THE REPUBLIC OF UGANDA MINISTRY OF LANDS, HOUSING AND URBAN DEVELOPMENT (MLHUD) EU FINANCING FOR LAND ADMINISTRATION IN UGANDA (P175732) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) November 2022 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Uganda (GOU) (the Recipient) will implement the EU Financing for Land Administration in Uganda Project (P175732) (the Project) with the involvement of the Ministry of Lands, Housing and Urban Development, as set out in the Grant Agreement. The International Development Association (the Association) has agreed to provide financing for the Project, as set out in the referred agreement. 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 Grant Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement. 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 and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient Accounting Officer of Ministry of Lands, Housing and Urban Development. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING: MLHUD Prepare and submit to the Association regular monitoring reports on the environmental, Consolidated quarterly Environmental social, health and safety (ESHS) performance of the Project, including but not limited to and Social (E&S) reports shall be the implementation of the ESCP, status of preparation and implementation of E&S submitted to the Association instruments required under the ESCP, stakeholder engagement activities, and throughout the project implementation functioning of the grievance mechanism(s) in a form and substance acceptable to t starting 6 months after the Project Association. effective date. After 6 months of project effectiveness reports shall be consolidated by the Project Implementing Unit (PIU) under the MLHUD and submitted to the Association on a quarterly basis. Mid-term and completion reports shall be submitted during the Mid- Term review period as agreed in the financing agreement. B INCIDENTS AND ACCIDENTS: MLHUD Promptly notify the Association of any incident or accident related to the Project which Notify the Association Task Team has, or is likely to have, a significant adverse effect on the environment, the affected Leader (TTL) not later than 48 hours of communities, the public or workers, including, inter alia, cases of sexual exploitation and learning of incident or accident abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or multiple injury [specify other examples of incidents and accidents, as appropriate for the Provide subsequent report to the type of operation]. Provide sufficient detail regarding the scope, severity, and possible Association with within 7 (seven) causes of the incident or accident, indicating immediate measures taken or that are working days following the planned to be taken to address it, and any information provided by any contractor incident/accident. It shall also be and/or supervising firm, as appropriate. reflected in the quarterly reports. Subsequently, prepare a report on the incident or accident and propose any measures to Notification/reporting system shall be in address it and prevent its recurrence. place throughout the Project life cycle. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE: MLHUD The project will be implemented through the Project Coordination Unit PCU at MLHUD, Project effectiveness and thereafter that is currently implementing the CEDP/CEDP AF project. The PCU shall recruit qualified maintain these positions throughout Environment Specialist and a qualified Social Development Specialist to support Project implementation management of ESHS risks and impacts of the Project. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS: MLHUD Adopt, disclose, and implement the Environmental and Social Management Framework Adopt the ESMF prior to project (ESMF) for the Project, consistent with the relevant ESSs. appraisal and thereafter implement the ESMF throughout Project implementation. Develop, adopt, disclose and implement other environmental and social instruments, such as site-specific Environmental and Social Impact Assessments (ESIAs) and ESIAs/ESMPs where necessary in place corresponding Environmental and Social Management Plans (ESMPs) consistent with the prior to commencement of associated relevant ESSs activities and implemented during the activities 1.3 MANAGEMENT OF CONTRACTORS: Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S As part of the preparation of Project Environmental instruments, the Labor Management Procedures, and code of conduct, into the ESHS procurement documents and respective Specialist and Social specifications of the procurement documents and contracts with contractors and contracts. Development Specialist supervising firms. Thereafter ensure that the contractors and supervising firms comply Supervise contractors throughout and cause subcontractors to comply with the ESHS specifications of their respective Project implementation. contracts. Contractors’ Environmental and Social Management Plans, Codes of Conduct, Contracts Prior to the start of sub-project activities for Workers, Labour Force Management Plans, Camps and Material Yards Establishment and throughout the project life cycle. and Management Plans, HIV/AIDS Management Plans, sub project specific Health, Safety and Environment (HSE) Management Plans shall be developed in coordination with the service providers and Supervising Consultants once they have been selected. 