RWANDA QUALITY BASIC EDUCATION FOR HUMAN CAPITAL DEVELOPMENT PROJECT: P177883 Draft UPDATED ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) FOR SECOND ADDITIONAL FINANCING March 25 2022 1|Page MINISTRY OF EDUCATION PROJECT: QUALITY BASIC EDUCATION FOR HUMAN CAPITAL DEVELOPMENT IN RWANDA –P177883 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Ministry of Education (MINEDUC) is implementing the Rwanda Quality Basic Education for Human Capital Development Project (the Project), with the involvement of the following Ministries/agencies/units: Ministry of Finance and Economic Planning, Ministry of Local Government (Districts), Rwanda Basic Education Board, University of Rwanda-College of Education and RDB. The International Development Association (IDA) has agreed to provide financing for the Project. 2. The Ministry of Education is implementing material measures and actions so that the Project is being implemented in accordance with the World Bank (WB) Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out a summary of the material measures and actions. 3. The Ministry of Education will also comply with the provisions of any other E&S documents required under the ESF and referred to in this updated ESCP, such as Environmental and Social Management Plans (ESMP), Environmental and Social Management Framework (ESMF), Resettlement Action Plans (RAP), and Stakeholder Engagement Plans (SEP), that will be updated or developed for the project and the timelines specified in those E&S documents. 4. The table below summarizes the material measures and actions that are required as well as the timing of the material measures and actions. The Ministry of Education is responsible for compliance with all requirements of the updated 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 updated ESCP will be monitored and reported to the World Bank by the Ministry of Education as required by the ESCP and the conditions of the legal agreement, and the World Bank will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the WB and MINEDUC, this updated ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, the MINEDUC will agree to the changes with the WB 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 WB and the MINEDUC. The Ministry of Education will promptly redisclose the updated ESCP. Depending on the project, the updated 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 Ministry of Education shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. 2|Page Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed REGULAR REPORTING: Prepare and submit regular environmental and social monitoring Quarterly (every 3 months) and MINEDUC/SPIU, reports on environmental, Social, Health and Safety (ESHS) annually, throughout the project Schools & Districts, performance of the project implementation, stakeholder engagement implementation. Contractors. activities and grievances redress mechanism including the activities under additional financing, in accordance with legal agreement, Monitoring costs to including the requirements of ESCP, and ESSs. be incorporated in the overall project More elaborates aspects of monitoring and reporting will be provided June 2022 management costs. in ESIA, and RPF and the updated ESMF. Recruitment and GEMS data collection has been used for the under-parent project to operation of the collect data at school construction sites in order to track the progress required staff will of the school construction activities as well as their compliance with be financed under Environmental and Social Standards of the World Bank and Rwanda project management Environmental regulation. and implementation GEMS data collection will continue to be used in the monitoring of (component 3). AF activities and MINEDUC/PIU staffs are familiar with it. 3|Page Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed INCIDENTS AND ACCIDENTS NOTIFICATION The following will be given ultimate priority: ✓ Notify within 24 hours any incident or accident related to the Any incident or accident shall Contractor. project or that has an impact on it, and that has or could have a be notified immediately after Districts significant adverse effect on the environment, the affected occurrence. Fatalities will be MINEDUC/SPIU communities, the public, or the workers including, but not reported within 24 hours after limited to, any , any allegations of gender-based violence occurrence. Implementation and/or sexual exploitation, abuse and harassment (GBV/SEA- funding to be part HS), Project-related work-related accidents or fatalities, of the EMPs worker strikes, and social unrest. budgets ✓ Provide sufficient details of the incident or accident, indicating the measures taken or to be taken to address it and all the information made available by any contractor, supplier or service provider and by the supervising entity, as applicable”. ✓ Provide sufficient details regarding the incident or accident, and indicate immediate measures taken to address it. ✓ A report of the incident shall be submitted, detailing summary findings of the Root Cause Analysis (RCA) ✓ An incident register shall be maintained at all construction sites, throughout the duration of the works. 