United Nations World Food Programme


Sudan Emergency Safety Nets Project-SESP-
               P178989


     ENVIRONMENTAL AND SOCIAL
      COMMITMENT PLAN (ESCP)


          Final for Negotiations

               July 6, 2022




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                                 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN

1.   The United Nations World Food Programme (the Recipient) will implement the Sudan Emergency Safety Nets Project
     (the Project). The International Development Association (the Association), acting as the administrator of the Sudan
     Transition and Recovery Support Multi-Donor Trust Fund (MDTF), has agreed to provide financing for the Project.

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 Association. The
     ESCP is a part of the Financing Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP
     have the meanings ascribed to them in the referred agreement(s).

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 Association. Once adopted, said E&S instruments may be revised from time to time with prior written
     agreement by the Association.

4.   As agreed by the Association 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, the Recipient through Sudan Transition and Recovery Support Multi-Donor
     Trust Fund (MDTF) and the Association agree to update the ESCP to reflect these changes through an exchange of
     letters signed between the Association and the Recipient, the Country Director of the United Nations World Food
     Programme. Recipient shall promptly disclose the updated ESCP.




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ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sudan Emergency Safety Nets Project


MATERIAL MEASURES AND ACTIONS                                                                      TIMEFRAME                                 RESPONSIBLE ENTITY
MONITORING AND REPORTING
A     REGULAR REPORTING                                                                            Submit biannual reports to the            World Food Programme
      Prepare and submit to the Association regular monitoring reports on the environmental,       Association throughout Project            (WFP)
      social, health and safety (ESHS) performance of the Project, including but not limited to    implementation in form and matter
      the implementation of the ESCP, status of preparation and implementation of E&S              agreed upon with the Association.
      instruments required under the ESCP, stakeholder engagement activities, and
      functioning of the grievance mechanism(s).
B     INCIDENTS AND ACCIDENTS                                                                      Notify the Association no later than 48   WFP, Payment Service
      Promptly notify the Association of any incident or accident related to the Project which     hours after learning of the incident or   Providers, and Cooperating
      has, or is likely to have, a significant adverse effect on the environment, the affected     accident, using such reporting formats    Partners
      communities, the public or workers, including, inter alia, cases of sexual exploitation      as the Association may specify.
      and abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or
      multiple injury, security breach, among others. Provide sufficient detail regarding the      Provide subsequent report to the
      scope, severity, and possible causes of the incident or accident, indicating immediate       Association within a timeframe
      measures taken or that are planned to be taken to address it, and any information            acceptable to the Association.
      provided by any contractor and/or supervising firm, as appropriate.

         WFP will follow its protocol in order to comply with the Environmental and Social
         Standards and reporting obligations under the Grant Agreement (GA). Overall, the ESF
         and provisions in the GA shall govern and the WFP protocol is a means of
         implementation of the ESSs. The Bank confirms that this WFP protocol is materially
         consistent with Bank standards.

        Subsequently, at the Association’s request, prepare a report on the incident or accident
        and propose any measures to address it and prevent its recurrence.
ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS
1.1     ORGANIZATIONAL STRUCTURE                                                                 Relevant organizational structure shall     WFP, Payment Service
        WFP shall establish and maintain a functional environmental and social risk              be established within one month of          Providers and Cooperating
        management organizational structure throughout Project implementation equipped           Project Effective Date and will be          Partners
        with qualified staff (at least one environment and social specialist at the headquarter  maintained throughout Project
        and/or regional level), stakeholder engagement consultant and resources to support       implementation.
        management of ESHS risks and impacts of the Project. The Bank as part of
        strengthening the environmental and social shall share and review terms of reference,
        product monitoring, capacity building and sharing experiences.

         WFP will mobilize additional staff as needed to ensure the sound environmental, social,
         health and safety management of the Project. This will include community-based

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ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sudan Emergency Safety Nets Project


MATERIAL MEASURES AND ACTIONS                                                                       TIMEFRAME                                RESPONSIBLE ENTITY
      engagement activities of the Project, such may include subject matter specialists on
      GBV/SEA/SH, labor conditions, social inclusion, etc.

