REPUBLIC OF IRAQ MINISTRY OF ENVIRONMENT (MOEN) Iraq – Integrated Persistent Organic Pollutants (PoPs) Management Project (P178935) STAKEHOLDERS ENGAGEMENT PLAN (SEP) DRAFT FOR CONSULTATIONS 13 NOVEMBER2023 Disclaimer: The SEP is in draft form. Table of Contents 1. Introduction and Project Description ..................................................................................................................3 1.1 Implementation institutional Arrangement……………………………………………………………………………………….9 2. Brief Summary of Previous Stakeholder Engagement Activities ......................................................................10 3. Stakeholder Identification and Analysis ............................................................................................................13 3.1. Methodology...............................................................................................................................................13 3.2. Affected Parties, Other Interested Parties, and Disadvantaged/Vulnerable Individuals or Groups .................14 3.3. Summary of Project Stakeholder Needs .......................................................................................................17 4. Stakeholder Engagement Program ....................................................................................................................18 4.1. Purpose and Timing of Stakeholder Engagement Program ...........................................................................18 4.2. Proposed Strategy for Information Disclosure ..............................................................................................18 4.3. Proposed Strategy for Consultation..............................................................................................................22 4.4. Proposed Strategy to Incorporate the View of Vulnerable Groups ................................................................23 4.5. Timelines .....................................................................................................................................................23 4.6. Review of Comments ...................................................................................................................................23 4.7. Future Phases of Project ..............................................................................................................................23 5. Resources and Responsibilities for Implementing Stakeholder Engagement Activities ..................................24 5.1. Resources ....................................................................................................................................................24 5.2. Management Functions and Responsibilities................................................................................................24 6. Grievance Mechanism ........................................................................................................................................25 6.1. Specification ................................................................................................................................................25 6.2. The Proposed GM........................................................................................................................................25 a. Uptake ........................................................................................................................................................28 b. Sorting and Processing .................................................................................................................................28 c. Acknowledgment and Follow Up .................................................................................................................28 d. Verification, Investigation, and Action ..........................................................................................................29 e. Providing Responses to GM users ................................................................................................................29 f. Closing and Reporting ..................................................................................................................................30 g. Procedure for Appeal...................................................................................................................................30 6.3. Roles and Responsibilities of the GM Coordinator ........................................................................................31 7. Monitoring and Reporting .................................................................................................................................31 7.1. Involvement of Stakeholders .......................................................................................................................31 7.2. Reporting Back to Stakeholder Groups .........................................................................................................31 1 Abbreviations and Acronyms COVID-19 Corona Virus Disease E&S Environmental and Social ESCP Environmental and Social Commitment Plan ESF Environment and Social Framework ESIA Environmental and Social Impact Assessment ESMP Environmental and Social Management Plan ESS Environmental and Social Standard GEF Global Environment Facility GM Grievance Mechanism I3RF Iraq Reform, Recovery and Reconstruction Fund MoA Ministry of Agriculture MoEn Ministry of Environment MoEIec Ministry of Electricity NGO Non-Governmental Organization NIP National Implementation Plan OPs Obsolete Pesticides PAPs Project Affected Parties PCBs Polychlorinated Biphenyls PMU Project Management Unit PMT Project Management Team POPs Persistent Organic Pollutants SEA/SH Sexual Exploitation and Abuse /Sexual Harassment SEP Stakeholder Engagement Plan UNEP United Nations Environment Programme UPOPs Unintentional Persistent Organic Pollutants WB World Bank 2 1. Introduction and Project Description The project responds to Iraq’s (i) national priorities of managing hazardous waste and chemicals, (ii) international commitments under Stockholm Convention on environmentally sound management of Polychlorinated Biphenyls (PCBs), Obsolete Pesticides (OPs) and Unintentional Persistent Organic Pollutants (UPOPs), and (iii) environmental challenges caused due to conflict pollution. Given the significant level of chemical contamination and large quantities of Persistent Organic Pollutants (POPs) in Iraq, the project through the grant from Global Environmental Facility (GEF) proposes to support the government in (i) updating the National Implementation Plan (NIP) covering all types of POPs, (ii) conducting comprehensive national inventory of OPs, PCBs, Industrial POPs (IPOPs) and UPOPs, (iii) containing, disposing and destroying selected high-risk stockpiles of POPs and (iv) building capacities of Ministry of Environment (MoEn), Ministry of Agriculture (MoA) and Ministry of Electricity (MoElec) to scale up the interventions beyond the project and across the country to minimize environment and health risks to local communities. Through these activities, the project aims to (i) safely dispose 1000 tons of obsolete pesticides including POPs and containers, and strengthen the lifecycle management of pesticides in Iraq, and (ii) safely manage and dispose 3000 tons of PCBs, PCB contaminated equipment, waste, and oil, and improve country-wide inventory of PCBs transformers and capacitors. In achieving these objectives, the project will be guided by the strategies outlined in: (i) Iraq’s NIP priorities as per the framework of Stockholm Convention, (ii) the overall objectives of the GEF, and (iii) the specific needs and features of Iraq to manage environmental risks caused by successive conflicts and deficiency in the management of hazardous chemicals over the years. In addition, the project will also guided by the overall objectives of the Strategic Approach to International Chemicals Management (SAICM), to ensure sound management of chemicals in Iraq and reduce adverse effects of pesticides on human health and environment. The project through additional grant funds from I3RF also proposes to (i) carry out detailed assessment of critical high-risk hotspots contaminated with hazardous chemicals including POPs pesticides and PCBs in the seven conflict affected governorates, (ii) build technical and analytical capacity of MoEn and (iii) strengthen policy and institutional framework for the management of contaminated sites. These activities will build on previous assessments of environmental hotspots in Iraq, including those conducted by UNEP and the World Bank, as well as insights from the work carried out by the MoEn. The objective here is to demonstrate management of hotspots and develop technical capacity of MoEn for the management of contaminated sites, covering aspects such as identification, assessment, risk assessment, remediation, and post-remediation monitoring. All these activities are proposed to be carried out through the following four components. Component 1: Updated inventory and strengthen framework for the management of POPs and hazardous chemicals (US$4.22 million GEF grant) This component will support review and updating the NIP, carrying out the inventory of PCBs, OPs, UOPS, IPOPs and developing an enabling framework for PoPs management through the following three sub- components. 3 Sub-component 1.1 Review and update of Iraq National Implementation Plan for POPs The sub-component will support the review and update of the current National Implementation Plan (NIP) of Iraq for POPs to comply with Article 7 under the Stockholm Convention, its endorsement and submission to Convention Secretariat. This will thus involve quantitative, and qualitative national inventories and assessments for new POPs, UPOPs, IPOPs, PCBs and updating current inventory of POPs pesticides, to enable development of comprehensive NIP for POPs. Building on the above inventories and assessments for OPs, PCBs, IPOPs and UPOPs and the current NIP, a comprehensive NIP (including Kurdistan) for POPs Management will be prepared, as the main output of this sub-component. This preparation and updating of NIP will involve (i) ranking actions based on the obligations set out under the Stockholm Convention, risks posed to human health and the environment in Iraq, (ii) identifying cost-effective action plans for the newly adopted POPs and (iii) revised action plans for the initial POPs listed under the Convention. The updated NIP will also consider emerging aspects such as circular economy approaches, green chemistry, extended producer responsibility green public procurement and economic incentives where feasible and appropriate. The NIP will also include an assessment of infrastructure and capacity needs of GoI for the management of all POPs, developing new and updating POPs inventories. Institutional mechanisms and the need for its strengthening for the implementation of the NIP will also be identified. While doing so, the existing national coordination mechanisms