REPUBLIC OF GHANA GHANA PRODUCTIVE SAFETY NET PROJECT 2 ORIGINAL FINANCING (P175588) AND ADDITIONAL FINANCING (GPSNP 2 AF) (P180659) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN April 2023 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Ghana (the Recipient) is implementing the Ghana Productive Safety Net Project 2 (GPSNP 2) (the Project), with the involvement of the Ministry of Local Government, Decentralization and Rural Development (MLGDRD) and the Ministry of Gender, Children and Social Protection (MoGCSP), as set out in the Financing Agreement. The International Development Association (the Association) has agreed to provide the original financing (P175588) and additional financing (P180659) for the Project, as set out in the referred agreement. This ESCP supersedes previous versions of the ESCP for the Project and shall apply both to the original and the additional financing for Project referred to above. 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. 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 the Ministry of Local Government, Decentralization and Rural Development (MLGDRD) and the Ministry of Gender, Children and Social Protection (MoGCSP) and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Chief Director of the MoGCSP and Chief Director of the MLGDRD. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Ghana Productive Safety Net Project (GPSNP) – 2 - Additional Financing MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit, semi-annual and annual reports Coordination units of both to the Association throughout Project Ministries (MLGDRD, Prepare and submit to the Association regular monitoring reports on the environmental, implementation, commencing after the MOGCSP) social, health and safety (ESHS) performance of the Project, including but not limited to Effective Date. the implementation of the ESCP, status of preparation and implementation of E&S instruments required under the ESCP, stakeholder engagement activities, and Submit each report to the Association functioning of the grievance mechanism(s) no later than 30 days after the end of each reporting period. B INCIDENTS AND ACCIDENTS Promptly notify the Association of any incident or accident related to the Project which Notify the Association no later than 48 Coordination units of both has, or is likely to have, a significant adverse effect on the environment, the affected hours after learning of the incident or Ministries (MLGDRD, communities, the public or workers, including, inter alia, cases of sexual exploitation and accident and within 24 hours for SEA/SH MOGCSP) abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or incidents and fatalities. multiple injury [specify other examples of incidents and accidents, as appropriate for the type of operation]. Provide sufficient detail regarding the scope, severity, and possible causes of the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor Provide subsequent report to the and/or supervising firm, as appropriate. Association within a timeframe acceptable to the Association (not more Subsequently, at the Association’s request, prepare a report on the incident or accident than 1 month after the and propose any measures to address it and prevent its recurrence. incident/accident) C CONTRACTORS’ MONTHLY REPORTS Require caterers and contractors and supervising firms (for the labour-intensive public Submit the monthly reports to the Coordination units of both works) to provide monthly monitoring reports on ESHS performance in accordance with Association upon request as annexes to Ministries (MLGDRD, the metrics specified in the respective bidding documents and contracts and submit such the reports to be submitted under MOGCSP) reports to the Association. action A above. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Maintain the organizational structure that currently exists on the original project with Maintain the existing organizational qualified staff and resources to support management of E&S risks and impacts including structure throughout Project an Environmental and Social Safeguards Specialist. implementation. MLGDRD/RDCU 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Ghana Productive Safety Net Project (GPSNP) – 2 - Additional Financing MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY The Environmental and Social Safeguards Specialist, Gender Officer and Environment MoGCSP and Social focal persons at the zonal level currently implementing the Ghana Productive Safety Net Project 2 (P175588) (Original Financing or GPSNP 2) will continue to provide E&S support for risk identification, management, and reporting for GPSNP-2 Additional Financing (GPSNP 2 AF). They will be supported by existing Environmental and Social Safeguards Officers at the Zonal level to implement the Project and to adequately support the management of E&S risks. An Environmental and Social Safeguards Specialist shall be hired at the MLGDRD to The Environmental and Social provide E&S implementation support to the Project. At the MoGCSP, a Gender Focal Safeguards Specialist at the MLGDRD Person shall be appointed to support the implementation of the gender and SEA/SH and Gender Focal Person at the prevention plan as it relates to their subprojects. MoGCSP shall be appointed before the Effective Date. The Regional Development Coordinating Unit (RDCU) and the Ghana School Feeding Program (GSFP) secretariat may also hire external expertise and consultancy services for specific E&S activities, where necessary. This structure shall be maintained throughout Project implementation. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS • The ESMF and RPF shall be Adopt and implement the Environmental and Social Management Framework (ESMF) implemented throughout the MLGDRD/RDCU and Resettlement Policy Framework (RPF) that were prepared for GPSNP 2, consistent Project implementation. MoGCSP with ESSs and in a manner acceptable to the Association. The ESMF includes Labor • ESIAs/ ESMPs when required, shall Management Procedures (LMP), and Integrated Pest Management Plan (IPMP), and be prepared, and submitted for the Occupational Health and Safety (OHS) management plan. Association’s approval before launching the bidding process for When required for the specific subproject, under the Labor-Intensive Public Works the respective subproject. Once (LIPW) subprojects under Component 2 and/or the Ghana School Feeding Program approved, the ESMPs are carried activities under Component 3, prepare, disclose, consult upon, adopt and implement an out throughout Project Environmental and Social Impact Assessment (ESIA), and corresponding Environmental implementation. and Social Management Plan (ESMP), as set out in the ESMF and consistent with the • Occupational Health and Safety relevant ESSs. Management Plan shall be prepared and submitted for the Bank’s approval before launching the procurement process for caterers. Once approved the OHS will be carried out throughout Project implementation. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Ghana Productive Safety Net Project (GPSNP) – 2 - Additional Financing MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 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 MLGDRD/RDCU instruments, the Labor Management Procedures, and code of conduct, into the ESHS procurement documents and MoGCSP specifications of the procurement documents and contracts with contractors and respective contracts. supervising firms, and GSFP caterers. Thereafter ensure that the contractors and • Supervise contractors throughout supervising firms and caterers comply and cause subcontractors to comply with the ESHS Project implementation. specifications of their respective contracts. 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. MLGDRD/RDCU MoGCSP Ensure that the consultancies, studies, capacity building, training, and any other technical assistance activities under the Project are carried out in accordance with terms 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. 1.5 CONTINGENT EMERGENCY RESPONSE FINANCING a) The adoption of the CERC Manual a) Ensure that the CERC Manual includes a description of the ESHS assessment and and the CERC ESMF in form and management arrangements for the implementation of the CERC component in substance acceptable to the Association accordance with the ESSs. is a withdrawal condition under Section III.B.1(b)(ii) of Schedule 2 of the b) Adopt any environmental and social (E&S) instruments which may be required for Financing Agreement for the Project. activities under the CERC component (Component 6) of the Project, in accordance with the CERC Manual and the CERC ESMFthat will be finalized before CERC activation, and b) Adopt any required E&S instrument thereafter implement the measures and actions required under said E&S instruments, and include it as part of the respective within the timeframes specified in said E&S instruments. bidding process, if applicable, and in any case, before the carrying out of the relevant Project activities for which the E&S instrument is required. Implement the E&S instruments in accordance with their terms, throughout Project implementation. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES MLGDRD/RDCU 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Ghana Productive Safety Net Project (GPSNP) – 2 - Additional Financing MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Update, redisclose, adopt and implement the Labor Management Procedures (LMP) Update, redisclose, and adopt the LMP MoGCSP developed for GPSNP2 as part of the ESMF, including, inter alia, provisions on working not later than three months after the conditions, management of workers relationships, occupational health and safety Effective Date of GPSNP 2 AF and (including personal protective equipment, and emergency preparedness and response), thereafter implement the LMP code of conduct (including relating to Sexual Exploitation and Abuse (SEA) and Sexual throughout Project implementation Harassment (SH)), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms as While the updates are being finalized, well as GSFP caterers. implement the original LMP prepared for the GPSNP 2. The LMP will be referenced in the ESHS specifications of the procurement documents with requirements for contractors and caterers to update into a Plan during implementation and comply with its requirements consistent with ESS2 (including, inter alia, the provisions of protective gear for cooks, timely payment of cooks, employment of minors, specification of work hours for the GSFP cooks). 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Operationalize the grievance mechanism prior to engaging Project MLGDRD/RDCU The Recipient and contractor shall maintain and operate within the Project grievance workers and thereafter maintain and MoGCSP/GSFP mechanism for all categories of Project workers, as described in the LMP and consistent operate it throughout project with ESS2. implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Adopt and implement a Waste Management Plan (WMP), to manage hazardous and WMP will be adopted prior to MLGDRD/RDCU non-hazardous wastes including food waste, consistent with ESS3. commencement of activities for MoGCSP/GSFP Component 2 (LIPW) and Component 3 (GSFP), and to be maintained throughout implementation. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Resource efficiency and pollution prevention and management measures identified in • Adopt the necessary plans (ESMPs, MLGDRD/RDCU the ESMF or any subsequent tool to be occasioned by subprojects shall be complied with IPMP) and procedures (SOPs) prior MoGCSP/GSFP consistent with ESS3. Subproject-specific measures will be included in the ESMPs that to implementation of Labor - will be prepared before commencement of any civil work. The Integrated Pest Intensive Public Works (LIPW) Management Plan (IPMP) annexed to the ESMF will be implemented by the Recipient as subprojects and Ghana School required. Feeding Programme (GSFP) s. Potential sources of food contamination (use of chemicals during storage and cleaning), • Maintain throughout Project hygienic state of storage facilities, handling and disposal of garbage, use of expired food implementation ingredients), and smoke impacts on health will be mitigated by complying with all relevant standard operating procedures (SOPs). 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Ghana Productive Safety Net Project (GPSNP) – 2 - Additional Financing MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY • Prior to implementation of LIPW MLGDRD/RDCU Project Contractors shall be required to implement measures and actions in the sub activities. project checklist/ technical specifications to assess and manage traffic and road safety • Maintain throughout Project risks as required. implementation 4.2 COMMUNITY HEALTH AND SAFETY Prepare, adopt, and implement measures and actions to assess and manage specific risks • Prior to commencement of civil MLGDRD/RDCU and impacts to the community arising from Project activities and include these measures works MoGCSP/GSFP in any ESMP, to be occasioned by the ESMF, in a manner acceptable to the Association. • Maintain throughout Project The Project shall adopt and implement the stand-alone COVID-19 Response Plan implementation. prepared for the Original GPSNP 2 to assess and manage the risks of spread of COVID-19. 