4|Page Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed 1.1 ORGANIZATIONAL STRUCTURE: Run a functional organizational structure with qualified staff to All staff should be in place by MINEDUC/SPIU, support management of E&S risk management. Environment effectiveness, including the Safeguard Specialist and Social Specialist have been recruited at the recruitments of the MINEDUC/PIU level and 15 E&S recruited at District level. Environmental Safeguard (Currently, the MINEDUC PIU structure is not fully staff and is Specialist and the field based 9 missing the Environmental Safeguard Specialist and the field based 9 Environmental and Social Environmental and Social Safeguard Officers) Safeguard Officers before effectiveness. The environmental and social management issues in MINEDUC and Maintained as necessary its implementing partners will be handled by MINEDUC Safeguard throughout Project MINEDUC Team under supervision of Project Coordinator in the Ministry of implementation. Education. Appoint focal person from MINEDUC/PIU staffs assigned to support By June 2022 PIU on social issues such as disability inclusion and GBV 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT: Carry out specific environmental and social assessment, in accordance Implementation: whole life of MINEDUC/SPIU with existing legal instruments related to Environmental Impact the project. Consultants Assessment, to identify and assess the specific environmental and social risks and impacts of the project and appropriate mitigation measures. The following have been prepared by the Parent Project and are guiding the project implementation: - Resettlement Policy Framework (RPF) that will be updated to ESMF updated by effectiveness. accommodate the potential environmental and social risks and 5|Page Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed impacts of the AF - Environmental and Social Management Framework (ESMF) (and the ESMF will be updated to accommodate the potential environmental and social risks and impacts of the AF) - Prepare Environment and Social Impact Assessment (ESIA/ESMP) and seek Rwanda Development Board (RDB) EIA or ESMP clearance before the start of civil works - All subprojects associated with the works (new classroom construction, rehabilitation, new school construction, toilet facilities, water points etc) must be systematically screened from both environment and social standpoint. The ESMF will be updated to accommodate the potential environmental and social risks and impacts of the AF. 1.3 MANAGEMENT TOOLS AND INSTRUMENTS: There will be development and implementation of specific In place already by the Parent MINEDUC/SPIU, environmental and social management plans based on the particularity Project. June 2022 for TTCs District & Schools of each site considering existing environmental features. Once and Model Schools. prepared, the plans will be prepared and cleared prior to commencement of works, throughout Project implementation. The following tools, incorporating management related to the AF, will be updated before approval and implemented: OHS management plan Implementation: whole life of Labour Management procedures the project. Site rehabilitation plan Grievance management plan ESIA/ESMPs for retaining walls and water tanks Screening tool for all subprojects. 6|Page Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed 1.4 MANAGEMENT OF CONTRACTORS: The project implementation will involve implementing partners such Development of procedures are MINEDUC/SPIU as districts and respective schools. To ensure coordination for already in place, check and REMA successful implementation of the project, the Ministry of Education update or confirm if needed Districts will establish measures which include, but not limited to: before approval by effectiveness. a) Assessment of the environmental and social risks and impacts associated with contracts of suppliers. Implementation: whole life of b) Ascertain that implementing partners have adequate human the project. resource with knowledge and skills to perform their project tasks in accordance with their commitments. c) Incorporate all relevant aspects of the ESCP into tender documents. d) Officially require implementing partners to apply the relevant aspects of the updated ESCP and the relevant management tools. e) Monitor implementing partners and their associates’ compliance with their commitments; f) Require implementing partners to have equivalent arrangements with their subcontractors. g) All implementing partners to have Environment and Social Staff h) Ensure that GBV code of conduct are included in service providers tender documents in accordance with national laws and the bank ESF requirements. 