and capacities established during the development of current NIP. This includes the establishment of a federal co-ordination committee of members from Iraq and Kurdistan involving relevant ministries and stakeholders dealing with POPs management, such as experts from non- governmental organizations, academic and civil society involved in the chemicals' life cycle of the adopted POPs. This committee will provide guidance and recommendations to support decision-making processes and the effective implementation of policies and strategies related to hazardous chemicals and POPs. In addition, the committee will also ensure adoption of NIP updates, outcomes, and actions by the different stakeholders. Sub-component 1.2 Policy, regulatory and institutional strengthening for POPs management This sub-component will assess policy, institutional and regulatory gaps for the implementation of NIP and other requirements of implementing the Stockholm Convention. Based on this assessment, this sub- component will support development of (i) policies for the prevention and management, (ii) regulations and standards for ensuring compliance, (iii) monitoring systems for tracking the entire value chain of import, production, supply, usage, and disposal, (iv) protocols and guidelines for the storage, handling, maintenance, and usage, and (v) framework and guidelines for the risk-based remediation of sites contaminated by POPs and other hazardous chemicals. To the extent possible, this sub-component will also support the process of approval and implementation of the above activities, within the project life time. Building further on these activities and existing national coordinating mechanism, this sub-component swill also supports MoEn in fulfilling its specific obligations under the Stockholm Convention. In addition, it is envisaged that economic sustainability and a sustainable administration of the project will be achieved through strengthening of the institutional structure for new POPs management and establishment of co- ordination mechanisms with other ministries, stakeholders (internal and external) and communities. 4 Sub-component 1.3: Knowledge management and capacity building This sub-component will support building the technical, analytical and infrastructure capacity of the Ministry of Environment and key stakeholders, Ministries of Agriculture and Electricity. In addition to building technical capacity, this component will provide specific customized comprehensive training in (i) conducting inventory of (ii) inspection, monitoring, handling, and management; (iii) monitoring and testing, (iv) management, treatment, disposal and destruction, (v) implementation and enforcement of policies and regulations formulated for the sustainable management of OPs, IPOPs, UPOPs, PCBs, and other hazardous chemicals. Given the constraints such as limited budgetary resources and the absence of national infrastructure, conducting all necessary sampling and analysis required for the project becomes challenging. To establish a more sustainable approach, this subcomponent will identify the need for building the laboratory capacity (technical and infrastructure) of MoEn, MoA and MoElec. This will involve supporting activities to (i) assess local analytical capacity and priority of pollutants to be measured based on their relevance in the country and build capacities of national laboratories and academic research laboratories to test for POPs parameters and (ii) provide needed laboratory equipment and infrastructure for POPs assessment, measurement, analysis, and prevention measures ensuring compliance to the commitments under Stockholm Convention and sustainable management of chemicals and hazardous substances. The sub-component also envisages enhancing the capacity of maintenance workshops operating under the jurisdiction of MoElec aimed at facilitating the testing of PCBs in both oil, soil samples and other matrices. This is proposed to be performed through (i) procurement of PCB/chloride analyzer system to efficiently detect and quantify the presence of PCBs and the acquisition of reagents and accessories, and (ii) training and capacity building for the maintenance workshops. The training programs will consider lessons learnt and challenges overcome by similar programs in other countries. The utility personnel in the power sector will receive training in the collection, handling, storage, and transport of PCB and wastes and will have their capacity built to operate according to agreed standards. All stages of the waste handling routines will be governed by international guidance and practices and monitored by an independent third party. Component 2: Management and disposal of priority stockpiles of POPs in Agriculture and Power Sector (US$7.90 million GEF Grant) Sub-component 2.1: Management and Disposal/ destruction of POPs OPs in the agriculture sector Building on the POPs pesticides inventory in component 1.1, this sub-component will identify priority sites, conduct detailed assessments, understand critical risks, prioritize sites based on the level of contamination and risks, develop necessary management and destruction/ disposal strategies for sites totaling up to 1000 tons of OPs. The current NIP of MoEn prepared with the help of UNEP brought out significant contamination issues at many of the 18 pesticides warehouses in Iraq. Many of these warehouses based on limited sampling are suspected to have various Organochlorine (OC) and Organophosphate (OP) compounds such as Chlorophenylmercury, Lindane, Diazinon, Heptachlor, Fenitrothion, Malathion, Endosulfan, Dieldrin, DDT and its decay derivatives DDE, and Methoxychlor. In addition soil contamination resulting from pesticide seepage and spillage from contaminated soil, deteriorating conditions of containers (ripped and worn 5 out), warehouse floors saturated with pesticides and contaminated soil, and significant quantities of OPs are also expected. This highlights the critical environmental and safety concerns associated with these warehouses and the need for detailed assessments to establish the exact level of OP contamination, their destruction/ disposal and remediation of the site. Considering this, the exact nature and level of OPs contamination and risks at these sites will be assessed and prioritized through stakeholder consultations. For the identified priority sites necessary designs and plans will be developed for the (i) capture, segregation and containment of obsolete pesticide stockpiles and contaminated materials; (ii) undertake physical recovery, (ii) packaging and removal of the recovered stockpiles and contaminated material (iii) secure temporary storage to ensure prevention of further release of OPs and their general spread into the global environment. Wherever, destruction of contaminated material is identified as a priority due to risk to local communities and achieving GEF strategic objectives of maximizing volume of obsolete pesticides eliminated, this sub- component will support their disposal based on of Best Available Technologies (BAT)/ Best Environmental Practice (BEP) along with required environment management measures. The selection of destruction/disposal technologies will rely on the recommendations of the feasibility study to be carried out under component 1.1 of the project. Wherever feasible disposal in country through co-incineration in cement kilns or development of appropriate facilities will be pursued or a combination of in-country and disposal at international facilities will be adopted. All these activities will be implemented through ‘Learning by Doing Approach’, so that the capacity of participating ministries (MoEn and MoA) is developed for identification, assessment, disposal/ destruction and management of OPs beyond the project implementation. Sub-component 2.2: Management and Disposal of PCBs The inventory of PCBs, their phase out plan and NIP developed in sub-component 1.1 will guide this sub- component in designing environmentally sound treatment/disposal of the equipment and dielectric fluids that will be generated from the contaminated equipment or treat such units so that level of contamination is reduced to below the low POPs limit specified under the Stockholm Convention (50 ppm). This will involve collection of PCBs (oils, equipment and waste), their transport, interim storage and management activities such as drainage, packaging, refilling, and decontamination/ destruction (or dichlorination). The objective is not just to dispose/ decontaminate PCBs but also to develop a national approach within the legal framework as well as costs (including recovery of potentially valuable materials) and time demands. Hence, the overall objectives of this sub-component would be to develop a harmonized national regulatory and administrative framework for PCBs and PCB wastes in compliance to the commitments under Stockholm and Basel conventions, technical and administrative capacity with GoI agencies to manage PCBs and destruction or decontamination of 3,000 tons of PCB-containing or PCB contaminated wastes. Considering the large volume of PCB contaminated equipment within the power sector, it would be crucial to consider various disposal scenarios both to maximize the impact of the quantity managed with project support and also for further elimination of PCBs by Iraq. Each of the disposal scenarios will be carefully evaluated during the project implementation with due to consideration to factors such as environmental impact, safety measures, and compliance with relevant regulations. The chosen approach will prioritize the protection of both human health and the environment. 