4.3 SEA AND SH RISKS Implement the standalone SEA/SH Action Plan prepared for the project and integrate Implement the SEA/SH Action Plan requirements as part of the ESMPs developed for relevant subprojects, to assess and throughout Project implementation. MLGDRD/RDCU manage the risks of SEA and SH, all consistent with ESS4. MoGCSP 4.4. DAM SAFETY Prior to commencement of civil works Assess the dam safety risks associated with the rehabilitation of small earth dams and concerning the relevant LIPW dugouts under LIPW activities and prepare and implement an operational and activities maintenance plan including an emergency preparedness plan as part of the ESMP prior to commencing civil works, all consistent with ESS4. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK Adopt the RPF for the GPSNP 2 prior to Implement the existing Resettlement Policy Framework (RPF) developed for the Project, the implementation of the GPSNP 2 AF, consistent with ESS5, and should be implemented throughout the project. and thereafter implement the RPF MLGDRD/RDCU throughout Project implementation 5.2 RESETTLEMENT PLANS RAPs shall be submitted for the Association’s approval, and once The MLGDRD/ RDCU shall prepare, disclose, consult upon, adopt, and implement approved, implemented prior to MLGDRD/RDCU resettlement action plans (RAPs) in accordance with ESS 5 and consistent with the commencing Project activities that requirements of the RPF that has been prepared for the Project, in a manner acceptable involve land acquisition and to the Association. resettlement, including ensuring that before taking possession of the land and related assets, full compensation has been provided and, as applicable, displaced people have been resettled and moving allowances have been provided. 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Ghana Productive Safety Net Project (GPSNP) – 2 - Additional Financing MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 5.3 GRIEVANCE MECHANISM The grievance mechanism to address resettlement-related complaints shall be described Prior to commencement of MLGDRD/RDCU in the RPF, RAPs and SEP, and will be completed before commencement of Project resettlement activities and maintained activities. The GRM will incorporate existing GPSNP2 GRM systems in place at the throughout implementation implementing agencies and the local level. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS The MLGGRD through the RDCU will avoid adverse impacts on biodiversity and habitats Throughout Project Implementation MLGDRD/RDCU by screening the relevant subprojects for these impacts in accordance with the ESMF and excluding ineligible investments listed in the ESMF. Where avoidance of such impacts is not possible, the Recipient shall adopt and implement measures and actions for biodiversity impact mitigation as required in the ESMF and consistent with ESS6. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not relevant. ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS The MLGDRD shall adopt and implement the Chance Finds procedure described in the Implement the procedures throughout MLGDRD/RDCU ESMF developed for the Project, consistent with ESS8. Project implementation. In the event of a find or the observation of a cultural practice, implement the guidelines detailed in the ESMF and contact the relevant government agencies that is entrusted with the protection of cultural heritage in Ghana to assist to preserve such finds. ESS 9: FINANCIAL INTERMEDIARIES Not relevant. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Redisclose, adopt and thereafter implement the updated Stakeholder Engagement Plan Redisclose, and adopt the updated SEP, MLGRD/RDCU (SEP) for the Project consistent with ESS10, which shall include measures to, inter alia, and thereafter update as needed, and MoGCSP provide stakeholders with timely, relevant, understandable and accessible information, implement the SEP throughout Project and consult with them in a culturally appropriate manner, which is free of manipulation, implementation. interference, coercion, discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM MLGRD/RDCU 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Ghana Productive Safety Net Project (GPSNP) – 2 - Additional Financing MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Publicize, maintain, and operate an accessible grievance mechanism (Single Window CE The GRM is already in place; Maintain MoGCSP Service) that already exists on the parent project, to receive and facilitate resolution of and operate the mechanism throughout concerns and grievances in relation to the parent Project and AF, promptly and Project implementation. 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. CAPACITY SUPPORT CS1 Training will be required for new PIU staff and Project workers on: • stakeholder mapping and engagement Throughout project implementation MLGRD/RDCU • specific aspects of environmental and social assessment MoGCSP • emergency preparedness and response • community health and safety. CS2 The MLGRD shall ensure that relevant project actors are trained in the following areas: Target Groups and Timeframe for MLGRD/RDCU • The project’s GRM Delivery MoGCSP • Stakeholder roles and engagement • Training is required for all relevant • E&S requirements (impacts and mitigation measures) of project activities project actors at the district • Subproject Environmental and Social screening (Caterers, Cooks, Desk officers and • Occupational Health and Safety Community Development Officers, • Emergency preparedness and response Works Engineers, Contractors, and • Training on COVID 19 transmission, prevention, preparedness, and response their supervisors), and community • SEA/SH Risk Mitigation levels (Facility Management • Disability inclusion training Committee members) • Documentation and reporting • Training will be done before commencement of civil works, and annually thereafter throughout implementation, as needed 9|Page