THE GOVERNMENT OF SIERRA LEONE MINISTRY OF LANDS, HOUSING AND COUNTRY PLANNING Sierra Leone Land Administration Project (P177031) & SPF: Sierra Leone, Innovative Solutions for Land Dispute Resolution (P500529) STAKEHOLDER ENGAGEMENT PLAN (SEP) April 2024 Version Date Comment 1.0 March 2022 First approved SEP version for SLLAP 2.0 April 2024 Updated SEP, combining SLLAP and SPF activities 1 ACRONYMS Acronym Full Meaning CBO Community Based Organization CERC Contingent Emergency Response Component COVID-19 Coronavirus EIA Environmental Impact Assessment ESCP Environmental and Social Commitment Plan ESF Environmental and Social Framework ESHS Environmental, Social, Health and Safety ESIA Environmental and Social Impact Assessment ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan ESS Environmental and Social Standard FCC Freetown City Council FCDO Foreign, Commonwealth and Development Office FM Financial Management GBV Gender-Based Violence GoSL Government of Sierra Leone GRM Grievance Redress Mechanism IA Implementation Agency IT Information Technology LC Local Council LRP Livelihood Restoration Plan M&E Monitoring and Evaluation MDA Ministries Departments and Agency MLHCP Ministry of Lands, Housing and Country Planning MoF Ministry of Finance OARG Office Of Administrator General PCU Project Coordination Unit PIM Project Implementation Manual PSC Project Steering Committee RAP Resettlement Action Plan SLLAP Sierra Leone Land Administration Project SEP Stakeholder Engagement Plan SPF State- and Peace-Building Fund TA Technical Assistance ToR Terms of Reference WB World Bank 2 Table of Contents ACRONYMS ..................................................................................................................................................... 2 Table of Contents............................................................................................................................................... 3 LIST OF TABLES ............................................................................................................................................. 4 EXECUTIVE SUMMARY ............................................................................................................................... 5 1.0 INTRODUCTION ....................................................................................................................................... 7 1.1 Overview.................................................................................................................................................. 7 1.2 Project Background.................................................................................................................................. 7 1.3 Objective of Stakeholder Engagement Plan ............................................................................................ 9 1.4 Scope of the Stakeholder Engagement Plan ........................................................................................ 10 2.0 APPLICABLE REGULATIONS AND REQUIREMENTS ..................................................................... 12 2.1 World Bank Requirements ..................................................................................................................... 12 2.2 Key National Legislation and Policies on Stakeholder Engagement and Information Disclosure......... 13 3.0 STAKEHOLDER IDENTIFICATION AND ANALYSIS ....................................................................... 15 3.1 Stakeholder Identification ...................................................................................................................... 15 3.2 Stakeholder Mapping and Analysis ....................................................................................................... 17 3.3 Stakeholder Analysis ............................................................................................................................. 19 4.0 STAKEHOLDER ENGAGEMENT PROCESSES ................................................................................... 25 4.1 Summary of Consultation Activities Already Undertaken .................................................................... 25 4.2 Stakeholder Engagement Methods ........................................................................................................ 26 4.3 Methods of Consulting Disadvantaged / Vulnerable Individuals or Groups ......................................... 28 4.4 Stakeholder Engagement Plan (SEP) ..................................................................................................... 29 4.5 Stakeholder Engagement Strategy ......................................................................................................... 41 4.6. Proposed Strategy for Information Disclosure...................................................................................... 44 5.0 RESOURCES AND RESPONSIBILITIES FOR IMPLEMENTING STAKEHOLDER ENGAGEMENT ACTIVITIES ....................................................................................................................... 47 5.1 Resources ............................................................................................................................................... 47 5.2 Management Functions and Responsibilities ......................................................................................... 48 6.0 GRIEVANCE REDRESS MECHANISM (GRM) FOR SLLAP ......................................................... 49 6.1 The Grievance Redress Mechanism Process for SLLAP...................................................................... 49 6.2 Scope of the GRM ................................................................................................................................. 49 6.3 Implementation Steps of GRM .............................................................................................................. 50 6.4 Key Stakeholders Roles and Responsibilities in the GRM Process....................................................... 54 7.0 GRIEVANCE REDRESS MECHANISM (GRM) FOR SPF ................................................................... 55 8.0 MONITORING, EVALUATION AND REPORTING ......................................................................... 56 8.1 Involvement of Stakeholders in Monitoring Activities .......................................................................... 56 8.2 Reporting back to Stakeholder Groups .................................................................................................. 56 9.0 ANNEXES................................................................................................................................................. 