6 Learning from the successful experience of Egypt POPs Project (P116230/GEF ID 3905), the project will explore the viability of (i) procuring mobile de-chlorination unit and hiring a vendor to perform de- contamination activities and also train GoI team. This will facilitate availability of infrastructure and technical capacity with GoI in carrying out PCB de-contamination activities beyond the project. Component 3: Support to the Management of Chemical Contamination and hotspots (US$4.76 million I3RF Grant) Considering the profile and nature of the chemical contamination, its linkages with the current project and further funding available from I3RF, this component proposes to build the capacity of MoEn in chemical contamination and management of such sites. In addition to complementing many activities of the project, this component will also support GoI meet its commitments related to hazardous chemicals under Basel and Rotterdam conventions, through the following three sub-components. This component will focus on the seven conflict affected governorates of Iraq and build on the inventory and preliminary assessment of environmental hotspots caried out by MoEn and WB during 2020-22. This assessment identified 76 sites spread over 1333 ha, to have been polluted with oil/ hydrocarbon and chemical contamination, directly affecting over 55, 000 people and over 1.7 million people indirectly. As recommended by this assessment, this component will support the the following priority activities organized under three sub-components. Sub-component 3.1 Assessment and preparation of remediation plan for priority contaminated sites This sub-component of the project proposes to carry out detailed assessment of 3 to 5 priority sites (depending on the cost of assessment, complexity of sites and cost-effectiveness of the remediation/ clean up) to develop complete information on nature and level of contamination/ pollution at the sites and risk it poses to communities. The candidate sites will be selected based on the inventory of contaminated sites developed and risk rating of the sites in the assessment referred above. The objective of these detailed assessments will be to assess the level of contamination/ pollution at the sites, risks these sites pose to the human health and environment and overall potential of the site to contribute to the economic development of the region. This will involve detailed site assessments (phase 2) and investigations, sampling surveys, assessment of environmental, health and economic impacts in the influence area and develop management and/or remediation plans based on risk based criteria and future use of the site. The remediation plan will be developed in close consultation with local communities and stakeholders and opportunities for private sector participation (if any) in implementing the remediation plans. This sub-component will be implemented by the technical team of MoEn, MoA, MoElec and MoO together with consultants, so that the government agencies build necessary technical skills in developing remediation plans. To strengthen synergies between components 1, 2 and 3 of the project, efforts will be made to prioritize hotspot sites contaminated with OPs or PCBs, so that detailed assessments can be carried out through sub-component 3.1, while management and/ or remediation activities can be carried out through component 2 of the project. The initial assessment of contaminated sites identified 11 sites (such as Diyala Electricals) that are likely to have been contaminated with OPs and PCBs. These sites will further be evaluated during implementation and priority sites will be selected in such a way that the activities of this component complement the activities of the other components of the project. 7 Sub-component 3.2 Enabling actions for the development of National Program on Contaminated Sites Management The environmental hotspots assessment work carried out by MoEn and WB, recommended development of National Program on Contaminated Sites Management (NPCSM). The assessment also identified actions critical for the implementation of NPCSM. This sub-component of the project, supports the implementation of these enabling actions involving (i) establishing a GIS based contaminated sites information system, (ii) formulation or strengthening GoI’s policy on contaminated sites management; (iii) support development of comprehensive regulations on chemicals (pollution/ contamination) management together with sub-component 1.3; (iv) development of framework/ guidelines for the identification, assessment, risk assessment, remediation and post remediation monitoring of chemical contaminated sites with inputs from components 1 and 2; (v) development of soil and groundwater screening and clean-up standards for chemical contamination; (vi) revision/ updating water quality standards with regard to hydrocarbons and hazardous chemicals; and (vii) facilitate development of NPCSM along with appropriate budgetary allocation/ resource mobilization. Activities of this sub- component will complement the policy and regulatory activities of sub-component 1.3 and will be closely coordinated, to ensure that a comprehensive policy and regulatory framework for chemicals and contaminated sites is established in Iraq. Sub-component 3.3 Strengthen institutional framework and capacities for NPCSM Building on the recommendations of the hotspots assessments work, this sub-component of the project will support MoEn in evaluating various institutional models and developing detailed institutional structure that help effective management of chemicals and contaminated sites management and establishment of NPCSM. In addition, specific training programs will also be developed and rolled out through this sub-component to various stakeholder agencies on chemical contamination to carry out site assessments, development of conceptual models, risk assessment, development of remediation plans and programs. Similar to other activities of this component, the training and capacity building activities will be designed to complement activities under sub-component 1.3 of the project. In addition, this sub-component will strengthen the laboratory capacity of MoEn, for carrying out site assessment and sampling and analysis of chemical contamination. This would include procurement of on- site monitoring equipment and laboratory equipment for analyzing soil, water, dust, and air samples. While actual number and type of equipment to be procured will be finalized in the implementation phase of the project, these will include field equipment such as photo ionization detectors, oil water interface meters, hazardous waste material sampling equipment, toxic gas detectors, hand held Energy Dispersive X-ray Fluorescence (ED-XRF) and GPS devises, and laboratory equipment such as Gas Chromatography- Mass Spectrometry (GC-MS), Inductively Coupled Plasma (ICP), HPLC, TCLP equipment and laboratory ED- XRF, etc. In addition, this sub-component will support in enhancing laboratory capabilities to meet the necessary calibration requirements and accreditation. The assistance aims to extend to helping the laboratory establish maintenance protocols and ensure their operations continue to meet these standards even beyond the project. Component 4: Project Management and Project Monitoring and Evaluation (US$ 0.545 million including US$0.425 million GEF Grant and US$0.120 million I3RF Grant) 8 Sub-component 4.1 Project Management (US$0.445 GEF Grant and US$0.12 million I3RF Grant) This sub-component will support the establishment and operation of a Project Management Unit (PMU) at the Ministry of Environment. The PMU will be responsible for overall management, procurement, financial and environmental and social management functions to be carried out and will provide needed operating costs associated with day-to-day project management and implementation. To support this, the PMU will be staffed with a project manager, procurement officer, financial officer, and environmental and social specialists The PMU will also coordinate with other stakeholder ministries such as MoA and MoElec in implementing the project activities. Given the complexity of the project and capacity constraints, MoEn will hire UNDP as project management agency to who will provide the necessary technical and management support in delivering the project activities. sub-component 4.2 Project Monitoring and Evaluation (US$0.1 million GEF Grant) This sub-component will also support preparation and implementation of monitoring and evaluation activities of the project by collecting evidence-based information and data, and reporting to the World Bank and the GEF, as well as a mid-term and technical evaluations in compliance to the World Bank and GEF guidelines. As per the GEF Environmental Policy (2019), the updates on GEF Evaluation Policy include among others introducing the principle that evaluation should apply a gender-inclusive approach, as well as introducing a requirement to collect (i) socio-economic co-benefits data, (ii) sex and gender disaggregated data, and (iii) geographic coordinates of project sites, as available. The GEF requirements for designing a M&E plan for Components 1&2 will be adopted using SMART indicators for results and implementation linked to the GEF results frameworks and including (1) the applicable GEF indicators on global environmental benefits identified at each replenishment cycle, (2) the socio-economic co-benefits and sex-disaggregated and gender-sensitive indicators (where relevant), (3) project site geographic coordinates. Whereas for Component 3 funded by I3RF, the activities will be monitored and reported regularly as per the specific reporting requirements of the donor, through the respective component. 1.4 Implementation Institutional Arrangements To complement its efforts in project implementation, MoEn will seek the services of UNDP as ‘Delivery Partner’ to implement part of the project activities. With technical expertise in development and environment management sector and strong local presence, UNDP is well positioned to support MoEn in implementing project activities. The MoEn will sign an agreement with UNDP, using standard output agreement to execute part of the project activities. It is envisaged that the implementation of Components 1, 2 and 3 of the project will be included in the output agreement. The exact share of activities between MOE and UNDP, however, will be finalized during project implementation. MoEn and the PMU will supervise the activities to be implemented by UNDP and in close coordination with the GoI, particularly with the relevant ministries and all stakeholders. 9 2. Brief Summary of Previous Stakeholder Engagement Activities The stakeholders’ consultations have been done so far in the preparation for the project are three as described below. Two Stakeholder Engagement were conducted as part of the National Implementation Plan of the Stockholm convention. The first stakeholder engagement session took place in Amman in 2019. Its participants and objectives can be found in Table 1. Table 1: First Stakeholder Engagement Session – Participants and Objectives Participants - Ministry of Environment (MoEn) - Ministry of Electricity (MoElec) - Ministry of Industry and Minerals (MoIM) - Ministry of Agriculture (MoAgr) - Ministry of Oil (MoO) - Ministry of Construction, Housing, Municipalities and Public Works (MoCHMPWs) - AmanatBaghdad Objectives 1- Review the Stockholm Convention and its importance to Iraq 2- Review the Convention’s chemicals and pesticides 3- Review the Convention's national plan and project steps as well as the objective of their implementation 4- Defining the responsibilities of each Ministry, specifying their obligations, and emphasizing the significance of their roles in safeguarding human health and the environment 5- Organize participants into groups based on the expertise of each ministry, and also create additional teams for administrative and legal evaluation, final report preparation, and awareness and information 6- Train the teams, under the supervision of national experts on how to fill up the forms of each chemical substance The second stakeholder engagement session took place in Beirut, Lebanon, in 2019. Its participants and objectives can be found in Table 2. 