1.5 PERMIT, CONSENTS AND AUTHORIZATIONS: Obtain or assist in obtaining, as appropriate, the permits, consents and ESIA Certificate: before the MINEDUC, RDB, authorizations that are applicable to the Project from relevant national commencement of construction Contractors and authorities. works subject to ESIA. Districts Prior to the commencement of any construction activities, the Ministry Other permits, consents and 7|Page Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed shall obtain an Environmental and Social Impact Assessment authorizations: before Certificate from the relevant authority; building permits from One commencement of related Stop Centers in their respective District, and any necessary permits, project activities. consents and authorizations for contractors, in accordance with relevant laws. All suppliers of raw materials such as sand, stones, bricks, timber and Implementation and compliance: other relevant construction should be authorized sites with legal throughout the project life documents to operate. Comply or cause to comply, as appropriate, with the conditions established in these permits, consents and authorizations throughout Project implementation. 1.6 THIRD PARTY MONITORING: ✓ Monitoring of environmental and social hazards and their impacts Continuous throughout the MINEDUC/SPIU, on the project-affected communities and workers will continuously project period REMA, be monitored by Rwanda Environment Management Authority Contractors, (REMA), to ensure effective compliance in accordance with ESIA Districts, Sectors conditions of approval. ✓ Regular inspections will be done by other relevant Institutions/One stop Centers to monitor and make sure that the project is complying with national buildings codes. ✓ Concerned local government authorities shall carry out routine According to their routine monitoring and inspection to ensure comprehensive compliance in monitoring and inspection accordance with Environmental, social and health aspects of the plan: project to the community. 2.1 LABOR MANAGEMENT PROCEDURES: Implement the updated LMP for the AF 8|Page Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed The labor management procedures shall be done through the following Update LMP by June 2022. MINEDUC/SPIU, actions: Contractors, - Avail information to workers regarding their terms of employment. Continuous throughout the Districts The information will set out their rights under national labor and project period employment law, including their rights related to hours of work, wages, overtime, compensation and benefits; - Provide workers with adequate periods of rest per week, annual holiday and sick leave, as required by national law; - Ensure Non-Discrimination and Equal Opportunity in the project; - Set out measures to prevent and address harassment, intimidation and/or exploitation in human resources policies and procedures; - Ban the use or support of child, forced or compulsory labor. - Works should have signed contracts with clear terms as per the Rwanda Labor law and the LMP. - Ensure the signing of contracts and Codes of Conduct by the contractors, in accordance with LMP guideline. - As it has been done during the implementation of the parent project, People with disabilities will be employed as well in the implementation of AF and they will be given tasks that correspond to their capacity. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: The process or procedure to receive and facilitate resolution of The AF will use the established MINEDUC/SPIU, stakeholders’ concerns and grievances regarding the environmental GRM of the parent project to Contractors, and social performance will respect the following: handle and resolve all project Districts related complaints throughout ✓ The grievance mechanism will be scaled to the risks and implementation. potential adverse impacts of the project. ✓ Where possible, grievance mechanism will utilize existing formal or informal grievance mechanisms suitable for project 9|Page Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed purposes. ✓ The Grievance mechanism, process or procedure shall address concerns promptly and effectively, in a transparent manner that is culturally appropriate and readily accessible to all segments of the project-affected communities, at no cost and without retribution. ✓ The mechanism, process or procedure will not prevent access to judicial or administrative remedies. ✓ The project-affected communities will be informed about the grievance process in the course of its community engagement or stakeholders’ engagement activities, and will make publicly available a record documenting the responses to all grievances received. ✓ Handling of grievances will be done in a culturally appropriate manner and be discreet, objective, sensitive and responsive to the needs and concerns of the project-affected communities. 