60 Annex 1: Stakeholders consulted during the assignment............................................................................. 60 Annex 2: List of People Consulted for Preparation of RPF......................................................................... 63 Annex 3 : List of People Consulted for Preparation of ESMF ................................................................ 65 3 LIST OF TABLES Table 1: List of stakeholders identified under SLLAP ................................................................................... 18 Table 2: List of stakeholders identified under the SPF Project....................................................................... 19 Table 3: Analysis of stakeholder interests and likely influence in the project................................................ 20 Table 4: Analysis of stakeholder interests and likely influence in the SPF project ........................................ 23 Table 5: Summary of consultation activities undertaken during project preparation ..................................... 25 Table 6: Summary of consultation activities undertaken during SPF Project preparation ............................. 26 Table 7: Stakeholder engagement methods .................................................................................................... 27 Table 8: Methods of consulting disadvantaged /vulnerable individuals or groups ......................................... 28 Table 9: Stakeholder Engagement Plan for SLLAP ....................................................................................... 30 Table 10: Stakeholder Engagement Plan for the SPF Project......................................................................... 35 Table 11: Stakeholder Consultations Conducted During Project Preparation ................................................ 41 Table 12: SLLAP Information Disclosure and Consultation Plan.................................................................. 44 Table 13: SPF Information Disclosure and Consultation Plan ....................................................................... 45 Table 14: Proposed Budget for the SEP ......................................................................................................... 47 Table 15: Steps in project-specific grievance handling processes .................................................................. 51 Table 16: Stakeholder Roles and Responsibilities in GRM Processes ........................................................... 54 Table 17: Monitoring and Evaluation Plan for SEP ....................................................................................... 58 4 EXECUTIVE SUMMARY This Stakeholder Engagement Plan (SEP) is designed to guide the processes of engagements, consultations, and disclosure of project information to all relevant stakeholders of the proposed Sierra Leone Land Administration Project (SLLAP) and the related State- and Peacebuilding Fund (SPF) supported Sierra Leone, Innovative Solutions for Land Dispute Resolution project. (SPF Project). The Government of Sierra Leone (GoSL) through the Ministry of Lands, Housing and Country Planning has received a $41.1 grant from the World Bank to implement the SLLAP. The Project Development Objective (PDO) is to establish an efficient and accessible land administration system in Sierra Leone. The project has five main components: i. Institutional Development and Legal Reform ii. Land Information System Development iii. Recording and Registration of Land Tenure Rights iv. Project Management v. Contingent Emergency Response The preparation of the SEP was done in accordance with World Bank ESS10: Stakeholder Engagement and Information disclosure and relevant national laws and policies that promote effective stakeholder engagement and identification during project design and implementation. Some of these laws include the: Constitution of Sierra Leone, 1991; National Land Policy, 2015; Local Government Act, 2004 (as amended in 2017); Environment Protection Agency, Act 2008 (as Amended in 2010 and 2022); Town and Country Planning, Cap. 81 (as amended in 2001); Local Content Act, 2016; Right to Access Information Act, 2013; Sexual Offences Act, 2012; Child Rights Act, 2007; National Policy on the Advancement of Women, National Policy on Gender Mainstreaming; and the GBV Referral Protocol. The development objective of the US$3.3m recipient-executed trust fund SPF Project is to pilot innovative approaches for reducing fragility and conflict in the context of the land administration reform process and build capacity among land sector CSOs to support communities and land governance in Sierra Leone, with particular emphasis on the needs of women, youth and other disadvantaged and vulnerable populations in Sierra Leone. In this context the original SLLAP SEP was updated to also include the new SPF activities as these are also implemented by the Ministry of Lands, Hosuing and Country Planning through the SLLAP PCU. The development and analysis of the SEP was carried out in consultation with key stakeholder groups and based on the preliminary information contained in the Project Appraisal Document and initial consultations carried out by the Ministry of Finance – the main proponent of this project. The stakeholders identified in the SEP have been grouped into four categories, namely: i. Project Implementing Agency (MLHCP) ii. Affected Parties (mainly beneficiaries, PAPs, etc.) iii. Other Interested Parties iv. Vulnerable Groups This SEP includes details of the purpose, timing, and methods of engaging with each stakeholder group and the strategies for information disclosure to all stakeholders, especially vulnerable groups. The management, coordination and implementation of the SEP will be the responsibility of dedicated team members within the Project Coordinating Unit (PCU). The resources for the implementation of the SEP will be sourced from the Government of Sierra Leone GoSL and from Component 4 of the project which made budget provisions to cover costs associated with overall project coordination including communication and outreach to stakeholders. 5 Key institutions and focal persons have been identified in this SEP along with their designated roles and responsibilities. A Grievance Redress Mechanism (GRM) has also been incorporated into the SEP where project related grievances will be resolved using laid down procedures. The GRM will be accessible and understandable for all stakeholders in the project and for the entire project life. A Monitoring and evaluation framework has also been designed to monitor the implementation of the SEP. Moreover, performance indicators for each stakeholder engagement activity have been developed and outlined. 