10 Table 2: Second Stakeholder Engagement Session – Participants and Objectives Participants - Ministry of Environment (MoEn) - Ministry of Electricity (MoElec) - Ministry of Industry and Minerals - Ministry of Agriculture (MoAgr) - Ministry of Oil Objectives 1- Review the results of the inventories of pesticides, PCBs, and dioxins and furans 2- Discuss these results with the stakeholder ministries 3- Agree on action plans that will follow the implementation of the convention’s national plan 4- Agree on Iraq’s priorities for post-convention plans A public and inclusive stakeholder consultation meeting took place at the MoEn, on Monday 18th of September 2023, with the objective of discussing the ESF instruments with the relevant stakeholders. Various participants from different sectors were present, as shown below, the no. Of women was 8 and foe men it was 18. • MoEn’s Representatives o Department of chemical monitoring and contaminated sites assessment o Department of international environmental relations o Department of citizens’ affairs o Department of planning and project management • Public Institutions o Ministry of Oil o Ministry of Science and Technology/department of management and disposal of Hazardous residues o Ministry of Agriculture / technical agent's office o Ministry of Agriculture / veterinary department o Ministry of Agriculture / department of planning and follow-up o Ministry of Agriculture / department of agricultural protection o Ministry of Industry and Minerals / department of industrial development and regulation o Ministry of Construction, Housing, Municipalities and Public Works / general municipalities directorate and environment department 11 o Ministry of Electricity / technical department and environment department • Private Sector o Iraqi Chemists' Union o International Committee of the Red Cross o Samaa’ Al Fayhaa’ Company o ELARD Consulting group • Representatives of the World Bank via the online platformRepresentees from the local communities. The session was introduced by Dr. Loai Sadik Mohammed, director chemical monitoring and contaminated sites assessment department, who explained the project components and the importance of all the parties involved. Afterwards, a comprehensive presentation exposed by the representative of the environmental and social consultants covered the following: o Introduction to the scope of the project: POPs definition and overview, project information, project objectives, project pillars, and project components and sub- components. o Environmental and Social Framework (ESMF): possible environmental risks and mitigation measures, possible social risks and mitigation measures, sub-projects environmental and social risk classification & E&S management tools, and institutional arrangements. o Stakeholder Engagement Plan (SEP): SEP objectives, main project stakeholders, engagement and information disclosure methods, Grievance Redress Mechanism, types of conflicts/complaints that may arise, and uptake channels to register grievances. o Environmental and Social Commitment Plan (ESCP): Main measures and actions to be undertaken, etc. Many interventions and discussions reflected various views and suggestions as outlined below: o Possibility of modifying, updating, and linking the project components to the environmental components such as inspecting residual POPs in environmental components, and hazardous waste treatment, disposal, and export. o Concerns related to the discharge of untreated aromatic compounds and sewage into the rivers, mismanagement of expired materials, and the environmental pollution in the Dora refinery. o The Ministry of Agriculture is ready to collaborate with MoEn to dispose all obsolete pesticides. o Challenges facing the treatment services, primarily for oil-related waste, in terms of landfills lack and the capabilities to deal with hazardous waste. o Proposal for developing a partnership with the General Authority for Food Safety, for the examination of POPs in food. 12 o The Ministry of Agriculture is ready to cooperate with MoEn through providing all the needed data. The detailed interventions and discussions, along with the consultation pictures, and the lists of registered participants, can be found in appendix 1. 3. Stakeholder Identification and Analysis 3.1. Methodology This section outlines the key stakeholders who will be informed and consulted about the project. To meet best practice approach, the project applies the following principles of stakeholder engagement during the preparation of the project, as well as across its lifetime: • Openness and Life-Cycle Approach: Public consultations for the project will be arranged during the whole life cycle, carried out in an open manner, free of external manipulation, interference, coercion, or intimidation; • Informed Participation and Feedback: Information will be provided to and widely distributed among all stakeholders in an appropriate format; opportunities are provided for communicating stakeholders’ feedback, for analyzing and addressing comments and concerns; and • Inclusiveness and Sensitivity: Stakeholders’ identification is undertaken to support better communications and build effective relationships. The participation process for the projects is inclusive. All stakeholders are encouraged to be involved in the consultation process. Equal access to information is provided to all stakeholders. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods. Special attention is given to vulnerable groups, in particular women and people with disabilities. For the purposes of effective and tailored engagement, stakeholders of the proposed project can be divided into the following core categories: • Affected Parties – persons, groups, public and other entities within the project Area of Influence that are directly influenced or impacted (actually or potentially, and negatively or positively) by the project and/or have been identified as most susceptible to change associated with the project, and who need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures; • Other Interested Parties – individuals/groups/entities that may not experience direct impacts from the project but who consider or perceive their interests as being affected by the project and/or who could affect the project and the process of its implementation in some way; and • Vulnerable Groups – persons who may be disproportionately impacted or further disadvantaged by the project(s) as compared with any other groups due to their vulnerable status and that may 13 require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the project. Vulnerable groups in this project include primarily women and informal workers in the waste and chemical sector. Other groups will include the elderly, people with disabilities, refugees, the poor, and people who do not know how to read and write. 3.2. Affected Parties, Other Interested Parties, and Disadvantaged/Vulnerable Individuals or Groups Key stakeholders including project affected parties, other interested parties, and disadvantaged/vulnerable individuals or groups are outlined in the table below. Table 3: Identified Key Stakeholders Stakeholder Role/ Interest in the Project Affected Parties Project workers, ocal communities and population in the direct and indirect areas of influence around the project interventions, who may be affected/ benefited due to the project activities or outcomes. These will be identified during the preparation phase and consulted as per the detailed ‘Stakeholder Engagement Plan’ to be prepared in compliance with the ESF requirements of the Bank. Other Interested Parties A. Public Institutions Ministry of Finance (MoF) National level ministry responsible for overall financial planning and budgeting. Will play a critical role in the implementation of the project, ensuring availability of counterpart financing and also designing future strategies for POPs management. Ministry of Planning (MoP) National level ministry responsible for design, development and policy formulation. Will be an important ministry for the project development, monitoring and also development policy and regulatory framework for POPs management. Ministry of Environment (MoEn) National level ministry responsible for the overall environmental (implementing agency, and management in Iraq and the competent authority of Stockholm author/owner of this SEP) Convention. Also responsible of the enforcement of environmental regulations, implementation of international environmental conventions, and implementation of the proposed project. Will also play an important role in the identification of policy and regulatory requirements for POPs management (contaminated sites assessment and remediations, monitoring, laboratory analysis and technical review, etc.) and coordinating with various project stakeholders. Ministry of Agriculture (MoAgr) National level ministry responsible for policy formulation, development of agriculture sector in the country and its implementation. Will also play an important role in the disposal of OPs by the project, formulation of policy and regulatory framework of OPs management in Iraq, and support the management of contaminated environmental hotspots. 14 Ministry of Electricity (MoElec) National level ministry responsible for electricity production, transmission (including its transmission and and distribution in Iraq. Will play an important role in the distribution companies) decontamination/disposal of PCBs by the project and formulation of policy and regulatory framework of PCB management in the country. Ministry of Oil National level ministry responsible for oil extraction, export/import and related activities. Will play an important role in the decontamination/ disposal of PCBs by the project and formulation of policy and regulatory framework of PCB management in Iraq. Ministry of Industry and Minerals National level ministry responsible for the industrial development, regulation, and promotion. Will play an important role in the decontamination/disposal of PCBs by the project and formulation of policy and regulatory framework of PCB management in the country. Ministry of Construction, Housing, National level ministry that provides policy and administrative oversight Municipalities and Public Works for municipalities. Will play an important role in the formulation strategies (MoCHMPWs) for municipal solid management and UPOPs generated due to open burning of waste. Governorates in the Project Area Regional body of the Government of Iraq, that provides administrative oversight on urban and rural bodies in its jurisdiction. Will play an important role in coordinating with various agencies and implementation of all project’s activities. Municipalities and local agencies Local entities who benefit from the project activities and anticipated improvements due to pollution management and health and environments in the area. Government sector involved in the Will play an important role in providing inputs to the formulation of waste solid waste and hazardous waste management strategies, reduction of open burning of waste and UPOPs collection, recycling, treatment and reduction. disposal B. Private Sector Associations and agencies involved in Entities