The Republic of Iraq Iraq – Integrated Persistent Organic Pollutants (POPs) Management Project (P178935) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) APPRAISAL VERSION 22nd December 2023 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Iraq (the Recipient) will implement the “Integrated Persistent Organic Pollutants (PoPs) Management Project (the Project), with the involvement of the Ministry of Environment (MoEn), as set out in the Grant Agreement and the Project Agreement. The International Bank for Reconstruction and Development (the World Bank) acting as the administrator for the [the Global Environmental Facility (GEF), and for the Iraq Reform, Recovery and Reconstruction Fund (I3RF), has agreed to provide the financing (P178935) for the Project, as set out in the referred agreements. 2. The Recipient shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the World Bank. The ESCP is a part of the Grant Agreement and the Project Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreements. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Recipient shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted and implemented under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESS, and in form and substance, and in a manner acceptable to the World Bank. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the World Bank. 4. As agreed by the World Bank and the Recipient, this ESCP will be revised from time to time if necessary, during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to Project performance. In such circumstances, Recipient shall agree to the changes with the World Bank and shall update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the World Bank and the Recipient. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING REGULAR REPORTING Prepare and submit to the Bank regular monitoring reports on the environmental, social, health and safety (ESHS) performance of the Project, including but not limited to the Starting from the Effective Date, implementation of the ESCP, status of preparation and implementation of E&S documents quarterly reports shall be submitted no required under the ESCP. A later than 20 days after the end of each PMU at MoEn It shall also prepare and present the stakeholder engagement activities, functioning of the reporting period and maintained grievance mechanism, including but not limited to grievance logs from workers and throughout the Project Implementation. communities, overall E&S performance of the project, compliance to ESSs during implementation of project activities, project-related accidents and implementation plans for the project activities in the subsequent quarter. INCIDENTS AND ACCIDENTS B Promptly notify the Bank of any incident or accident related to the Project which has, or Notify the Bank no later than 48 hours is likely to have, a significant adverse effect on the environment, the affected after learning of the incident or accident. communities, the public or workers including inter alia, cases of sexual exploitation and abuse (SEA), sexual harassment (SH) and accidents related to health and safety, etc. Provide subsequent reports to the Bank Provide sufficient details regarding the scope, severity, and possible causes of the incident within a timeframe acceptable to the PMU at MoEn or accident, indicating immediate measures taken or that are planned to be taken to Bank. address it, and any information provided by any contractor and supervising entity, as This notification/reporting system shall appropriate. remain in place throughout Project Subsequently, at the Bank’s request, prepare a report on the incident or accident and implementation. propose any measures to address it and prevent its recurrence. CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports to the World Require contractors and supervising firms to provide monthly monitoring reports on Bank upon request as annexes to the PMU at MoEn C ESHS performance in accordance with the metrics specified in the respective bidding reports to be submitted under action A documents and contracts and submit such reports to the World Bank. above. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS ORGANIZATIONAL STRUCTURE The MoEn has appointed one Establish and maintain a PMU within MOEn that implementing the project that is tasked environmental and one social specialists 1.1 with ESHS management, with qualified staff and resources to support management of at the PMU and will be maintained PMU at MoEn ESHS risks and impacts of the Project including assigning or hiring an environmental through the implementation phase of specialist, a social specialist, and GM team. the Project. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY In addition, GM team has been also appointed to follow the grievance mechanism. The first drafts of ESMF and GAP were disclosed on 14th, and 11th, November 2023 and will be finalized, and adopted prior to Appraisal, and thereafter implement the requirements set out in ENVIRONMENTAL AND SOCIAL INSTRUMENTS these instruments (ESMF, and GAP) throughout Project implementation. 1. Adopt and implement an Environmental and Social Management Framework (ESMF) for the Project, consistent with the relevant ESSs. For sub-projects, adopt the ESIA and ESMP (as applicable according to the 2. Adopt and implement an Environmental and Social Impact Assessment (ESIA), 1.2 ESMF) before commencement of the PMU at MoEn and corresponding Environmental and Social Management Plan (ESMP), and related activities during Gender Action Plan (GAP). implementation, and thereafter implement the ESIA and ESMP throughout Project implementation. The requirements of ESIAs/ESMPs will be submitted for review and clearance and integrated in bidding process to ensure contractors consider those in their proposals and thereafter as part of implementation. MANAGEMENT OF CONTRACTORS As part of the preparation of Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S procurement documents and respective instruments, the Labor Management Procedures, and code of conduct, into the ESHS 1.3 contracts. PMU at MoEn specifications of the procurement documents and contracts with contractors and Supervise contractors throughout supervising firms, including the UNDP that will implement components 1, 2, and 3 Project implementation according to output agreement. Thereafter ensure that the UNDP, contractors and supervising firms comply and cause subcontractors to comply with the ESHS specifications of their respective contracts. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. MoEn Ensure that the consultancies, studies (including feasibility studies, if applicable), capacity building, training, and any other technical assistance activities under the Project are carried out in accordance with terms of reference acceptable to the World Bank, that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. 1.5 THIRD PARTY MONITORING: Within the timeframes requested by the MoEn World Bank. For high environmental risk activities (including, inter alia, the destruction and or the disposal of POPs and land remediation, if needed) the Recipient shall: (i) promptly appoint a third- party monitor consultant, with terms of reference, qualifications and experience acceptable to the World Bank, to visit and monitor the Project area, collect relevant data and communicate with Project stakeholders and beneficiaries; (ii) require the third-party monitor consultant to prepare and submit monitoring reports, which shall be promptly made available to and discussed with the World Bank; and (iii) promptly take any actions, as may be requested by the World Bank upon its review of the third-party monitor consultant reports. ESS 2: LABOR AND WORKING CONDITIONS LABOR MANAGEMENT PROCEDURES Adopt and implement the Labor Management Procedures (LMP) for the Project, including, The first draft LMP was disclosed on 14th, inter alia, provisions on working conditions, management of workers relationships, November 2023, and will be updated 2.1 occupational health and safety (including personal protective equipment, and emergency and adopted prior to Appraisal and PMU at MoEn preparedness and response), code of conduct (including relating to SEA and SH), forced should be implemented throughout labor, child labor, grievance arrangements for Project workers, and applicable Project implementation. requirements for contractors, subcontractors, and supervising firms. GRIEVANCE MECHANISM FOR PROJECT WORKERS GM shall be established prior to hiring Project workers and thereafter maintain 2.2 Establish and operate a grievance mechanism for Project workers, as described in the LMP PMU at MoEn and operate it throughout Project and consistent with ESS2. implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY WASTE MANAGEMENT PLAN As part of the ESMF and the site-specific 3.1 Adopt and implement a Waste Management Plan (WMP), to manage hazardous and instruments and maintained throughout PMU at MoEn non-hazardous wastes, consistent with ESS3. the Project implementation. RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the adoption 3.2 Incorporate resource efficiency and pollution prevention and management measures in and implementation of the PMU at MoEn the ESIAs/ESMPs to be prepared under action [1.2] above. ESIAs/ESMPs. ESS 4: COMMUNITY HEALTH AND SAFETY TRAFFIC AND ROAD SAFETY Same timeframe as for the adoption 4.1 Incorporate measures to manage traffic and road safety risks as required in the ESMPs to and implementation of the PMU at MoEn be prepared under action 1.2 above. ESIAs/ESMPs. COMMUNITY HEALTH AND SAFETY Assess and manage specific risks and impacts to the community arising from Project under Action 1.2, including, inter alia, the potential for community exposure to communicable Same timeframe as for the adoption and 4.2 PMU at MoEn diseases, toxic emissions from waste, fire risks, response to emergency situations, and implementation of the ESMPs. include mitigation measures in the ESIAs/ESMPs to be prepared in accordance with the ESMF. SEA/SH Action Plan is prepared as part of SEA AND SH RISKS the Gender Action Plan prior to appraisal 4.3 Adopt and implement a proportionate SEA/SH Action Plan as part of the gender action and thereafter implement the SEA/SH PMU at MoEn plan (GAP), to assess and manage the risks of SEA and SH. Action Plan throughout Project implementation. SECURITY MANAGEMENT Assess and implement measures to manage the security risks of the Project, including Prior to engaging security personnel and 4.4 the risks as set out in the ESIAs/ESMPs, guided by the principles of proportionality and thereafter implemented throughout PMU at MoEn GIIP, and by applicable law, in relation to hiring, rules of conduct, training, equipping, Project implementation. and monitoring of such personnel. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent The SEP was disclosed on 14th, with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, November 2023, the SEP will be 10.1 PMU at MoEn relevant, understandable and accessible information, and consult with them in a culturally implemented and updated as necessary appropriate manner, which is free of manipulation, interference, coercion, discrimination throughout the Project lifecycle. and intimidation. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY PROJECT GRIEVANCE MECHANISM Establish, update, publicize, maintain, and operate an accessible grievance mechanism, to receive and facilitate resolution of concerns and grievances in relation to the Project, promptly and effectively, in a transparent manner that is culturally appropriate and readily The current GM system will be updated accessible to all Project-affected parties, at no cost and without retribution, including and operationalized by the Effective 10.2 concerns and grievances filed anonymously, in a manner consistent with ESS10. PMU at MoEn Date and to be maintained throughout project implementation. MO The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT Training to the public and community groups as well as local authorities, and others as identified in the SEP on the following as relevant to them: - Stakeholder mapping and engagement. CS1 - Specific aspects of the ESIA/ESMP that require feedback from the public and local Throughout project implementation authorities and for their own awareness so that community health and safety can be improved. - Grievance mechanism. Training shall be conducted for project personnel, contractors and workers, while maintaining training records on the following: - ESIA/ESMP implementation. PMU at MoEn. CS2 - LMP. Throughout project implementation - OHS including emergency prevention and preparedness and response. - GM. - GBV AND SEA/SH. TRAINING FOR CONTRACTORS’ STAFF Provide training on implementation of environmental and social due diligence documents (e.g., OHS, environmental and social assessments, community health and safety, Prior to commencing works and CS3 stakeholder engagement, grievance, codes of conduct, etc.) to all staff working with throughout project implementation. contractors and sub-contractors that are responsible for project’s environment and social issues. 7|Page