2.3 OHS MEASURES: Update the Occupational Health and Safety (OHS) of the parent project to reflect the activities of AF. The relevant OHS provisions in the General EHSGs will be applied to Update by effectiveness as part MINEDUC/SPIU, the project, and this requirement will be set out in the legal agreement of ESMF update Contractors, District and the updated ESCP. Funded under the Measures will be designed and implemented, in accordance with EMPs budget national law and the EHSGs, to address: Throughout the execution of the ❖ Identification of potential hazards to project workers, particularly project. those that may be life-threatening. ❖ Provision of preventive and protective measures, including 10 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed modification, substitution, or elimination of hazardous conditions or substances; ❖ Training of project workers and maintenance of training records; Documentation and reporting of occupational accidents, diseases and incidents; ❖ Emergency prevention, preparedness and response arrangements. Applicability and Approach: ✓ Employers and supervisors are obliged to implement all reasonable precautions to protect the health and safety of workers. ✓ The contractor will hire a technical staff capable to manage the occupational health and safety issues of their employees, ✓ Preventive and protective measures will be introduced according to OHS management plan Prevention of COVID-19 Project staffs and supervisor to ensure that all workers are in good Throughout project health condition and in case of COVID-19 pandemic symptoms to implementation MINEDUC notify the authority and other organs in charge of public health. 2.4 EMERGENCY PREPAREDNESS AND RESPONSE: As part of the OHS measures specified in 2.3, include measures on Prior to initiating construction. MINEDUC/SPIU, emergency preparedness and response, and ensure coordination with Maintained throughout Project Contractors, measures under 4.5. implementation. Districts ✓ Measures to address incidents will be identified and designed to Funded under the prevent unanticipated incidents from injuring the health and safety EMPs budget of the affected community, and to minimize, mitigate and compensate for any impacts that may occur. The following measures will be put in place; 11 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed ✓ Carry out the Risk Hazard Assessment (RHA), as part of the Environmental and Social Assessment; ✓ Prepare an Emergency Response Plan (ERP) in coordination with the relevant local authorities and the affected community. The emergence Preparedness and Response will include: - engineering controls (such as containment, automatic alarms, and shut-off systems) commensurate with the nature and scale of the hazard; - identification of and secure access to emergency equipment available on-site and nearby; - notification procedures for designated emergency responders; - Training program for emergency responders including drills at regular intervals; - Public evacuation procedures; - Designated coordinator for ERP implementation; - Measures for restoration and clean-up of the environment following any major accident; - Documentation of emergency preparedness and response activities, resources, and responsibilities. 2.5 PROJECT WORKERS TRAINING: ✓ Training will be provided to workers in hygiene, health and safety, Prior to commencement of MINEDUC/SPIU, sexual transmitted diseases, Gender based violence/exploitation construction, with regular site Contractors, and sexual abuse. training sessions. Districts. Training costs to be included in the capacity building budget. More awareness campaigns to be delivered through different media 12 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed (local radio stations, wall charts, poems, social media, etc.) to project Through project implementation MINEDUC, workers, students and local community on technics that can be used in Districts, prevention of respiratory disease especially COVID-19; those include proper handwashing, avoiding unnecessary handshaking, practicing social distancing, coughing on the elbow, etc. 3.1 MANAGEMENT OF WASTE AND HAZARDOUS MATERIALS: The following measures will be put in place to ensure effective The ESMF will be updated by MINEDUC/SPIU management of wastes and hazardous materials, including those effectiveness, and that such and its related to the AF activities; mitigation measures would be implementing ✓ Generation of hazardous and non-hazardous waste materials part of the project ESMF (and partners, will be avoided or minimized in all possible measures; subsequent ESMPs) Contractors ✓ Where waste generation cannot be avoided, it will be reduced, Throughout project recovered and reused in a manner that is safe for human health implementation. and the environment. Where waste cannot be recovered or reused, it be treated, destroyed, or disposed of it in an environmentally sound manner that includes the appropriate control of emissions and residues resulting from the handling and processing of the waste material. ✓ The existing national requirements for management of hazardous wastes including national legislation and applicable