6 1.0 INTRODUCTION 1.1 Overview The Government of Sierra Leone (GoSL), with support from the World Bank (WB), is implementing the Sierra Leone Land Administration Project (SLLAP). The Ministry of Lands, Housing and Country Planning (MLHCP), as the implementing agency, is responsible for preparing the Stakeholder Engagement Plan (SEP) under the requirements of World Bank’s Environmental and Social Framework (ESF). As per the Environmental and Social Standard 10(ESS 10 – “Stakeholder Engagement and Information Disclosure)� this SEP seeks to define a technically and culturally appropriate approach to provide stakeholders with timely, relevant, understandable and accessible information. The goal of this SEP is to improve and facilitate consultation and decision-making, to create an atmosphere of understanding among project-affected people (PAPs) and other stakeholders and to provide these groups with sufficient opportunity to voice their opinions and concerns that may influence the Project decisions. The SEP is a useful tool for managing communications between MLHCP and its stakeholders. 1.2 Project Background SLLAP The Project Development Objective (PDO) of SLLAP is to establish an efficient and accessible land administration system. The Project will address critical challenges within the land sector in Sierra Leone. These include: i) weak institutional and technical capacity in the delivery of cadastral and registration services; ii) weak legislative framework in land administration and management; iii) tenure insecurity and inefficiency in land/property transactions; iv) increasing and unresolved land disputes within the statutory and customary tenure systems; and v) gender inequality relating to access to and control over land resources and decision-making. SLLAP has the following components: Component 1: Institutional Development and Legal Reform ― The main objective of this component is to strengthen Sierra Leone’s institutional framework for land administration by supporting buildings, operations, strategies, capacity, and sensitization. Activities under this component will support the funding required for office building or renovation (both in Freetown and the four Provincial capitals) and supply of furniture, equipment, vehicles, and initial operating cost. Decisions will be made concerning the locations of offices and what local buildings and facilities to use. Once this is done, necessary site locations, architectural drawings, building approvals, and site-specific Environmental and Social Management Plans (ESMPs) will be prepared. Component 2: Development of a Land Information System ― The Project will finance required ICT equipment, design, and development of Land Information System (LIS) with automated land administration processes (that need review and simplification) and digitization of deeds and cadastral maps. To ensure that data ownership in the LIS is linked to cadastral boundaries, the Project will finance procurement of high-quality orthophoto or satellite imagery. Further, the component will finance the establishment of a geodetic network through location measurements of existing ground control points and installation of Continuously Operating Reference Stations (CORS) on top of existing government-owned buildings in Freetown and in some of the provinces. The activities under this component will not lead to any potential resettlements. Component 3: Recording and Registration of Land Tenure Rights ― The primary focus of this component is to improve the quality and completeness of the records of land tenure rights and the ease and security with which these rights can be transferred whether by inheritance, sale, lease, or some other third-party rights. This will involve both recordings of the locations of these rights (mapping the parcel) and assessing the legal and legitimate rights to these parcels in line with National Land Policy (2015) goals and principles. The activities will seek to make the land registration and surveying of parcels more efficient and trustworthy and to ensure that the public is keen to utilize it to protect property rights. The component will finance initial pilot activities for participatory survey and recording of customary land rights with scale-up activities planned in selected priority areas. While the activities might unearth existing land disputes between private parties, the demarcation activities will not lead 7 to resettlements. The identified disputes will be dealt with through other social safeguard instruments, including a Grievance Redress Mechanism (GRM). Component 4: Project Management ― This component will finance all expenses required to ensure efficient and transparent project management and coordination. This will include the financing of Project Coordination Unit (PCU) staff at MLHCP, facilitation of meetings of the Project Steering Committee (PSC), and facilitation of Technical Working Group (TWG) meetings and consultations. Component 5: Contingency Emergency Response Component (CERC) ― The CERC is a zero-sum component included to mitigate situations of urgent need and allows for the rapid reallocation of funds in the event of a natural disaster or crisis that has caused or is likely to imminently cause a major adverse economic and/or social impact. SPF The Project Development Objective of the SPF Project is to pilot innovative approaches for reducing fragility and conflict in the context of the land administration reform process and build capacity among land sector CSOs to support communities and land governance in Sierra Leone, with particular emphasis on the needs of women, youth and other disadvantaged and vulnerable populations in Sierra Leone. The SPF Project has four components: Component 1: Strengthening women’s land rights through piloting Gender Transformative Approaches. This component promotes gender equality in access to land and other natural resources through innovative Gender Transformative Approaches (GTAs)1 to identify and address the root causes of gender inequalities and structural barriers to women’s land and resource rights. The component will promote locally generated and context-specific strategies that work across multiple levels with a variety of partners and stakeholders to foster transformative changes. This component will finance initial research to understand how women’s land rights are affected by laws and traditional norms, including inheritance, but also how women’s participation, decision