         WFP will also contract a third-party service providers to deliver cash and/or food, in
         conflict and hard to reach areas. WFP shall ensure Environmental, Social, Health and
         Safety (ESHS) compliance in all Project components, including compliance with this
         ESCP.
         WFP’s partner implementing entities including third-party service providers shall deploy
         the required environment E&S risk management personnel including managing GRM,
         and stakeholder engagement.

         WFP shall ensure, through its established organizational structure, that the E&S
         Specialist and/or other relevant staff fulfills her/his mandate relating to the
         environmental and social management as well as health and safety aspects of the
         Project, including the prevention and management of SEA/SH.
1.2      ENVIRONMENTAL AND SOCIAL INSTRUMENTS                                                       1. The WFP Guide to Personal Data        WFP
         WFP will prepare, adopt and implement appropriate environmental and social risk            Protection and Privacy Principles and
         management instruments to avoid/mitigate the risks associated with the Project             operational standards for the
         including, (i) WFP Policy on Occupational Safety and Health (OSH) (2016), Warehouse        protection of beneficiaries’ personal
         Management Handbook and the Food Storage Manual, and Fleet Manual, (ii) reliance           data in WFP’s programming shall be
         on the WFP Guide to Personal Data Protection and Privacy Principles and operational        implemented throughout Project
         standards for the protection of beneficiaries’ personal data in WFP’s programming ; and    Implementation.
         (iii) a security risk assessment and management plan will be prepared for respective
         areas with security risks.
                                                                                                    3. SEA/SH Prevention and Response
         WFP and its implementing partner entities, and Payment Service Providers shall             Action Plan shall be prepared and
         implement activities in line with the provisions outlined in those documents.              disclosed before disbursement.

         Labor Management Procedures (LMP), including measures for Project workers and              4. Labor Management Procedures
         workers Grievance Redress Mechanism; Social Assessment (SA) including risks of             (LMP), Security Management Plan
         discrimination, community tensions, and violence and respective mitigation measures        (SMP) and Social Assessment (SA) shall
         as well as Gender-Based Violence/Sexual Abuse and Exploitation (SEA)/Sexual                be prepared before disbursement; and
         Harassment (SH) Prevention and Response Action Plan (including Contractor’s Code of        will be implemented throughout
         Conduct) will be prepared by WFP and adopted by Payment Service Providers and              Project implementation.
         Cooperating Partners.




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ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sudan Emergency Safety Nets Project


MATERIAL MEASURES AND ACTIONS                                                                        TIMEFRAME                               RESPONSIBLE ENTITY
        The project operation manual shall include key environmental and social risk
        management commitments and references to environmental and social instruments.
1.3     MANAGEMENT OF CONTRACTORS.                                                                   The relevant ESHS measures shall be     WFP, Payment Service
        WFP shall manage and supervise contractors, including Payment Service Providers and          incorporated into the procurement       Providers and Cooperating
        Cooperating Partners, to ensure their compliance with the ESSs and the terms of this         documents before launching the          Partners
        ESCP, including by integrating ESHS specifications into procurement documents,               procurement process for the relevant
        contracts and sub-contracts, and ensuring compliance with their implementation               activities and shall thereafter be
        thereafter. These ESHS specifications shall include but not be limited to:                   complied with throughout the carrying
        ▪ Codes of conduct (CoC) for contractors/Payment Service Providers and their                 out of such activities.
             workers to prohibit SEA/SH and training of workers on their obligations under the
             CoC. Payment Service Providers and Contracted Partners shall implement the WFP          Supervise contractors/Payment Service
             prepared and costed SEA/SH Prevention and Response Action Plan.                         Provider throughout Project
        ▪ Monitor Contractor/Payment Service Provider commitment and compliance.                     implementation.
        ▪ Require contractors to implement all applicable EHS measures and provide details
             on contractor’s oversight on ESHS performance.
1.4     EXCLUSION CRITERIA                                                                           Throughout Project implementation       WFP, Payment Service
        The Project will mainly support unconditional cash and food transfer. Activities that                                                Providers and Cooperating
        may have significant adverse social impacts and may give rise to significant social                                                  Partners.
        conflict, shall be considered ineligible for financing under this Project.
1.5     PERMITS, CONSENT AND AUTHORIZATION                                                           Before carrying out of the respective   WFP, Payment Service
        WFP shall coordinate with Payment Service Providers and Cooperating Partners to              Project activities, and thereafter      Providers and Cooperating
        secure relevant permits, consents, and authorizations applicable to the Project activities   implemented throughout undertaking      Partners.
        from relevant National Authorities/ Agencies. The Recipient shall comply or cause to         any such conditions demanding
        comply, as appropriate, with the conditions established in these permits, consent and        activities.
        authorizations throughout Project implementation.
ESS 2: LABOR AND WORKING CONDITIONS
2.1     LABOR MANAGEMENT PROCEDURES                                                                  To be prepared before disbursements;    WFP and adopted by
        Consistent with ESS2 and to the satisfaction of the Association, prepare, adopt and          thereafter implement the LMP            Payment Service Providers
        implement Labor Management Procedures (LMP), which shall be applicable to all                throughout Project implementation.      and Cooperating Partners.
        Project workers, including, inter alia, provisions on working conditions, management of
        workers relationships, occupational health and safety (including personal protective
        equipment, and emergency preparedness and response), code of conduct (including
        relating to SEA and SH), forced labor, child labor, grievance arrangements for Project
        workers, and applicable requirements for contractors/ Payment service Providers and
        supervising firms.