international conventions, will be abided by. ✓ There will be no manufacture, trade and use of chemicals and hazardous materials subject to international bans, restrictions or phase-outs. ✓ The release and use of hazardous materials will be minimized 13 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed and controlled. ✓ No exchange of PPEs especially helmets during construction to avoid possible transmission of respiratory disease Resource Efficiency: Feasible measures (financial and technical) for improving efficiency in consumption of energy and water, as well as other resources and material inputs will be put in place. The production, transportation, handling, storage, and use of During project implementation MINEDUC hazardous materials for the entire cycle of the project will be assessed through the ESIA and/or the ESMP. 4.1 TRAFFIC AND ROAD SAFETY: ✓ The potential traffic and road safety risks to workers and Update by effectiveness as part MINEDUC/SPIU, potentially affected communities throughout the project life cycle of the ESMF update and Contractors, will be identified, evaluated and monitored. maintain during the project Districts, timeline. Such mitigation Schools ✓ The appropriate measures and plans will be identified, developed measures are part of the project and implemented to address potential traffic and roads safety risks, ESMF (and subsequent ESMPs) including appropriate training to workers on driving and vehicle safety. ✓ The regular maintenance of project vehicles will be ensured. 14 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed 4.2 COMMUNITY HEALTH AND SAFETY: ✓ The potential risks and impacts of the parent project and the MINEDUC/SPIU, AF activities to the community and environment will be Update by effectiveness and Contractors, identified and appropriate mitigation measures will be set in maintain during the project Districts the ESMF to be updated in regard to parent project activities as timeline well as to AF activities. ✓ Community Exposure to disease namely water borne diseases, vector borne diseases, communicable diseases and COVID-19 pandemic will be avoided or mitigated taking into consideration higher sensitivity of vulnerable groups. Throughout project MINEDUC, District ✓ Report any suspicious respiratory transmitted disease and implementation quarantine infected worker and avoid contact with local community 4.3 GBV AND SEA RISKS: During development and implementation of measures and actions to Update by effectiveness and MINEDUC/SPIU, assess and manage the risks of gender-based violence (GBV) and maintain during the project Contractors, sexual exploitation and abuse (SEA), much emphasis will be put on the timeline Districts following ✓ Prevent or mitigate risks of sexual exploitation and abuse that may result from interaction and collaboration between groups of actors ✓ Identify and understand the risk to women and other vulnerable populations, of sexual exploitation and abuse; ✓ In collaboration with local government and other actors in Update by effectiveness MINEDUC education, MINEDUC will assess the impact of COVID-19 on child sexual assault, teenage pregnancy, dropout and other GBV cases associated with school suspension and Stay-home orders resulted from COVID-19 pandemic. 15 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed ✓ Raise consciousness of boys and girls at increased risk of During COVID-19 Pandemic MINEDUC, REB violence and how to report violence cases during schools’ shutdown and stay-at-home orders as results of COVID-19 through use of social media, radio television and mobile sms communication ✓ Organize awareness raising sessions and educate the workers Monthly awareness raising Districts, Sectors and the community in the project site on issues of GBV/SEA, campaigns through the and MINEDUC legal rights, grievance redress mechanism and referral path for stakeholder’s engagement victims of GBV and SEA. forums such as umuganda ✓ SEA risks will be monitored continuously through the life of a project. If the risk of SEA is found to be increase during the course of a project, this should trigger concomitant action. ✓ Grievance Redress Mechanisms for SEA will be strengthened and integrated to track complaints related to SEA/GBV, including a feedback system for regular and timely feedback on actions taken to respond to complaints. 