making, and leadership rights are realized. Based on the research results, the component will finance the development and implementation of an awareness raising campaign on the underlying causes of gender discrimination, the importance of gender equality and women and girls’ empowerment. By using GTAs, the component will foster inclusive dialogues at the household and community level to trigger reflections on and change of discriminatory social and gender norms and perceptions on gender roles and identities that hold women back despite the new land laws. This will be done by using and evaluating innovative approaches, tools, and technology, such as Talking Books (audio devices that can play and record messages, targeting people with low literacy skills). Activities will include co-creation processes with representatives from the communities, community leaders and national experts to translate the project’s communication strategy into specific Talking Book content including highlighting real life and fictional role models. Further, the component will finance the design and implementation of a leadership capacity building program for women leaders, traditional and religious leaders, CSOs, young women and girls, men and boys, women’s organizations, and local media to reinforce their capacities, either individually or collectively, to advocate for women’s land rights. This includes piloting the design and implementation of the very first generation of training programs for women to support them in taking up roles in new land institutions such as Chiefdom, Town and Village Area Land Committees created by the new land laws. Activities will support the development, piloting and fine-tuning of a gender-responsive capacity building program tailored to the learning needs of the local stakeholders, to help them understand and effectively engage with new land laws including in the process of securing customary land rights. 1 See for example FAO (2020): Gender transformative approaches for food security, improved nutrition, and sustainable agriculture. A compendium of fifteen good practices. 8 Component 2: Improving the functionality and gender responsiveness of the land dispute resolution system. This component will improve the functionality of and promote better integration between formal and informal land dispute resolution mechanism and institutions. The component seeks to promote innovative and gender responsive Alternative Disputes Resolution (ADR) mechanisms with the goal of improved access to legal support and legal aid institutions for women, men, and communities. The project will finance an analysis of the nature and extent of land disputes, and available dispute resolution mechanisms, and legal aid support (accessibility, strengths, and weaknesses) vis a vis the requirements of new land laws. Building on the analysis, the project will finance the design and piloting of a program to increase the capacities of representatives of formal and informal land dispute resolution mechanisms by using innovative gender-responsive and inclusive participatory approaches to resolve land disputes in the context of the new land laws. The program will be providing tailored gender and law sensitization training to build the capacity of judicial and law enforcement institutions, which have not been targeted in previous interventions in this context. This is to reinforce the capacities of such institutions to act in line with the new land laws and to respond to landowners’ and users’ needs, particularly the most vulnerable. The results will feed into the development of a training manual. Component 3: Promoting innovative governance arrangements for stakeholder dialogue and improved land governance. This component will finance the implementation of innovative strategies and governance arrangements that foster collaboration, transparency, and sustainable management of land resources. This component will finance an institutional and political economy analysis at the sub-national level, aimed at unpacking power relations, interests and influence in the land sector, stakeholders’ capacities and skills as well as capacities to act collectively. The analytics will use a participatory, multistakeholder and innovative governance analysis framework.2 Based on the political economy analysis, the component will finance the establishment of Local multi-stakeholder platforms (MSPs), composed of local government, traditional authorities, Village Area Land Committees, Chiefdom Land Committees, CSOs as well as the private sector. Building on the successful experience of the national VGGT TWG, the local structures would support gender responsive land governance reform processes at the decentralized level through policy dialogue, conflict prevention, and defining local priorities, towards increased resilience. Knowledge generated at this level, would feed into the national VGGT TWG. One example of a beneficial outcome is that local MSPs would provide an entry point for a new and innovative stakeholder dialogue by involving medium-sized national investors who have largely been left out of activities aimed at achieving responsible land-based investment. Component 4: Bank-Executed Grant Implementation Support. This component would provide technical support from the World Bank to the grant’s implementing partners to ensure compliance with World Bank policies and procedures as well as coordination of activities with the Sierra Leone Land Administration Project (SLLAP, P177031). SLLAP does not provide any services for dispute resolution beyond the clarification of land parcel boundaries, while other forms of land disputes (e.g., intra-family inheritance disputes) exist. The proposed activities would therefore complement SLLAP. Trainings for women in new land sector institutions need to be newly developed and tested as no experiences with these new institutions exist. Once this is done, SLLAP could potentially adopt and scale up any successfully tested approaches. SLLAP will further benefit from the local level land sector dialogues, which are not supported under SLLAP as these require local level interventions of local level actors, such as local CSOs. 1.3 Objective of Stakeholder Engagement Plan The purpose of this SEP is to describe the the strategy and program for both the Project and for the SPF Project for engaging with stakeholders in a culturally appropriate manner, encompassing guiding principles 2 See for example FAO (2022): Focus on governance for more effective policy and technical support. Framework paper. 