Nigeria: Accelerating Resource Mobilization Reforms PforR (TA Component) P177308 [Draft] ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) [March 27, 2024] 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Federal Republic of Nigeria will implement the Investment Project Financing (IPF) Technical Assistance Component (the Project) of the Nigeria Accelerating Resource Mobilization Reforms PforR, with the involvement of the following Project Implementing Entities/ministries/agencies : Office of the Permanent Secretary of Finance, Federal Ministry of Finance, Federal Inland Revenue Service, Nigeria Customs Service, as set out in the Financing Agreement and the Project Agreement.1 The International Development Association (Association), has agreed to provide financing for the Operation as set out in the referred agreement(s). The operation consists of a Program-for-Results Financing component (the “Program�) and an Investment Project Financing component (the “Project�). 2. The Recipient through the office of the Permanent Secretary of Finance 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 and the Project Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred 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 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 Office of the Permanent Secretary of Finance, Federal Ministry of Finance, Federal Inland Revenue Service, Nigeria Customs Service, and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient, Permanent Secretary of the Finance Lydia Jafiya, Permanent Secretary of Finance. The Recipient shall promptly disclose the updated ESCP. 1 Use “Financing Agreement� for IDA financing. Use “Loan Agreement� for IBRD financing. Use “Grant Agreement� for TF financing. Add a reference to “Project Agreement� where there is one. Consult with the Project Lawyer for correct references. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Half-yearly/ six-monthly reports to Project Coordination the Association throughout Unit (PCU) housed in Prepare and submit to the Association regular monitoring reports on the Project implementation, the Technical Service environmental, social, health, and safety (ESHS) performance of the Project, including commencing after the Effective Directorate in the but not limited to the implementation of the ESCP, status of preparation and Date. Office of the implementation of E&S instruments required under the ESCP, stakeholder Permanent Secretary engagement activities, and functioning of the grievance mechanism(s). of Finance, and the Project Implementation Unit (PIUs) at the Federal Inland Revenue Service, Nigeria Customs Service B INCIDENTS AND ACCIDENTS Notify the Association no later PCU/PIUs than 48 hours after learning of the Promptly notify the Association of any incident or accident related to the Project that incident or accident. has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public, or workers, including, inter alia, cases of sexual exploitation Provide subsequent reports to the and abuse (SEA), sexual harassment (SH), and accidents that result in death, serious Association within a timeframe or multiple injuries [specify other examples of incidents and accidents, as appropriate acceptable to the Bank, as for the type of operation]. Provide sufficient detail regarding the scope, severity, and requested. 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 and/or supervising firm, as appropriate. 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. C CONTRACTORS’ REPORT Half-yearly/ six-monthly reports as PCU/PIUs annexes to the reports (to be Require contractors and supervising firms to provide REGULAR monitoring reports on submitted under action A above) environmental, social, and health and safety (ESHS) performance in accordance with to the Association throughout the metrics specified in the respective bidding documents and contracts and submit Project implementation, such reports to the Association. commencing after the Effective Date. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.1 ORGANIZATIONAL STRUCTURE One Environment and one social PCU [Specify whether additional staff need to be assigned/hired to work on the Project.] officer will be hired no later than three months after the Establish and maintain a PCU/PIUs throughout the project implementation with effectiveness. qualified staff and resources to support the management of ESHS risks and impacts of the Project, in a manner satisfactory to the Bank. Organizational structure to be • Assign focal officials responsible for ensuring E&S PAP implementation. maintained throughout the Project implementation. Hire qualified Environment and Social Officers/Consultants and provide a capacity building/system strengthening program to strengthen his skills PCU 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS PCU/PIUs 1. Implement the ESMP 1. The Federal Ministry of Finance, Budget and National Planning, Federal Inland throughout Project Revenue Service, and Nigeria Customs Service will apply the ESMP to ensure waste implementation. management and OHS and sustainable procurement throughout the implementation. 1.3 TECHNICAL ASSISTANCE Throughout Project PCU/PIUs implementation. Ensure that terms of reference for studies, capacity building, training, project coordination roles, and consultancies for the Independent Verification Agency are carried out in a manner satisfactory to the Association and are consistent with the requirements of 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 six two months of project Prepare a Labor Management Procedures (LMP) that will detail the aspects of ESS2- effectiveness. related requirements (especially OHS, related to COVID-19 guidelines as well as social distancing norms) that will apply in case any direct or indirect workers (hired through a third party) are hired and will include a GRM specifically for project workers to raise any issues. The LMP will include terms and conditions of employment, non� discrimination and equal opportunity, the establishment of worker’s organizations, and occupational health and safety (OHS) measures regarding COVID-19 which will detail requirements of social distancing, use of face masks, hand washing and hand sanitizing. The LMP will set out grievance arrangements for project workers and Codes of Conduct (CoC) that also address SEA/SH risks 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Throughout Project Establish and operate a grievance mechanism for Project workers, as described in the implementation LMP and consistent with ESS2. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Throughout the implementation PCU/PIUs Update and implement occupational health and safety measures (OHS), including emergency preparedness and response measures, Project workers training to heighten awareness of possible risks (PPE, first aid, firefighting equipment, etc.), injuries and to mitigate impacts on local communities. The OHS measures shall be updated before the engagement of all consultants and workers including the Independent Verification Agency to address work-related risk and maintained throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Implement the WMP throughout PCU/PIUs Update and implement a Waste Management Plan (WMP) as a part of the ESMP, to Project implementation. manage hazardous and non-hazardous wastes, consistent with ESS3. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT During the preparation of any PCU/PIUs Incorporate resource efficiency and pollution prevention and management measures bidding document. in the bidding document. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY implement the ESMP throughout PCU/PIUs Project implementation. Implement measures captured in the ESMP to address potential risks/impacts on local communities due to project activities including inappropriate pollution prevention measures, health risks mitigation measures stemming from poor e-waste management and disposal, gaps in the implementation of COVID-19-specific measures at the workplace could spread the disease to local communities; in mitigation measures in the ESMPs which has been prepared. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT Not relevant to the project N/A N/A ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES Not relevant to this project. N/A N/A ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not relevant to this project. N/A N/A ESS 8: CULTURAL HERITAGE Not relevant to the project. N/A N/A ESS 9: FINANCIAL INTERMEDIARIES [This standard is only relevant for Projects involving Financial Intermediaries (FIs).] 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Not relevant to the project. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION By Project Appraisal PCU/PIUs Prepare, adopt, and disclose the Stakeholder's Engagement Plan (SEP). SEP is to be incorporated into the Project’s management system, with adequate staffing and a budget will be allocated for the implementation of the SEP. 10.2 PROJECT GRIEVANCE MECHANISM Within 6 months of project PCU/PIUs Establish, publicize, maintain, and operate an accessible grievance mechanism, to effectiveness receive and facilitate the resolution of concerns and grievances about 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. CAPACITY SUPPORT CS1 Capacity support to PCU staff, stakeholders, and Project workers] on: Throughout Project PCU • The E&S implementation and management in a PforR operation, implementation. results verification, consultation, communication, etc. Specific training such as ESF and ESMP implementation will be conducted within 6 months of project effectiveness 6|Page