who will play an important role in providing inputs to the production, supply and distribution of formulation of OPs management strategies and their implementation. pesticides and fertilizers Industries and agencies involved in Entities who will play an important role in providing inputs to the the production, supply, operation formulation of PCBs management strategies and their implementation. and maintenance of transformers and allied equipment Industries, associations and agencies Entities who will play an important role in providing inputs to the involved in the production, supply formulation of POPs management strategies and their implementation. and distribution of chemicals Agencies, contractors and operators Entities who will play an important role in providing inputs to the involved in the solid waste and formulation of waste management strategies, reduction of open burning hazardous waste collection, recycling, of waste and UPOPs reduction. treatment and disposal 15 Industry associations and Groups Key stakeholder who will play an important role in providing inputs to the formulation of policy and regulatory framework for POPs and their implementation. C. Additional Interested Parties International Organizations Many international organizations are actively in the environment and climate change sector in Iraq. Collaboration with these organizations will help in improving the project design and implementation of the project. This can also help in mobilizing counterpart financing required for the project. Some of the agencies actively involved in Iraq are EU, Kfw, GIZ, FAO, UNDP, UNEP, USAID and others. Civil Society, Non-Governmental Civil society and nongovernmental organizations can provide important Organizations and Think Tanks inputs that can help the project design and implementation. They may also be knowledgeable of the project area and the nearby populations, and can help play a role in identifying risks, potential impacts, and opportunities to consider and to be addressed by the project. Such agencies will be identified during the project preparation phase and will be involved during the consultation process. International NGOs and Think Tanks Number of international civil society and nongovernmental organizations are actively involved in POPs management. These organizations can provide important inputs that can help the project design and implementation. This will help in identifying risks, potential impacts, and opportunities to consider and to be addressed by the project. Such agencies will be identified during the project preparation phase and will be involved during the consultation process. National organizations and entities Number of organizations are actively involved in working with working for vulnerable groups and disadvantaged/vulnerable individuals or groups. They can provide IDPs important viewpoints and insights on issues/impacts of POPs on vulnerable groups and key aspects to be considered in the project design. End users of pesticides and fertilizers Groups who will play an important role in providing inputs to the formulation of OPs management strategies and their implementation. Academia Academia is an important resource, who can provide technical inputs and also insights to the project design based on their research and expertise. Media It is important for the project to collaborate with national and local media streams to understand local issues/impacts related to POPs, disseminate relevant information to the public. Accordingly, the project will identify relevant media channels and platforms they work with. These will include conventional media such as TV, Radio and Newspapers, as well as social media. 16 Disadvantaged and Vulnerable It is particularly important to understand project benefits and impacts and Groups how they affect disadvantaged or vulnerable individuals or groups, who often do not have a voice to express their concerns or understand the impacts of a project. Once the project geographical areas of intervention are selected, the specific vulnerable groups will be identified and included in the stakeholder engagement plan activities. Vulnerable groups in this project include primarily women and informal workers in the waste and chemical sector (power generation and transfer). Other groups will include elderly, persons with disabilities, refugees, the poor, and people who do not know how to read and write. 3.3. Summary of Project Stakeholder Needs A summary of key stakeholder needs is provided in the table below. Table 4: Key Stakeholder Needs Stakeholder Language Preferred Notification / Specific Needs (Daytime Topics to be Group Needs Engagement / Consultation Meetings, Accessibility) Discussed Methods / Approaches National Arabic/English Email, SMS, phone calls, During working hours, Project objectives, Public individual one-on-one virtual meetings implementation Institutions interview, focus group, mechanisms, and social media, etc. E&S implications Private Arabic/English Direct contact/email, social During working hours Project objectives, Sector media implementation Entities mechanisms, and E&S implications Local and English Email, phone calls, No specific need Project objectives, International interviews, social media, implementation Organizations etc. mechanisms, and E&S implications Vulnerable Arabic Phone calls, direct visit (if Daytime meeting in Project objectives, Groups possible) easily accessible implementation locations to mechanisms, and accommodate elderly E&S implications participants and if possible, equipped with childcare space for women attending with children 17 4. Stakeholder Engagement Program 4.1. Purpose and Timing of Stakeholder Engagement Program The main goal of the Stakeholders consultations and engagements is to ensure stakeholders, and particularly local communities in the targeted geographical areas are aware of the planned project activities, and understand the possible environmental and social implications, impacts, and justifications of such activities. The SEP aims also to improve the design of the project by adding some concrete propositions that are relevant to the project and that help ameliorate its outcome. The propositions will be taken into account and further consultations will help improve the successful implementation of the project. MoEn is planning to hold a series of consultation meetings throughout the project and with a possibility of adding relevant stakeholders according to the needs of the project. Additional identified stakeholders will accordingly be reflected in an updated SEP. The approved cleared SEP will be disclosed prior to project appraisal and following consultation with the identified stakeholders. As the SEP is a living document, it will be updated periodically and as necessary as agreed with the Bank following the provisions of the Environmental and Social Commitment Plan (ESCP). The program proposed in Table 5 includes the proposed timing of the various engagement activities. Precise dates cannot be confirmed until a schedule for the project activities is fixed. Stakeholders will be made aware of these events through various means of information disclosure as identified in Table 5. Local communities and vulnerable groups will be reached out to, through the support of local NGOs. 4.2. Proposed Strategy for Information Disclosure Table 5 below describes the information that will be disclosed, its formats and the types of methods that will be used to communicate this information to each of the stakeholder groups. Noting that once a sub-project is identified, consultations and SEA/SH engagements will be conducted during E&S instrument preparation and during the sub-project implementation. 18 Table 5: Proposed Strategy for Consultation and Information Disclosure Project Stage List of Information to be Methods Proposed Timetable Target Responsibilities Disclosed Stakeholders During project Project Description, ESMF Posting of documents on the Consultation on ESMF, SEP, Affected and MoEn preparation and and ESCP, SEP and websites of MoEn, MoA, MoElec. LMP and ESCP was conducted interested before start of Grievance Mechanism as per Bank’s ESF parties activities, and (GM) and SEA/SH referral Notification via local traditional requirements, on September throughout the pathways. and digital media, and relevant 18th, 2013. Vulnerable project lifetime social media with posting of groups ESIA/ESMP when documents for review including Other documents to be made relevant. link to download. available for consultation Women-only when prepared. groups All documents to be Hard copies of the documents will disclosed with executive be made available at the identified summary in Arabic. municipalities and distributed during consultation meetings as applicable. Series of targeted focus group discussions with affected parties. During project Post-Disclosure report Disclosure on MoEn, MoA, MoElec To be available throughout Affected and MoEn preparation documenting all websites and print-outs at the project time and updated interested stakeholders’ concerns identified municipalities (Arabic every 6 months. parties and feedback received version). during the public Vulnerable disclosure period, and Direct reporting back to groups how the project responds community and vulnerable groups. to them, including NGOs and community groups. Hard copies of the documents will be made available at governorates/municipalities. 19 Project Stage List of Information to be Methods Proposed Timetable Target Responsibilities Disclosed Stakeholders Prior to start of Information on planned Preparation of info-graphics and Once ESIA/ESMP reports are All stakeholders MoEn project activities OPs/ PCB site/hotspots leaflets that are easily ready for consultation. and especially selection process and understandable, culturally potentially disposal/ remediation appropriate and accessible to the affected parties, process local authorities and communities including ESIA/ESMP. and vulnerable groups. vulnerable groups Consultation sessions at the target areas on ESIA/ESMP reports. Dissemination via social media and community meetings. During treatment/ Provide information Official letters of notification, At least 4 weeks prior to start All stakeholders MoEn disposal of OPs/ associated with the start leaflets, advertisements available of activities and until and particularly PCBs and implementation of in both English and Arabic. completion. potentially the planned works. affected parties MoEn/contractor websites, public and vulnerable GM/SEA/SH referral meetings, mass media, local groups pathways. noticeboards and noticeboards at Keeping stakeholders the premises of municipalities. informed on any project activity that might affect them, including temporary road closures, changes to the planned schedule, and labor influx. 