9 on how stakeholders are identified and involved throughout the course of the projects, providing information on previous engagements undertaken, prescribing processes and procedures to follow in stakeholder engagement and information disclosure, outlining the responsibilities of relevant institutions and contractors in the implementation of upcoming engagement activities, etc. The goal is to ensure timely provision of relevant and understandable information. It is also to create a process that provides opportunities for stakeholders to express their views and concerns and to allow both projects to consider and respond to them. The involvement of the local population is essential to the success of SLLAP and the SPF Project, as it ensures smooth collaboration between project staff and local communities and minimizes and mitigates environmental and social risks related to the proposed project activities. Of significance is the management of stakeholder expectations emanating from SLLAP/SPF Project-related interventions in a socially and culturally sensitive manner to enhance the attainment of the projects’ objectives. The specific objectives of SEP include the following: i. Identify and assess stakeholder groups and their profiles, interests, issues/impacts and concerns relevant to the projects (stakeholder mapping); ii. Identify specific initiatives (e.g., community meetings, focus group discussions, face-to-face meetings, posters in public facilities) to allow meaningful engagement with different stakeholder groups in a manner that is transparent and accessible, using culturally appropriate communication methods with specific focus on vulnerable groups; iii. Build a relationship with various stakeholders of the projects based on mutual respect and trust; iv. Facilitate adequate and timely dissemination of information on technical, economic, environmental, and social risks and impacts on stakeholder groups in a timely, understandable, accessible and culturally appropriate manner and format; v. Establish systems for prior disclosure/dissemination of information and consultation, including seeking inputs from affected persons, incorporation of inputs as applicable and provision of feedback to affected persons/groups on whether and how inputs have been incorporated; and vi. Establish a Grievance Mechanism for timely receipt, investigation and resolution of project related complaints, grievances, queries, and clarifications. 1.4 Scope of the Stakeholder Engagement Plan Stakeholder engagement refers to the process of: i. Sharing information and knowledge in a meaningful manner; ii. Seeking to understand and respond to concerns of individuals potentially impacted or affected by an activity in a transparent, inclusive and timely process; and iii. Building relationships based on trust. The implementation and monitoring of the stakeholder engagement plan are the responsibility of the Borrower throughout the planning, construction, operation, and decommissioning phases of the project activities. It is coordinated with other engagement activities linked with SLLPA and the SPF Project to avoid duplication of efforts and thus consultation fatigue. Accordingly, this SEP: i. Builds on and documents all consultations undertaken to date; ii. Presents the methodology for the planned stakeholder engagement activities to be undertaken during subsequent activities; and 10 iii. Highlights the regulatory framework for this SEP. The scope of the SEP (as well as of the associated Grievance Redress Mechanism (GRM) covers the SLLAP and SPF Project in their entirety in Sierra Leone. As such, the SEP includes various stakeholders who are positively, neutrally, and adversely affected by the projects. The project employees, workers, and contractors as well as any visitors to the Project premises shall comply with the requirements of this SEP. This SEP is intended to be a ‘live’ document; that is one of the environmental and social safeguards instrument the ESCP committed to be developed and updated throughout the project lifecycle to document the implementation of the Project and SPF Project community engagement and communication strategy and changing project landscape. This SEP will be reviewed regularly by the project Owner, the consultants to the projects, and the World Bank as the financier of the projects and updated as relevant. 11 2.0 APPLICABLE REGULATIONS AND REQUIREMENTS This SEP considers existing national institutional and regulatory requirements pertaining to stakeholder participation in development initiatives, the World Bank Environmental and Social Framework (ESF) and the associated Environmental and Social Standards (ESSs). The SEP will comply with stakeholder consultation and information disclosure requirements as stipulated in national legal instruments and international best practice. 2.1 World Bank Requirements The World Bank’s ESF outlines ten (10) specific Environmental and Social Standards (ESSs) that projects are expected to meet. Stakeholder engagement in line with the World Bank requirements is associated with ESS10 on Stakeholder Engagement and Information Disclosure (SEID), which recognizes “the importance of open and transparent engagement between the borrower and project stakeholders as an essential element of good international practice�. Specifically, the requirements set out by ESS10 are as follows: i). “Borrowers will engage with stakeholders throughout the project life cycle, commencing such engagement as early as possible in the project development process and in a timeframe that enables meaningful consultations with stakeholders on the Project design. The nature, scope and frequency of stakeholder engagement will be proportionate to the nature and scale of the project and its potential risks and impacts. ii). Borrowers will engage in meaningful consultations with all stakeholders. Borrowers will provide stakeholders with timely, relevant, understandable, and accessible information and consult with them in a culturally appropriate manner that is free of manipulation, interference, coercion, discrimination, and intimidation. iii). The process of stakeholder engagement will involve setting out further detail as in this ESS: i) stakeholder identification and analysis; ii) planning how the engagement with stakeholders will take place; iii) disclosing information; iv) consulting with stakeholders; v) addressing and responding to grievances; and vi) reporting to stakeholders. iv). The borrower will maintain and disclose, as part of the environmental and social assessment, a documented record of stakeholder engagement, including a description of the stakeholders consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account or the reasons why it was not.