4.4 GBV AND SEA RISKS DURING PROJECT Throughout the project MINEDUC/PIU IMPLEMENTATION: The project has designed a dedicated subcomponent 2.3 aimed at addressing GBV/SEA issues under this project. Supporting gender sensitive learning environment for students (US$ 1 million) 4.5 EMERGENCY RESPONSE MEASURES: Throughout the life cycle of the parent project as well as additional Update by effectiveness, as part MINEDUC/SPIU, financing, there will be continuous assessment of possible risks to the of the ESMF update and Contractors communities as it relates to emergency incidents such as the maintain during the project uncontrolled release of pollutants and fire, accidents, etc. timeline A procedure to ensure compliance with local laws and international 16 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed requirements relating to the emergency response approach, hazardous materials management, vehicle and container specifications, training of the drivers, risks associated with the transportation route will be developed. The emergency plans address the following aspects of emergency response and preparedness: COVID-19 pandemic mitigation related to the AF (also reflected in the updated SEP), Specific emergency response procedures, Communication strategy, Trained emergency response teams, Emergency contacts and communication systems/protocols, Procedures for interaction with local and regional emergency and health authorities, Protocols for fire truck, ambulance, and other emergency vehicle services. 4.6 SECURITY PERSONNEL: Not applicable to this project Not applicable to the project MINEDUC/SPIU, Contractors 4.7 TRAINING FOR THE COMMUNITY: Not applicable Not applicable Not applicable 5.1 LAND ACQUISITION AND RESETTLEMENT: Update, if only needed the a resettlement Policy Framework (RPF) Update by effectiveness if MINEDUC/SPIU, before effectiveness to guide project implementation needed. Districts 5.2 RESETTLEMENT PLANS: Develop and implement resettlement Before commencement of any plans [RAPs] consistent with the requirements of the RPF and ESS5. civil works at a site with MINEDUC/SPIU, expropriation requirement Districts 5.3 MONITORING AND REPORTING: Ensure that monitoring and reporting on land acquisition and resettlement activities are conducted Throughout the project life. separately. MINEDUC/SPIU, 17 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed All subproject sites will be (for additional classrooms and new schools Districts as well as for additional financing activities) assessed in terms of Throughout the project life. availability of land for additional classrooms or schools and those with land acquisition requirements, ARAPs will be prepared and submitted to the bank for review and clearance before the start of any civil works on such sites. 5.4 GRIEVANCE MECHANISM: Implement the arrangements for the The existing GRM of the parent grievance mechanism for resettlement (if established separately from project will be applied on AF as MINEDUC/SPIU, the grievance mechanism under ESS10) well. Districts, contractors 6.1 BIODIVERSITY RISKS AND IMPACTS: Develop and implement measures and actions to assess and manage By effectiveness update the MINEDUC/SPIU, risks and impacts on biodiversity, including identification of different ESMF (Site specific EMPs prior Contractors, types of habitat and circumstances in which offsets will be used as part to the commencement of parent Districts of the ESMF. (More elaborations will be provided in the site specific project activities as well as AF ESMPs These ESMP shall be developed in accordance with the activities). provisions of ESS6 and guidelines set forth in the ESMF, in a manner acceptable to the Association). Restrictions on land use and access to natural resources that cause a community or groups within a community to lose access to resource usage will be established. Sensitive ecosystems such as legally designated protected areas, forests, biodiversity areas or buffer zones will not be encroached. 7.1 INDIGENOUS PEOPLES PRESENT OR COLLECTIVELY Not applicable Not applicable ATTACHED TO PROJECT AREA: Not applicable 7.2 INDIGENOUS PEOPLES PLAN: Not applicable Not applicable Not applicable 18 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed 7.3 GRIEVANCE MECHANISM: Not applicable Not applicable Not applicable 8.1 CHANCE FINDS: Rwanda Development Board (RDB) and MINISPOC, develop chance Such mitigation measures are MINEDUC/SPIU, finds procedure, for the Parent Project in case valuable artefacts or part of the project ESMF (and Contractors, RDB, culturally valuable materials are found. Such procedure will be subsequent ESMPs). MINISPOC, included in all contracts relating to the implementation of the project. Districts The existing developed of the Ensure relevant workers are trained in the requirements of the parent project will be applied on procedure prior to ground disturbance. AF as well. 8.2 CULTURAL HERITAGE: Identify measures to address risks and impacts on cultural heritage. MINEDUC/SPIU, Contractors, Through the environmental and social assessment, determine Before construction on any site Districts appropriate measures to address risks and impacts on cultural heritage, including: - retain competent professionals to assist in the identification and protection of cultural heritage; - Consult with stakeholders, and encourage them to participate in management of cultural heritage likely to be affected by the project and explore avoidance and mitigation options; - Consult with persons with relevant expertise to determine whether disclosure of information regarding cultural heritage required under the ESSs would compromise or jeopardize the safety or integrity of such cultural heritage. - In collaboration with relevant stakeholders, implement any agreed protective or recovery measures such as identified in the ESIAs/ESMPs or other specific studies. 