20 Project Stage List of Information to be Methods Proposed Timetable Target Responsibilities Disclosed Stakeholders After the Disclose information on Environmental and Social At the end of All stakeholders MoEn completion of the project’s Performance Report available in construction/rehabilitation and particularly treatment and environmental and social both English and Arabic. period. potentially disposal process performance. affected parties Disclosure on MoEn, and contractors’ websites. Hard copies of the documents will be made available at the identified municipalities, and distributed during consultation meetings. Throughout the Semi-annual reports MoEn Website. Every 6 months. All stakeholders MoEn project lifetime regarding environmental and social impacts, Hard copies of the documents will grievances and project be made available at the achievement. governorates/ municipalities, and distributed during consultation meetings. At project Project outcomes, results, Project results and evaluation End of project. All stakeholders MoEn completion and impacts. report. Environmental and Social Stakeholders’ perception report. Performance Report. 21 4.3. Proposed Strategy for Consultation MoEn will use the following methods for future consultations with each of the stakeholder groups. Methods used may vary according to target audience, for example: • Interviews and meetings with stakeholders and relevant organizations; • Surveys, polls, and questionnaires; • Public meetings, workshops, and/or focus groups on specific topics via participatory methods; • One on one interviews with each stakeholder; • Other traditional mechanisms for consultation and decision making; and • Use of traditional mass media and social media. It is recommended to engage with local NGOs to support the engagement activities. A consultation workshop with NGOs is proposed to be conducted at the early start of the project to present the project activities and SEP and identify how they can support SEP activities and the necessary resources needed. The PMU will be documenting stakeholder engagement activities and updating the SEP whenever required) and ensuring the dissemination of the documented activities on the Ministry’s website. The documentation will take place by including the following: • Date and location of each meeting, with a copy of the notification to stakeholders; • The purpose of the engagement (for example, to inform stakeholders of an intended project or to gather their views on potential environmental and social impacts of an intended activity); • The modality of engagement and consultation (for example, face-to-face meetings such as town halls or workshops, focus groups, written consultations, or online consultations); • Number of participants and categories of participants; • A list of relevant documentation disclosed to participants; • Summary of main points and concerns raised by stakeholders; • Summary of how stakeholder concerns were addressed and taken into account; • Issues and activities that require follow-up actions, including clarifying how stakeholders are informed of decisions; and • Specific measures adopted to reach out to vulnerable groups. 22 4.4. Proposed Strategy to Incorporate the View of Vulnerable Groups Considering the specific scope of this project, vulnerable/disadvantaged groups at this stage can be identified to be mainly poor women and poor informal workers in the waste and chemical sector (power generation and transfer). In order to ensure those groups are adequately involved in the project, specific engagement methods will be applied. Since the mentioned groups are cross-cutting throughout all different stakeholder groups, the envisioned methods are being applied throughout consultations with any of the listed stakeholders. Those methods include: • Women-only consultation sessions (for women as part of the communities or NGOs); and • Dedicated consultations with identified informal workers in each implementation areas; they will be identified through close coordination with the local authorities. Given that the ESF instruments are living documents, they get updated periodically and as necessary, allowing the integration of consultation feedback and views in the project design. 4.5. Timelines The timeline for implementation of all phases of the project is 72 months. During the implementation stages, consultative meetings will be held with stakeholders and vulnerable groups covering all activities associated with the project lifecycle. Deadlines for comments will be two weeks after the proposed consultation meetings. The SEP will be published on the MoEn’s website for the entire period of project development and the PMU will continue to review the SEP throughout project implementation and update it as needed. The implementation of SEP will be reflected in the progress reports, through its various phases, to ensure timely identification of any new stakeholders and interested parties and their involvement in the process of collaboration with the project including any feedback received from them that support successful project implementation. The methods of engagement will also be revised periodically and as needed to maintain their effectiveness and relevance to the project’s evolving environment. 4.6. Review of Comments Communication and feedback from stakeholders will be taken into consideration at each stage of this project as per Table 5. The stakeholders will be kept informed as the project develops, including reporting on project environmental and social performance and implementation of the stakeholder engagement plan and grievance mechanism. The MoEn and PMU plan to have several meetings with stakeholders, during and post implementation, to receive reviews and comments that will be reflected in progress reports and the future updated SEP. 4.7. Future Phases of Project All stakeholders will be kept informed as the project develops, including reporting on project environmental and social performance and implementation of the stakeholder engagement plan and grievance mechanism. MoEn will prepare semi-annual reports regarding environmental and social impacts, grievances and project achievement and will present these to stakeholders. 23 5. Resources and Responsibilities for Implementing Stakeholder Engagement Activities 5.1. Resources MoEn, in particular the PMU Team Leader and the Environmental & Social team specialists (that will be hired for the purpose of the project), will be in charge of the stakeholders’ engagement activities as outlined in this SEP. The E&S specialist to be hired will establish the process in due time. The Grievance Mechanism will be managed by the Project PMU E&S Specialist who will also ensure it is adequately functioning. The budget for the SEP is part of the project budget, and it will cover: • The fees of national E&S team and external consultants; • Preparation and design for dissemination and information materials; • Printing of dissemination and information materials; • Transportation, venues and F&B expenses; and • Operation of the Grievance Mechanism. An estimated budget to implement the SEP is provided below: • External consultants: USD 5,000 • Preparation and design for dissemination and information materials: USD 2000 • Printing of dissemination and information materials: USD 2000 • Transportation, venues and F&B expenses: USD 2000 • Total during preparatory phase: USD 11,000 During operations, and in addition to the salaries of E&S specialist at the PMU, an annual budget for SEP implementation is estimated as follows: • Budget for NGOs support: USD 5,000 • Graphic design / printing of new materials: USD 1,000 • Transportation, venues and F&B expenses: USD 1000 • Operation of the Grievance Mechanism: USD 2000 • Total annual Budget: USD 9,000 5.2. Management Functions and Responsibilities The SEP will be managed and implemented by MoEn, the PMU Team Leader and E&S team Specialists. The main tasks and responsibilities include: • Approval of all documentation containing project information that will be used for stakeholder engagements, before they are implemented and disclosed; • Approval of the content of this SEP and any subsequent revisions; 24 • Operation of the grievance mechanism; and • Preparation of Environmental and Social Performance Reports and their meaningful and widespread disclosure. They will also be responsible to delegate the below activities to relevant teams: • Preparing and printing all disclosure and media tools used for the project; • Providing information to stakeholders using the disclosure materials; • The practical and logistical organisation of all stakeholder engagement activities including contacting stakeholders to arrange meeting times/locations; • The preparation and issuing of all stakeholder engagement invitation letters; • Attendance/facilitation of all stakeholder engagement meetings/discussions, including room meeting bookings, refreshments, and the recording of all results and issues raised; • Generating an accurate record of all stakeholder engagement activities and noting any future actions required; and • Ensuring that stakeholder engagement results are compiled into a summary with the aim of informing the project design. Environmental and Social Performance Reports shall also include a summary of the engagements completed, during the reporting period and how they have been used to improve performance in the future. All the metrics used for monitoring and improving the stakeholder engagement performance will be reported in those reports. 6. Grievance Mechanism According to provisions and requirements of the WB’s ESS10 (Stakeholder Engagement and Information Disclosure), the MoEn will put in place a functioning, accessible, and inclusive Grievance Mechanism (GM) that is proportionate to the potential social risks and impacts of the project. Nevertheless, the key purpose of this GM is to provide an avenue for complaints and suggestions regarding project’s components. The implementation of this procedure will result in the reduction of social risks, generate systemic change to reduce the volume of grievances and enhance the quality of the relationship between the project and its stakeholders. 6.1. Specification The GM at central level will be integrated within the existing complaining system(s) at the MoEn, and will use available resources and assets, to the extent possible. But will, at the same time, ensure that the system has the following key features in place, as a minimum: • Decentralized: MoEn will put in place a decentralized GM for processing project- related complaints in local areas. This will be done by delegating power to the local directorates and partner agencies to act upon certain types of grievances/appeals. (1) Cases will be primarily resolved at the local level; and (2) Cases which are not resolved at local level will be resolved at the central level. 