� (World Bank 2017: 98). ESS10 requires that a Stakeholder Engagement Plan (SEP) is proportionate to the nature and scale of the Project and SPF Project and their potential risks and impacts need to be developed by the borrower. It must be disclosed as early as possible and the b orrower needs to seek the views of t h e stakeholders on the SEP, including on the identification of stakeholders and proposals for future engagement. If significant changes are made to the SEP, the borrower must disclose the updated SEP. According to ESS10, the borrower should also propose and implement a grievance mechanism to receive and facilitate the resolution of concerns and grievances of project-affected parties related to the environmental and social performance of the projects in a timely manner. Identification of stakeholders will ensure a wide participation in project design and acceptability. To ensure that there is citizen participation in the project life span, this SEP clearly stipulates the processes of consultation and disclosure of key project information to the public and relevant stakeholders during the preparation and implementation of the projects. 12 2.2 Key National Legislation and Policies on Stakeholder Engagement and Information Disclosure The national laws, regulations and policies that are related to stakeholder engagement and information disclosure as follows: The Constitution of Sierra Leone: Section 3 of the Sierra Leone Constitution guarantees the fundamental human rights and freedoms of the individual without regard to race, tribe, place of origin, political opinion, colour, creed, or sex, which must be exercised in consonance with the rights and freedoms of others and for the public interest. Paragraph 25 of Section 3, which states that no person shall be hindered in the enjoyment of his freedom of expression including the freedom to hold opinions, receive and impart ideas as well as information without interference, is consistent with the provisions of ESS10 that requires full disclosure of project information to all stakeholders. The Local Government Act, 2004 (as Amended in 2017): The Local Government Act, 2003 has several areas where stakeholder consultation is required. For example, Section 23 makes provision for local councils to be consulted by central government ministries, departments, agencies, NGOs, etc., in development projects. Then Section 85 (4) notes that “A local council shall, before approving or reviewing a development plan, consult residents of the locality, agencies of Government and non-governmental and international organizations that have interest in working in the locality.� It is therefore expected that the Project Coordination Unit (PCU), in collaboration with the Local Councils, will actively engage and consult project stakeholders, especially those at the community level and other disadvantaged segments of the society. The Environment Protection Agency Act, 2008 (as Amended in 2010): The EPA Act is the legislation governing the protection of the environment in Sierra Leone. The Third Schedule (under Section 26) of the Act describes the content of Environmental Impact Assessment (EIA) and admonishes that EIA must report on communities, interested parties and Government ministries consulted and by extension issues consulted on. In terms of information disclosure, a requirement of ESS10, Section 27 (1) of the Environment Protection Agency Act, 2008 stipulates that the Agency, upon receiving the draft EIA report, shall circulate it to professional bodies, associations, ministries, and governmental organizations for their comments. Under Section 27 (2), the Agency is also required to openly display the EIA report in two consecutive issues of the Gazette as well as in the newspapers to allow for public viewing. The proponent is expected to address the comments from the public as received through the Executive Director within fourteen (14) days of receipt of the comments. The Town and Country Planning, Cap. 81 for the Laws of Sierra Leone (as Amendment in 2001): The Town and Country Planning Act mandates the Minister of Housing and Country Planning to consult the various Local Councils and Paramount Chiefs in the planning and management of cities and towns in Sierra Leone. The Act also requires the Minister to conduct location specific public hearings and consultations on issues related to the planning and management of the towns and cities. The Minister is also mandated by this Act to direct the posting of all relevant information such the surveyed maps, layouts, values of buildings or lands in the planning area to guide any compensation in case where the Project takes land. Regulation of Wages and Industrial Relations Act, 1971 (No. 18): Clause 29 of the Act explicitly outlines a seven-step process of redressing grievances for employees. The process starts with verbal discussion of grievances with employees’ immediate supervisors and goes right up to petitioning the Minister of Labour and Social Security in the event that the work-based grievance redress measures fail to resolve the grievance in question. The Persons with Disability Act, 2011 This Act sets up the National Commission for Persons with Disabilities (NCPD) with the objective of ensuring the well-being of Persons with Disabilities (PWDs). In Section 20 and 21 of the Act, is it an offence to deny a person contracts and employment opportunities based on disability. This provision meets the non-discriminatory requirement outlined in ESS10 and non-discrimination on the basis of disability in ESS2. In addition, the establishment of NCPD under this Act presents a good platform for PWDs seeking redress for work based or 13 work-related grievances to access to meet the requirements of ESS10. The Right to Access Information Act, 2013: This is the Act that provides for the disclosure of information held by public authorities or by persons providing services for them and to provide for other related matters. This implies that PCU is mandated by this Act to disclose all relevant information about the Project to interested stakeholders and that failure to supply information to interested stakeholders is tantamount to an offense which is liable to conviction or a fine not exceeding ten million Leones in the case of an individual and one hundred million Leones in the case of a corporate body or to a term of imprisonment not exceeding six months or to both the fine and imprisonment. The National Policy on the Advancement of Women: The National Policy on the Advancement of Women provides conducive environment that