1.4 TECHNICAL ASSISTANCE: Ensure that the consultancies, trainings on gender and other Environmental and social Throughout Project implementation. MLHUD risk Management and other capacity building, are carried out in accordance with terms 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY of reference acceptable to the Association, that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES: Adopt and implement the Labor Management Procedures (LMP) for the Project, Adopt the LMP in time for preparation MLHUD including, inter alia, provisions on working conditions, management of workers of procurement documents, and relationships, occupational health, and safety (including personal protective equipment, thereafter implement the LMP and emergency preparedness and response), code of conduct (including relating to SEA throughout Project implementation. and SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. Project Consultants/contracted staff shall be managed in accordance with Contract terms and conditions. Contract terms and conditions shall be assessed for their compliance with the project labor management procedures. Overall project labor management procedures shall be integrated in the Project ESMF and Implementation Manual. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish, maintain, and operate a grievance mechanism for Project workers, as described Establish grievance mechanism prior to MLHUD in the LMP and consistent with ESS2. This will include a framework and procedures to engaging Project workers and receive reports and complaints from Project workers and a response and accountability thereafter maintain and operate it framework to handle such reports and complaints. Information about grievance throughout Project implementation. mechanism must be disseminated to Project workers. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Relevant aspects of this standard shall be considered, as needed, under action 1.2 As part of the ESMF and throughout MLHUD above. inter alia, measures to adequately manage and dispose any waste generated Project implementation. from the activities and use of resources in a sustainable manner. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Adopt the ESMF prior to project MLHUD Incorporate resource efficiency and pollution prevention and management measures in appraisal and thereafter implement the the ESMPs to be prepared under action 1.2 above. ESMF throughout Project implementation. ESS 4: COMMUNITY HEALTH AND SAFETY 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 4.1 TRAFFIC AND ROAD SAFETY; Throughout the project period MLHUD-PCU Adhere to traffic and road safety signs. 4.2 COMMUNITY HEALTH AND SAFETY: Prepare, adopt, and implement measures and action to assess and manage specific risks Same timeframe for the preparation MLHUD-PCU and impacts to the community arising from the Project, including but not limited to, and implementation of the behavior of workers, potential risks of disease transmission during boundary ESMF/ESMPs to incorporate measures demarcation, including the transmission of HIV/AIDS, COVID-19 and other communicable to mitigate such risks and implement it diseases, response to emergency situations. All workers shall adopt a MLHUD Safeguard throughout the project period Management Policy and community Health and safety action plan as part of the contracting 4.3 SEA AND SH RISKS: GBV and SEA Risks has been rated low using the World Bank’s assessment tool. MLHUD These measures will be implemented MLHUD Shall implement actions to further minimize this risk, including signing of enforceable prior to the start of activities that involve Codes of Conduct by workers, sensitization activities for workers/communities by workers and implemented throughout relevant Service providers and consultant staff and establishing GRM that provide the Project life cycle. pathways for reporting and referring GBV cases. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK: Adopt and implement a Resettlement Policy Framework (RPF) for the Project, consistent Adopt the RPF prior to appraisal, and MLHUD with ESS5. thereafter implement the RPF throughout Project implementation. 5.2 RESETTLEMENT PLANS: Adopt and implement the respective MLHUD RAP, including ensuring that before Adopt and implement a resettlement action plan (RAP) for each activity under the taking possession of the land and Project for which the RPF requires such RAP as set out in the RPF and consistent with related assets if the demarcation and ESS5. titling leads to such, full compensation has been provided and [as applicable] displaced people have been resettled and moving allowances have been provided. 5.3 GRIEVANCE MECHANISM: The grievance mechanism (GM) to address resettlement related complaints has been Throughout the RAP implementation MLHUD described in the RPF and will be included in the RAPs and SEP. period. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: Screen the project activities to avoid any activities that could result into long term/or MLHUD Screen project activities and integrate irreversible impacts on natural habitats and/or activities in protected areas., in into ESMPs prior to commencement accordance with the project ESMF and ESS6. and thereafter throughout Project Integrate in ESMPs measures to avoid and mitigation potential harm to natural habitats implementation in accordance with ESS6 in manner satisfactory to the Association. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 INDIGENOUS PEOPLES FRAMEWORK: MOLHUD Assess the nature and degree of the expected direct and indirect economic, social, The VMGF developed and adopted cultural, and environmental impacts on Indigenous Peoples who are present in, or have nighty days after project effectiveness to collective attachment to, the project area. project Appraisal. Preparation and implementation of Vulnerable and Marginalized Groups Framework The VMGP developed prior to (VMGFs) as part of the design of subprojects likely to impact these groups (Iks, Tepeth and implementation of activities in areas Batwas) and develop and implement a Vulnerable and Marginalized Groups Plans (VMGP) with Vulnerable and Marginalized Groups. And both VMGF and VMGP maintained and implemented throughout project implementation 7.3 GRIEVANCE MECHANISM: The grievance mechanism (GM) to address resettlement related complaints has been Prior to commencement of activities MLHUD described in the ESMF, RPF,SEP and will be covered in the VMGF and VMGP. and maintained throughout the project. ESS 8: CULTURAL HERITAGE 8.1 CULTURAL HERITAGE RISKS AND IMPACT: Adopt and implement measures for safeguarding Cultural Heritage in accordance with the Prior to implementation of activities MLHUD guidelines of the ESMF, and consistent with ESS8. Identify measures to address risks and and monitored throughout Project impacts on cultural heritage that may occur during demarcation. implementation period. 8.2 CHANCE FINDS: Adopt, and implement the chance finds procedure described in the ESMF and ESMPs. MLHUD MLHUD shall work with the Department of Museums and Monuments at the Ministry of 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Tourism, Wildlife and Antiquities (MoTWA) and the Department of Culture and Family Prior to implementation of activities Affairs of MGLSD to implement the Chance Finds Procedure prior to implementation of and monitored throughout Project activities in such locations and maintained throughout the project implementation period. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION: Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project consistent Adopt the SEP prior to appraisal and MLHUD with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, and thereafter implement the SEP relevant, understandable, and accessible information, and consult with them in a throughout Project implementation. culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination, and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM The MLHUD has in place an establish GRM and a toll freeline for reporting of grievances. Establish the grievance mechanism at MLHUD The project will leverage on the already established GRM, asses its functionality and commencement of the project and strengthened it to take and resolve the project grievances and ensure that these systems thereafter maintain and operate the are established at all levels, DLGs, Sub County, Parish and local communities as mechanism throughout Project stipulated in the project GRM. publicize, maintain, and operate an accessible grievance implementation. 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. And as elaborated in the ESMF and SEF. The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 Update and implement the SLACC operational manual and SLAAC training manual to The training manual adopted during MLHUD incorporate Environmental and Social Risk Management related related trainings in project effectiveness and implemented compliance with the World Bank Environment and Social Framework and the Country’s throughout the project. legislation. Capacity building will be required for respective groups of people such as Ministry Prior to the start of activities and personnel, district, other MDAs closely associated with project, communities among throughout project implementation others. Specifically, the training should entail the following: 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1. The Environmental, Social, and relevant staff at MLHUD - PCU must be trained on all of the following areas that relate to their duties: • World Bank ESSs • Implementation of Stakeholder Engagement Plan (SEP) including stakeholder mapping, and its monitoring and evaluation • Implementation of Labour Management Procedures (LMP) • Implementation of Grievance Redress Mechanisms (GRM) • Occupational health and safety management, including First Aid courses to employees and Environment and Social Incident reporting procedures (ESIRT) under the project • Emergency preparedness and response procedures • Implementation of Environmental and Social risks management practices identified by Project actors during Project implementation. • SEA/SH and GBV • Implementation of the VMPP (FPIC, grievance Management) • Child labor and child protection restrictions. • Sensitization on National land legislation, and Environmental Management. 2. District and Sub-county Liaison personnel in respective Project districts will be trained on: (Labour Officers, CDOs, Commercial officers) • General ESF requirements. • Implementation of SEP, LMP and GRM, and oversight • ESMP Checklist preparation, updates, and oversight • Gender and GBVs aspects in the project. • SEA/SH and GBV • Child labor and child protection. • Procedures for identifying project beneficiaries • Monitoring and reporting on ESMP implementation and project activities • Sensitization on National land legislation and Environmental Management. 3. Communities and other stakeholders will be trained on: • Emergency preparedness and response • Community health and safety, including First aid courses to interested community members • Grievance Redress Mechanism (GRM) procedures • Sensitize the community on Uganda land tenure 9|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY • Sensitize the community on land rights and women’s rights to land. • sensitization of the community on natural resource conservation, protection, and regulated use of ecologically sensitive ecosystems. 10 | P a g e