25 • Multiple-channel: MoEn will activate different channels for submitting a complaint. This will include installing complaint boxes in prominent places in all project offices, online grievance portal, and free hotlines, as well as allowing online submission of grievances and appeals by using social media platforms, whenever possible. • Standardized: MoEn will put in place a standardized process for receiving grievances/ appeals through assigning clear responsibilities to the PMU /Environmental and social specialist that have been assigned to the project from the existing staff. The existing staff will be trained on the SEP and GRM. In case of receiving any SEA/SH complaints, they should be carefully handled following the key principles of confidentiality and survivor’s consent. • Culture-sensitive: MoEn will handle grievances in a culturally appropriate manner, being district, objective, sensitive, and responsive to the PAPs. The GRM will allow for anonymous complaints to be raised and addressed. The mechanism will also facilitate lodging complaints in a simplified format and language, suitable for local cultures. Moreover, to manage the risks related to labor and/or SEA/SH, MoEn will assign female staff for receiving and processing grievances from women, where separation between men and women is the norm in the beneficiary community. Provision to ensure confidentiality as well as protocols for referring cases to specialized agencies will be included (e.g., cases related to gender-based violence, child neglect/abuse, etc). Labor grievances may be submitted by direct delivery to a sealed grievance box at the Project site, or by direct submission to an MoEn focal point. • Vulnerability-responsive: MoEn will put in place all measures that would facilitate grievances lodging from vulnerable groups, including, people with disabilities, women, and elderly in particular, minorities, poor student whom, based on their circumstances, been impacted by any of the project’s activities. These measures will take into account the special needs, protect privacy, and provide safe and secure channels. By so doing, the GM will build on existing grievance structures, coordinate with social service providers, and provide SEA/SH complainants with all possible means of protection starting from point of complaining until resolution. The GM will also provide adequate advice/ procedural assistance for referral to traditional justice mechanisms, whenever needed. • Outreach and Communication: MoEn will designate necessary staff at the local level, to receive, acknowledge, sort, refer, and report on grievances/appeals. Communication material will be developed, which will include brochures and social media channels. The material will not only describe grievance and appeals procedures, but also eligibility to the project, and selection criteria, as well as required documentation. • Complainant Satisfaction: The GM will design and make available a questionnaire to assess the level of satisfaction with responses. This is to be administered in line with best management practices. The level of satisfaction will also be surveyed and 26 measured annually. In addition, the GRM will allow complainants who were not satisfied with responses, to resort to a second appellate level. 6.2. The Proposed GM The proposed GM for the project aims to promptly, efficiently, and accurately resolve issues that could come across implementation of project’s activities. The design of the GM system will provide means for collecting supportive documents and evidence, investigating the problem, and supporting the final decision. Complainants would commonly approach this GM for many reasons, including those related to incomplete or no service, vague procedures, inappropriate/ unfair treatment by the staff, and harm (environmental and/or social) to individuals or groups because of carrying out the project’s interventions. Users of the system include all stakeholder categories. It would enable all affected parties submit their grievances directly, or indirectly through an intermediate. MoEn shall maintain, throughout the project implementation, and publicize the availability of grievance mechanisms, and take all measures necessary to implement the determinations made by such mechanism in a manner satisfactory to the Bank. The complainants should be given the possibility to remain anonymous if they do not wish to reveal their identity. Enquiries or complaints can be raised through different channels: The main GRM uptake channels are summarized below. • Phone calls to MoEn; • Physical visits to MoEn; and • Email to MoEn. Figure 1: MoEn’s Contact Information for Grievances The aim is to resolve or respond to the enquiries within the same call where no follow up is required. Where more time is required or for complex enquiries, the enquirer will be kept updated on the progress. All complaints/concerns and feedback will be documented in a grievance log. MoEn will ensure that the GM is culturally appropriate and accessible for all PAPs. All staff and operators who will be handling the GM will receive the necessary training for effective handling of complaints including on any potential SEA/SH related complaints, complaints from the elderly or other vulnerable groups and grievances regarding the 27 conduct of security personnel. The project undertakes to respond to all grievances within 30 calendar days of submission (see the detail in table below) – and more quickly in cases where there is high risk of escalation. While the GM process is described in the sections below, the table below provides a visual overview of the steps and associated timelines. Table 6: Overview of the Steps and Associated Timelines Step Number and Timeline Title Step 1 (Day 1) Uptake Step 2 (Day 2) Sorting and processing Step 3 (Day 3-6) Acknowledgment and follow up Step 4 (Day 7-10) Verification, investigation, and action by PMU investigation committee Step 5 (Day 11-30) Providing responses to GM users Step 6 (Quarterly) Reporting a. Uptake A range of channels will be made available for submission of feedback (Figure 1). In addition, hard copies of GM uptake forms will be available at different project sites. To submit feedback through the phone line, GM users can call between Sunday-Thursday from 8 AM to 2:30 PM. Queries, suggestions and complaints must be specific and concise to the extent possible, and contain basic information including: the name of the subproject, the location, the timeline of the issue/incident, persons involved, and contact details for non-anonymous GM users, and details of the incident/issue. b. Sorting and Processing Grievance Log will be maintained by the PMT focal point if s/he is the first point of contact with the GRM user. A summary of the feedback received, date that it was received, location (where relevant), channel through which it was received (in-person, letter, telephone etc.), whether an acknowledgement has been provided to the non-anonymous GM user that the issue is under consideration and/or has been escalated, whether the feedback is anonymous (this would include cases in which the person providing the feedback has expressed a preference for anonymity), whether the issue was resolved and if so, whether a final response has been provided to the non-anonymous user of the GM , whether the issue is pending and if so, whether it has been escalated to the PMU GM. c. Acknowledgment and Follow Up 28 If the identity of the GM user is known, then receipt of the feedback will be acknowledged within 3 business days. At the 20 business-day mark, if a complaint/question is still pending, the GM focal point will provide an update to the non-anonymous GM user, inform them if there will be delays in resolving their case, and provide the date for which they will be able to provide a response. The Grievance should classify as follows: High-Level Feedback Feedback received to be categorized as ‘high’ level instances will include issues that meet the following criteria: • Incidents that caused or may potentially cause significant or great harm to the environment, workers, communities, or natural resources, including issues of gender- based violence; • Incidents which entail failure to implement E&S measures with significant impacts or repeated non-compliance with E&S policies; • Incidents for which failure to address may potentially cause significant impacts that are complex and/or costly to reverse; and • Incidents that may result in fatality or some level of lasting damage or injury. This type of feedback will be acknowledged, and an investigation will be launched by the PMU/PMT and any other relevant stakeholders within 24 hours during workdays and within 48 hours if the feedback was received over the weekend. It should be noted that some types of incidents, including accidents and fatalities need to be reported to the World Bank. This guidance is provided in the Environment & Social Incident Response Procedures. Standard- Level Feedback If the identity of the aggrieved person is known and the grievance is classified as ‘standard’, the acknowledgement of grievance will be within 3 business days. At the 20 business-day mark, if a complaint/question is still pending, the GM focal point for the PMTs and the PMU will provide an update to the non-anonymous GM user, inform them if there will be delays in resolving their case, and provide the date for which they will be able to provide a response. d. Verification, Investigation, and Action Verification and investigation involve gathering information about the complaint to determine its validity and to generate a clear picture of the circumstances surrounding the issue under consideration. This process normally includes site visits, document reviews, a meeting with the GM user (if known and willing to engage), liaising with the PMU safeguards specialist(s) and meetings with other individuals and/or entities who can assist with resolving the issue. For complaints related to the misuse of funds, it may also require meetings with suppliers and contractors. Potential actions include responding to a query or comment, providing GM users with a status update by the 20-working day mark. Feedback that cannot be resolved at the PMT level should be referred to the PMU level for further investigation per the timelines and standards established for the GM. 29 e. Providing Responses to GM users This step entails informing GM users and the public at large about the results of the investigation and the actions taken. It is integral to enhance the GM’s visibility among beneficiaries and increase users’ trust in the system (making it more likely that they will provide feedback). The GM focal points of the PMTs can provide feedback by contacting the GM user directly (if his or her identity is known) within a 30-day period of receipt. Information included in the written response should include: setting out/summary of the feedback, detailing how the investigation was conducted, summarizing the facts, outlining the findings appropriate resolution along with the rationale for such resolution. Resolutions may include an explanation, apology, reconsideration, reimbursement, restitution– all are possible remedies. f. Closing and Reporting The overall accountability concerning the management of the Grievance Mechanism Procedure lies with the PMU. The E&S Specialist is responsible for overseeing the implementation, monitoring and treatment of the grievances. The GM coordinator will determine if the