9.1 ESMS: 19 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed Not applicable to the project Not applicable Not applicable 9.2 FI ORGANIZATIONAL CAPACITY: Not applicable Not applicable Not applicable to Rwanda’s case. 9.3 SENIOR MANAGEMENT REPRESENTATIVE: Not applicable Not applicable Not applicable 20 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed 10.1 Stakeholder Engagement Plan (SEP) Implement the updated Stakeholder Engagement Plan (SEP), Throughout project MINEDUC/SPIU, comprising the AF activities, describing the timing and methods of implementation engagement with the project-affected communities and other stakeholders throughout the life cycle of the project. MINEDUC/SPIU, Throughout Project Contractors, The updated SEP describes the range of information to be provided to implementation Districts and sought from stakeholders. Main characteristics and interests of stakeholders, as well as different levels of engagement and appropriate consultation will be taken into account. The updated stakeholder engagement plan also includes and describes the grievance mechanism required. SEP IMPLEMENTATION: ✓ Ensure effective information dissemination and consultations on emergency preparedness and response, ✓ Establish appropriate channels of communication to maintain ongoing engagement and communicating additional information that may arise at key stages in the project cycle prior to start-up of operations, and any specific issues identified as of concern to stakeholders. ✓ Inform stakeholders about any material changes to the project that result in additional risks and impacts of concern, specifying how those risks and impacts are being addressed and disclose an update. 10.2 PROJECT GRIEVANCE MECHANISM: 21 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed The existing GRM of the parent project will be applied on AF as well. Implement throughout the MINEDUC/SPIU, Activities and will ensure reception and timely response to any project Contractors, complaints made about the project (including those from members of Districts the communities, local businesses and other stakeholders) and will be the basis for developing appropriate mitigation strategies. The grievance redress mechanism to be updated will include the following elements: (a) Modalities by which stakeholders can submit their complaints, including, but not limited to, submissions in person, by phone, text message, letters or e-mail. (b) A log where complaints are registered in writing, maintained as a database. (c) Publicly advertised service standards outlining the length of time stakeholders can expect to wait for acknowledgement, response and resolution of their complaints. (d) Transparency about the grievance procedure, governing structure and decision makers. (e) An option for moving to mediation in cases where complainants are not satisfied with the proposed resolution and as appropriate; and (f) An appeal process (including the national judiciary) to which unsatisfied complainants may be referred when an agreed resolution by other means has not been reached. (g) The project-affected communities will be informed about the grievance process in the course of its community engagement or 22 | P a g e Summary of the Material Measures and Actions to Mitigate the Project’s Timeframe Responsibility / Potential Environmental and Social Risks and Impacts Authority and Resources/Funding Committed stakeholders’ engagement activities and will make publicly available a record documenting the responses to all grievances received. (h) Handling of grievances will be done in a culturally appropriate manner and be discreet, objective, sensitive and responsive to the needs and concerns of the project-affected communities. 10.3 Add other measures and actions that have been agreed, as per the specific risks and impacts of the Project (see ESIA) Specify Training to be provided Specify Targeted Groups and Timeframe for Delivery Use of Personal Protective Equipment (PPE) All workers and project staff Continuous Emergency Preparedness and Response, including COVID-19 pandemic Site Engineers and Project Manager mitigation in relation to the AF activities. A month Occupational health and safety including on emergency prevention and All workers and project staff preparedness and response arrangements to emergency situations. Continuous throughout the project timeline Environmental Awareness All workers and project staff Continuous throughout the project timeline Gender Based Violence (GBV) and Sexual Exploitation and Abuse (SEA) Idem Sexually Transmitted Diseases (STDs) and other communicable diseases Idem Environment and social monitoring and reporting Environment safeguard specialist and social safeguards specialist 23 | P a g e