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ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sudan Emergency Safety Nets Project


MATERIAL MEASURES AND ACTIONS                                                                       TIMEFRAME                               RESPONSIBLE ENTITY
2.2   OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES                                                 Maintained throughout Project           WFP, Payment Service
      Prepare, adopt, and implement Occupational, Health and Safety (OHS) measures, with            implementation as part of the LMP.      Providers and Cooperating
      particular reference to risks associated with Covid-19 and other communicable diseases.                                               Partners
2.3   GRIEVANCE MECHANISM FOR PROJECT WORKERS                                                       Establish grievance mechanism before    WFP and adopted by
      Establish and operate a grievance mechanism for Project workers, as described in the          disbursement; and thereafter maintain   Payment Service Providers
      LMP and consistent with ESS2.                                                                 and operate it throughout Project       and Cooperating Partners
                                                                                                    implementation.
2.4     WORKERS CODE OF CONDUCT                                                                     Code of conduct to be prepared and      WFP and adopted by
        The Recipient shall ensure that all tender documents, works contracts or service            disclosed before disbursement; and      Payment Service Providers
        contracts under the Project require suppliers / service providers, sub-contractors, or      thereafter implement throughout         and Cooperating Partners
        consultants to adopt a code of conduct, which will be signed by all workers financed        Project implementation.
        under the Project. This code of conduct will apply to contracts or services, ordered or
        carried out under such contracts or sub-contracts, and will cover gender-based violence,
        violence against children, sexual harassment, and sexual exploitation and abuse and will
        include an action plan for their effective application and provide training to this end.
ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT
3.1     Adopt and implement a Waste Management Plan (WMP), to manage hazardous and                  Adopt the WMP prior to commencing       WFP, Payment Service
        non-hazardous wastes, consistent with ESS3. Ensure that this WMP incudes waste from         any activity potentially involving      Providers and Cooperating
        transport-related activities.                                                               wastes, and thereafter implement the    Partners.
                                                                                                    WMP throughout Project
                                                                                                    implementation].
ESS 4: COMMUNITY HEALTH AND SAFETY
4.1     SEXUAL EXPLOITATION AND ABUSE/SEXUAL HARRASSMENT                                            SEA/SH Prevention & Response Action     WFP, Payment Service
        Prepare, adopt, and implement a Sexual Exploitation and Abuse/Sexual Harassment             Plan to be prepared and disclosed       Providers and Cooperating
        Prevention and Response Action Plan which assesses and indicates measures to                before disbursement; and thereafter     Partners
        manage specific risks associated with SEA/SH linked to the Project, in form and             implement throughout Project
        substance acceptable to the Association.                                                    implementation.

         The SEA/SH Prevention and Response Action Plan will include mitigation measures such
         as regular consultations with women and girls on project-related risks, the signing of a
         Code of Conduct for all project staff (including the WFP-ESRM structure, workers of
         Payment Service Provider, volunteers, etc.) with specific clauses on GBV/SEA/SH, a
         GRM sensitive to GBV/SEA/SH complaints with an accountability framework including
         referrals for survivors to GBV services, an awareness raising strategy targeting workers
         and community members on codes of conduct, reporting mechanisms in case of an
         incidence of SEA/SH and a response protocol to ensure survivors are referred to quality
         GBV services in a timely and ethical manner.