grievance has been closed to the satisfaction of the claimant. Once it has been closed, the information will be entered in the grievances register and the grievance can be closed. GRM focal points for all PMTs will report to the PMU GM coordinator on a monthly basis. Continuous communication should be maintained between the GM focal point within the PMT and the PMU GM coordinator in order to obtain, document and follow up the resolution of all grievances. The PMU GM coordinator will make consolidated reports available to the World Bank on a quarterly basis and on request. The reports should provide an overview of feedback received that is related to project implementation. Additional information should include: • Nature of the feedback; • Aggregate information on the GM users (including demographic – student, parent, gender, etc.); • Information on where the feedback was received and in what format; • Information on the status of complaints and queries (resolved, under review, etc.); • Information on how complaints and queries were resolved; • Information on unresolved complaints/queries and why they are not yet resolved; and • Recommendations for improving the GM. These recommendations should be based on the monitoring of the GM, specifically the extent of the GM’s functionality and the types of feedback that have emerged. g. Procedure for Appeal Aggrieved people who are dissatisfied with the outcome of their complaint can appeal the decision by resubmitting their complaint to the GM coordinator/ focal point within 30 working-days of receiving a response to the original submitted grievance. Subsequently, the GM coordinator/ focal point and other relevant personnel have 30 working-days to investigate 30 and address the issue. Additionally, the GRM coordinator/ focal point has 10 working-days to prepare a comprehensive response, including the findings of the investigation and the rationale of the determination. Accordingly, within a maximum of 40 working days, the appeal case should be closed. Lastly, if the aggrieved person is still not satisfied with the solution provided, they have I option to go to court. 6.3. Roles and Responsibilities of the GM Coordinator Throughout all the GM process, the GM coordinator must undertake the following: • Adhere to the designed community friendly grievance redress mechanism with clear and timely bound tiers and responsibilities to ensure dissemination on the local level. Develop quarterly grievance and redress report to be shared with World Bank; • Conducting field visits to ensure that the established grievance redress mechanisms are functioning properly and that the individual projects are implemented in a socially sustainable manner; • Reach out to local communities, including PAPs (If any), to raise awareness about the project and the implementation schedule; • Coordinate and provide support to the GM focal points who will be an assigned member of the PMU with a suitable training to handle complains according to the GM approved and mechanism and; and • Consolidate all Grievances received from the different project location, PMTs and reflect in the project report. 7. Monitoring and Reporting 7.1. Involvement of Stakeholders The ESCP and the SEP will require regular consultations with stakeholders to obtain feedback regarding the effectiveness of facilitation measures and will seek to gather suggestions for further improvements. These consultations will also be used to gather information about the project’s progress in meeting the results indicators, as noted in the project’s results framework. Biannual ESCP compliance monitoring reports will be prepared and submitted by the project’s Environment and Social Specialists throughout the project life. 7.2. Reporting Back to Stakeholder Groups The SEP will be reviewed and updated periodically as essential in the course of project implementation in order to guarantee that the information presented herein is consistent and 31 is the most recent, and that the identified methods of engagement remain appropriate and effective in relation to the project context and specific phases of the development. In addition, the current SEP will evolve into an operational action plan. This SEP cascades down most activities to a subsequent plan, as it provides general principles and recommendations but few concrete actions. Any major changes to the project related activities and to its schedule will be duly reflected in the SEP. Monthly summaries and internal reports on public grievances, enquiries and related incidents, together with the status of implementation of associated corrective/ preventative actions will be collated by responsible staff and referred to the senior management of the project. The monthly summaries will provide a mechanism for assessing both the number and the nature of complaints and requests for information, along with the project’s ability to address those in a timely and effective manner. Stakeholders will be kept informed as the project develops, including reporting on project environmental and social performance and implementation of the stakeholder engagement plan and grievance mechanism. Information on public engagement activities undertaken by the project during the year may be conveyed to the stakeholders in two possible ways: • Publication of project progress report, including interaction with the stakeholders. • A number of Key Performance Indicators (KPIs) will also be monitored by the project on a regular basis, including the following parameters: o Number of consultation sessions taking place; o Number of grievances received within a reporting period; and o Number of project-internal grievance resolved within a reporting period. 32 Appendix 1: Stakeholder Consultation Meeting – Discussion of the ESF instruments Purpose: Present the environmental and social instruments to the relevant stakeholders to gather their views, feedback, concerns, and suggestions. Date: September 18th, 2023. Location: Ministry of Environment – Iraq. Time: 10 a.m. – 1 p.m. List of Participants: • MoEn’s Representatives o Department of chemical monitoring and contaminated sites assessment o Department of international environmental relations o Department of citizens’ affairs o Department of planning and project management • Public Institutions o Ministry of Oil o Ministry of Science and Technology/department of management and disposal of Hazardous residues o Ministry of Agriculture / technical agent's office o Ministry of Agriculture / veterinary department o Ministry of Agriculture / department of planning and follow-up o Ministry of Agriculture / department of agricultural protection o Ministry of Industry and Minerals / department of industrial development and regulation o Ministry of Construction, Housing, Municipalities and Public Works / general municipalities directorate and environment department o Ministry of Electricity / technical department and environment department • Private Sector o Iraqi Chemists' Union o International Committee of the Red Cross o Samaa’ Al Fayhaa’ Company o ELARD Consulting group o Representatives of the World Bank via the online platform Meeting Agenda: 1. Session opening by MoEn’s representative and director of chemical monitoring and contaminated sites assessment department, Dr. Loai Sadik Mohammed, who welcomed the attendees, explained the project and its components, and explained the importance of all the parties involved in the project. 33 2. A comprehensive presentation was exposed by Dr. Bassam, representative of the environmental and social consultants carrying out the ESF instruments, following the outline below: o Introduction to the scope of the project: POPs definition and overview, project information, project objectives, project pillars, and project components and sub-components. o Environmental and Social Framework (ESMF): possible environmental risks and mitigation measures, possible social risks and mitigation measures, sub- projects environmental and social risk classification & E&S management tools, and institutional arrangements. o Stakeholder Engagement Plan (SEP): SEP objectives, main project stakeholders, engagement and information disclosure methods, Grievance Redress Mechanism, types of conflicts/complaints that may arise, and uptake channels to register grievances. o Environmental and Social Commitment Plan (ESCP): Main measures and actions to be undertaken, etc. Interventions and Discussions: 1. Intervention by Dr. Ihsan (from the board of consultants) about the possibility of modifying, updating and linking the project components to the environment such as air, water, inspection of residual POPs in environmental components, and hazardous waste treatment, disposal and export. He also raised the possibility of developing research laboratories and conducting specialized laboratory tests to meet the Stockholm Convention objectives. 2. Intervention by Dr. Akram from the Iraqi Chemists’ Union raising the following concerns: the discharge of untreated aromatic compounds into the water, the discharge of untreated sewage from residences and hospitals into rivers, management of expired materials, and the problem of environmental pollution in the Dora refinery… 3. Dr. Loai Sadik Mohammed clarified that the determination of the project components is based on the National Implementation Plan and the commitment of Iraq to the Stockholm Convention. The design of the components resulted from several meetings with the World Bank and GEF. Dr. Loai emphasized on the necessity to update the topographic surveys in Iraq, mentioning the flexibility of the World Bank in the project implementation. 4. Intervention by Dr. Mustafa from the Ministry of Agriculture showing the ministry’s readiness to dispose the pesticides at the Ministry of Agriculture. He also inquired about the implementation schedule. 5. The intervention by the president of the Chemists’ union raised the misuse of chemical substances in oil sites and the accumulation of hazardous substances in ports. He also highlighted the ongoing collaboration between his union and the Ministry of Industry’s Industrial Research and Development department, in terms of laboratory testing. 34 6. The representative of the Ministry of Science and Technology raised the challenges facing the treatment services, primarily for oil-related waste, in terms of landfills lack and the capabilities to deal with hazardous waste. 7. The representative of the Ministry of Agriculture proposed developing a partnership with the General Authority for Food Safety, for the examination of POPs in food. 8. Professor Amer informed that the beginning of activities should start by early 2024 in case of completion of all the procedures of the business plan and other logistics. 9. The representative of the Ministry of Electricity showed the Ministry's willingness to cooperate with the Ministry of Environment through providing all the needed data. Pictures: 35 36 Lists of Registered Participants: 37 Appendix 2: MoEn’s Grievance Mechanism at MoEn to receive the citizen's complaints/request/questions 38 39