allows women to improve their status and participation, to empower them and enhance their capacities as agents of change and beneficiaries of political and economic development, thus ensuring the full use of human resources for national development. It provides integrated guidelines for evaluating the activitiesof government department/institutions, civil society organizations, donor agencies and NGOs that are engaged in implementing Women in Development programmes. The Policy introduction underscores the fact that because women’s contribution to the national economy is acknowledged and yet undervalued, there is the need for their full integration into the development process in order to increase their contribution for national development. It is therefore anticipated that the Project will take inspiration from this policy to promote the welfare of women in the design and implementation of the Project. National Land Policy 2015 The National Land Policy (NLP) was published in 2015 after significant consultations. The main objectives of the NLP are to reform the complex and conflicting constitutional, legal, and institutional frameworks that will harmonize the dual land tenure system; and to enhance institutional capacity, strengthen tenure security and to promote equitable access to land resources for all Sierra Leoneans without any form of discrimination. The NLP includes principles of consultation and participation and states that: “The NLP shall be implemented, and tenure rights administered in accordance with the principle of participation and consultation. All relevant institutions and bodies that take decisions affecting the legitimate tenure rights of groups and individuals, shall ensure their active, free, effective, meaningful and informed participation and shall take into account existing power imbalances between different parties.� Further, the NLP states that a principle of implementation is “engaging with and seeking the support of those who, having legitimate tenure rights, could be affected by decisions, prior to decisions being taken, and responding to their contributions; taking into consideration existing power imbalances between different parties and ensuring active, free, effective, meaningful and informed participation of individuals and groups in associated decision-making processes.� The Customary Land Rights Act (CLRA) 2022 Enacted in 2022, the CLRA aims to give legal effect to provisions in the NLP which protect land rights under customary law for all citizens. It seeks to secure customary land tenure and provides guidance for customary land registration, which is a new process in Sierra Leone. The CLRA It covers an assortment of issues including non-discrimination, ownership, administration and management of customary land, gender equality, investment and dispute resolution. The law is divided into ten parts, each of which addresses a cluster of related matters. The National Land Commission Act (NLCA) 2022 The National Land Commission Act establishes the National Land Commission and other land administration bodies in Sierra Leone in line with the NLP. It seeks to reform the institutional structures responsible for land administration by merging several land administration functions in one entity. The NLCA 14 provides for registration of title to private land, a modern national land title registry, modern land surveying and mapping, and co-management of foreshores. Together with the CLRA, the NLCA decentralizes land administration structures to the district, chiefdom, and village levels. Both acts emphasize the strengthening of women's land rights and women's decision-making power related to land. 3.0 STAKEHOLDER IDENTIFICATION AND ANALYSIS 3.1 Stakeholder Identification Project stakeholders are defined as individuals, formal or informal groups, and organizations and/or government entities whose interests or rights will be affected directly, indirectly, positively, or negatively by the projects and who may have interest and the potential to influence SLLAP or SPF Project outcomes in any way. Cooperation and negotiation with stakeholders throughout development of the projects often also require the identification of persons within the groups who act as legitimate representatives, entrusted by their fellow group members with advocating to respective groups’ interests during the project consultations. Community representatives may provide helpful insight into the local settings and act as main conduits for dissemination of project-related information and as primary communication/liaison links between the projects and targeted communities and their established networks. Verification of stakeholder representatives (i.e., the process of confirming that they are legitimate and genuine advocates of the community they represent) is an important task in establishing contact with community stakeholders. The following principles for stakeholder engagement shall be applied to ensure best practices in this respect: • Openness and life-cycle approach: Public consultations for SLLAP and the SPF Project will be arranged during the whole life cycle of the project and will be carried out in an open manner and free of external manipulation, interference, coercion, or intimidation. • Informed participation and feedback: Adequate information will be provided and widely distributed among all stakeholders in an appropriate format. Opportunities will be provided for communicating stakeholder feedback as well as analyzing and addressing comments and concerns. • Inclusiveness and sensitivity: Stakeholder inclusivity shall be given adequate attention so as to buildeffective relationships and trust. All stakeholders at all times would be involved in the consultationprocess. Equal access to information is provided to all stakeholders. Sensitivity to stakeholder needs is the key principle underlying the selection of engagement methods. Vulnerable groups as well as the excluded such as women, youth, elderly, and persons with disability will be given special attention within the context of the appropriate cultural sensitivities of those concern. The identified stakeholder groups at this stage of the projects are at both external and internal project levels, including: i). External to core operation of SLLAP and the SPF Project: This include institutions, communities (in particular that will be identified on the long list and included in the shortlist), national, provincial, and local government authorities, non-governmental and other civil society organizations, local institutions (such as customary and non-customary institutions) and other interested or