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ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sudan Emergency Safety Nets Project


MATERIAL MEASURES AND ACTIONS                                                                       TIMEFRAME                                  RESPONSIBLE ENTITY

         Develop corresponding Training Module for Contractors, Consultants, Clients and
         Workers, Payment Service Providers.

         WFP personnel in country shall adhere to the Sexual Exploitation and Abuse Prevention
         and Response – Policy and Procedures as well as the respective provisions in the LMP.
4.2      SECURITY MANAGEMENT                                                                          To be developed before disbursement
         Prepare, adopt and implement a Security Risk Assessment and Security Management              and maintained throughout Project        WFP
         Plan. WFP shall assess and implement measures to manage the security risks of the            implementation.
         Project, including the risks of engaging security personnel to safeguard Project workers,
         sites, assets, and activities. The SRA/SMP will include Journey Management Procedure
         for travels to guide project travels at-risk areas. The Project SRA/SMP will also inform on
         the nature of security personnel that will be required to oversee and monitor the
         implementation of security measures. The SRA & SMP will be guided by the principles
         of proportionality and GIIP, and by applicable law, in relation to hiring, rules of conduct,
         training, equipping, and monitoring of such personnel. WFP and its implementing
         partners shall complete assessments and plans before any physical engagement,
         especially in high-risk security or conflict prone areas.
4.3      COVID-19 PREVENTION MEASURES                                                                 One month after Project effective date   WFP
         The Recipient shall prepare, disclose, consult upon, adopt, and ensure the                   and maintained throughout Project
         implementation of COVID-19 prevention measures (awareness meetings, wash kits,               implementation.
         social distancing, respect of hygiene and management of waste from works, etc.),
         particularly during training sessions and events and food distribution activities in
         accordance with WHO and national requirements.
ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT
         This standard is not currently relevant.
ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES
         The project activities are not anticipated to have any adverse direct impacts on                                                      WFP
         biodiversity and living natural resources as no physical investments will be financed.
         However, this standard is considered relevant in relation to WFP considering these
         issues in its sourcing of food for this project. WFP shall establish requirements for
         assessment, management, monitoring and reporting on environmental issues.
ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES
7.1      INDIGENOUS PEOPLES PLANNING FRAMEWORK                                                        Social Assessment shall be updated and   WFP
                                                                                                      approved before disbursement; and will
                                                                                                      be implemented throughout Project
                                                                                                      implementation.

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ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sudan Emergency Safety Nets Project


MATERIAL MEASURES AND ACTIONS                                                                   TIMEFRAME                                   RESPONSIBLE ENTITY
      WFP shall update, adopt and implement the Indigenous Peoples Planning Framework
      (Social Assessment (SA) of the SFSP to set principles of IPs/SSHUTLCs consultation,
      targeting and activities implementation throughout the Project. The SA/IPPF shall be
      submitted to the Association for approval and disclosure.
7.2   GRIEVANCE MECHANISM                                                                       The project will rely on WFP GRM and        WFP
      The Recipient shall ensure that the grievance mechanisms established for the Project,     disclosed within before disbursement
      as described in the SEP are culturally appropriate and accessible to affected             as part of the SEP and updated if
      IPs/SSHUTLCs and take into account of the availability of judicial recourse and           needed; and thereafter implement
      customary dispute settlement mechanisms among the communities.                            throughout Project implementation.

