procedures are revised, they will be safeguards and Bank requirements and will address: implemented throughout the duration of the project.  Analyze and avoid any effects on health and safety of independent contractor/consultant Direct workers/internship/community facilitator during or after the project implementation;  Training of project workers and maintenance of training records;  Documentation and reporting of occupational accidents, diseases and incidents;  Training workers on road safety and monitoring the application knowledge;  Prepare for emergencies during the project implementation in case of any problems or accidents;  Safety and health considerations of workers and code of conduct. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NCDDS ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 INDIGENOUS PEOPLES ENGAGEMENT M&E Officer, NCDDS The protocol will be developed and in place prior Indigenous peoples because of their specific needs, require specific measures to commencement of any engagement activities to ensure they can benefit from the project implementation and in line with in communities where Indigenous Peoples are their lives, traditions and customs. The following practices must be performed. present A protocol for engaging with Indigenous Peoples will be developed to cover:  Invitations to indigenous people including their representatives or village chiefs, with sufficient advance notice, when conducting any training, workshops or consultations;  Ensure understanding and participation of Indigenous Peoples in project implementation;  The preparation of training at least has a community facilitator and an interpreter for Indigenous Peoples; participation of Indigenous Peoples will be encouraged for each Indigenous Peoples group. 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NCDDS ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT AND DISCLOSURE Continue to implement the annual cycle of M&E Officer, NCDDS The nature of the project is to ensure meaningful engagement of all groups, in public information, citizen engagement, civil particular participation from Indigenous Peoples, marginalised and vulnerable society, and action plan development and groups. implementation with citizens. 10.2 PROJECT GRIEVANCE MECHANISM OPERATIONS POLICIES AND PROCEDURES M&E Officer, NCDDS The project grievance mechanism as per the NCDDS policy on environmental MANUAL (OPP) 31 July 2019, and Environmental and social safeguards includes the following: and Social Safeguards for  Civil society engagement where stakeholders can submit complaints Sub-National Democratic Development (ESS) 31 through verbal comments to Community Accountability Facilitators May 2019 are The Grievance mechanism as per (CAFs), NCDDS, or any public forum where there is participation from the NCDDS policy on environmental and social citizen, civil society and stakeholders; safeguards will be implemented throughout the  Civil society engagement where stakeholders have the right to submit a life of the project. complaint to ombudsman officer at sub-national level (i.e. province or district);  Civil society engagement where stakeholders have the rights to submit a complaint to the project technical team at sub-national level. Project team will record and review all complaints received at project quarterly meetings;  Civil society engagement where stakeholders have the right to submit a complaint directly to the Partnership Steering Committee (PSC). 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NCDDS CAPACITY SUPPORT (TRAINING) CS1 Training will be provided to all NCDDS staff, consultants and Training to subnational authorities on E&S M&E officer, HR officer, NCDDS volunteers and the curriculum will be reviewed to ensure all relevant policy and specific topics, continuously policies are covered and adequate. throughout the project timeline All relevant stakeholders (staff, contractors, volunteers and interns will receive training at the beginning of the project or on signing their contract. Refresher training will be conducted regularly, at least every year or as required by safeguard officers. This training will include the following aspects:  NCDDS E&S Policy  Training on project grievance mechanism for workers  Training on road safety and application knowledge  Training on stakeholder engagement including indigenous people and most vulnerable groups  Training on stakeholder engagement and disclosure  Policy on Incident Reporting 9|Page