        WFP shall also ensure that the Payment Service Providers who will be involved in the
        Project’s payments delivery services to adopt and implement the arrangements for
        grievance mechanism (including for IPs/SSHUTLCs), based on the ESF requirements.
        The Project’s grievance mechanism shall be outlined as part of the SEP.
        As required in ESS7 and ESS10, the stakeholder engagement process shall include
        stakeholder analysis and engagement planning, disclosure of information, in providing
        adequate, culturally appropriate forms of meaningful consultations and linguistically
        relevant content on the Project identification and implementation process and benefit
        sharing.
ESS 8: CULTURAL HERITAGE
        This standard is not currently relevant.
ESS 9: FINANCIAL INTERMEDIARIES
        This standard is not currently relevant.
ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE
10.1    STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION                              A draft SEP shall be prepared and           WFP
        WFP shall prepare, consult, adopt, disclose and implement a Stakeholder Engagement      disclosed prior to appraisal and shall be
        Plan (SEP). The SEP shall include measures to provide stakeholders with timely,         updated within before disbursement.
        relevant, understandable and accessible information, and consult with them in a         This plan will be adopted and
        culturally appropriate manner, which is free of manipulation, interference, coercion,   implemented (and updated, as needed)
        discrimination and intimidation, in a manner consistent with ESS 10 and acceptable to   throughout the Project
        the Association.                                                                        implementation.
10.2    PROJECT GRIEVANCE MECHANISM                                                             GRM as described in the SEP shall be        WFP
                                                                                                prepared & disclosed prior to appraisal
                                                                                                and updated before disbursement; and
                                                                                                thereafter maintain and operate the
                                                                                                mechanism throughout Project
                                                                                                implementation.

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ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sudan Emergency Safety Nets Project


MATERIAL MEASURES AND ACTIONS                                                                     TIMEFRAME                                  RESPONSIBLE ENTITY
      Establish, 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 accessible to all Project-affected parties, at no cost and without retribution,
      including concerns and grievances filed anonymously, in a manner consistent with
      ESS10.
      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.

      The GM shall be supported by a site-specific communications plan, as part of this
      Stakeholder Engagement Plan, and the Project Sub-component 2.1: Delivery systems
      (a) Outreach and Communication tailored to State context to ensure that local
      populations affected by the Project are aware of the existence of this mechanism and
      are aware of the procedures for lodging and handling complaints and other remedies.
10.3  COVID19 AND INFECTIOUS DISEASES                                                             Throughout Project implementation.         WFP
      Any stakeholder engagement activity, e.g., communities, development partners will
      comply with WHO guidelines and national protocols on social distancing and other
      measures to support the containment of the pandemic.
CAPACITY SUPPORT
CS1   Plan and deliver trainings to identified Project target groups, stakeholders, communities   A training plan for the Project shall be   WFP in consultation with
      to enhance their awareness of and mitigate environmental, social and health & safety        prepared within 60 days of the Project     stakeholders and
      risks and impacts, including but not limited to the following:                              Effective Date. It will then be            community leaders
      ▪ Specific aspects of environmental, social, health, security and safety assessment         implemented immediately and                (representation of
      ▪ Project activities implementation with standard precautionary measures to Covid-19        throughout the duration of the Project.    intergenerational, gender
      ▪ Community health, safety, and security                                                                                               and vulnerability
      ▪ GBV/ SEA/SH risk mitigation                                                                                                          considerations).
      ▪ Grievance Redress and Feedback Mechanism, including procedures to GBV/SEA/SH
          complaints
      ▪ Stakeholder Mapping and Engagement
      ▪ Communication campaigns to encourage Female Headed Households (FHHs) and
          other disadvantaged groups enrolment into the Project.
      ▪ Security issues and their management




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ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Sudan Emergency Safety Nets Project


MATERIAL MEASURES AND ACTIONS                                                                     TIMEFRAME                                  RESPONSIBLE ENTITY
CS2   Training for Project workers on environmental and social aspects, occupational health       A complete training plan for the Project   WFP, Payment Service
      and safety and response arrangements to emergency situations. These Project workers         shall be prepared 60 days of the Project   Providers and Cooperating
      will include volunteers to support the Project in community mobilization and awareness      Effective Date. It will then be            Partners.
      creation programs as well as in the grievance redress committees, contracted workers        implemented immediately and
      (Payment Service Providers, third-party service providers, partner implementing             throughout the duration of the Project.
      partners, Cooperating Partners), civil servants, specific WFP staff and consultants, etc.
      ▪ World Bank Environmental and Social Standards
      ▪ WFP Environmental Management System
      ▪ Labor Management, Occupational Health and Safety and provisions of workers GM
         as per LMP.
      ▪ Project activities implementation with standard precautionary measures to Covid-19
      ▪ Security issues and their management
      ▪ Sexual Exploitation and/or Sexual Harassment
      ▪ Prevention and reporting of SEA/SH
      ▪ GRM, including procedures to GBV/SEA/SH complaints
      ▪ Strategies and approaches for vulnerable groups inclusion into the Project.




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