affected parties; and ii). Internal to core operation of SLLAP and the SPF Project: These are land owning families, paramount chiefs and chiefdom councils, women groups, suppliers, contractors, distributors, the UN Food and Agriculture Organization (FAO) and regulators (who should be the same as the short-listed). Under ESS10, stakeholder identification categorizes stakeholders into three groups: i). Affected parties: These are persons, groups and other entities within the Project Area of Influence that are directly influenced (actually or potentially) by the projects and/or have been identified as most susceptible 15 to change associated with the projects and who need to be closely engaged in identifying impacts and their significance as well as in decision-making on mitigation and management of their present conditions; ii). Other interested parties: These are individuals, groups or entities that may not experience direct impacts of the projects but who consider or perceive their interests as being affected by the projects and/or who could affect the projects and the processes of its implementation in some way; and iii). Vulnerable/disadvantaged groups: Individuals or groups who may be disproportionately impacted or further disadvantaged by the projects as compared with any other groups due to their vulnerable status who may require special engagement due to their vulnerable status to ensure their equal representation in the consultation and decision-making process associated with the projects. Affected Parties: 1. SLLAP Project has multiple stakeholders from the government, private, academic, civil society and the general public. For the SEP document, stakeholders who are likely to be directly affected and involved in the implementation of policies are classified as Affected Parties and among them are: a). Ministries and Government Agencies; b). Local Government Administrations (LGAs) including City and District Councils; and c). Chiefdom Land Committees 2. SPF Project has also multiple stakeholders from the government, private, academic, civil society and the general public. For the SEP, stakeholders who are likely to be directly affected and involved in the implementation of policies are classified as Affected Parties and among them are: a). Ministries and Government Agencies; b). Civil society organizations and nonprofit organizations that receive contracts; c). Chiefdom Land Committee; Town Land Committees; Village Area Land Committees; d). Women, youth, men and others who receive training; e). Representatives of judicial and law enforcement institutions; f). Sub-national institutions that become members of local multi-stakeholder platforms. Other Interested Parties: These include individuals, groups or entities that may not experience direct impact of the Project but who consider or perceive their interests as being affected by the projects and/or who could affect the projects and the processes of their implementation in some way. Other interested parties include, among others, government institutions that may be involved in various ways in the projects, academia, civil society, international organizations, media, community-based organizations, etc. All relevant stakeholders should be identified before any attempt to engage. The preliminary list of stakeholders for SLLAP and the SPF Project will be critical in this process. However, for every project partner, the list is amended and modified based on project partner, institutional context, and stakeholder engagement objectives. It is done by answering the following questions: i). Who has the best knowledge to enforce the outputs of SLLAP and the SPF Project? ii). Who has the power to enhance project interventions to achieve the projected impacts and power to block them? iii). Who might be disadvantaged or might lose out as a result of the projects? Brainstorming the list of stakeholders before screening should include everyone who has interest. Where possible, 16 identify individuals and not just organizations. Here are some additional considerations for brainstorming: i). Learning from past and current engagements: Which stakeholders communicate regularly with clients? ii). Future consideration: Assess potential stakeholders from new groups. iii). Ensure diversity: Make sure to include a rich diversity of stakeholders, embodying a spectrum of expertise, attitudes, and geographies. Include individuals from each of the stakeholder categories, key players, context setters, subjects, the crowd. iv). Use technology tools: Analyse your social media as it provides opportunities to understand who is interested in your organization. v). Consider impact: It is crucial not to prioritize noisy critics over genuine experts. It should be carefully considered who is most impacted by the decisions and operations within the Project. 3.2 Stakeholder Mapping and Analysis Stakeholder mapping is a process of examining the relative influence that different individuals and groups have over SLLAP and the SPF Project as well as the influence of the projects over them. The purpose of stakeholder mapping is to: i). Study the profile of the stakeholders identified and the nature of the stakes involved; ii). Understand each group-specific issues, concerns as well as expectations from the projects that each group retains; and iii). Gauge their influence on the projects. Based on this understanding, stakeholders are categorized as High Influence/Priority, Medium Influence/Priority and Low Influence/Priority. Stakeholders who are categorized as a high influence are those who are expected to have a high influence over the projects or are likely to be heavily impacted by the projects’ activities. They are high up on the priority list for engagement and consultation. Together with the identification, the consultant should profile the stakeholders for proper engagement. Below is provided a list of potential criteria project partners could use to analyze the stakeholders: Interest: How willing is a stakeholder to engage with a project partner and the overall process? Influence: How much influence does a stakeholder have over the outcomes of the projects, either directly or via other stakeholders? How does a stakeholder influence a targeted policy Instrument? Here, it must be also clarified who the stakeholder influences, e.g., landowner association, policy maker, etc. To determine the connections and influences, a Social Network Analysis (SNA) is required. Also, the identification of key relationships is very important to avoid exacerbating conflicts and enabling the creation of alliances that empower marginalized groups. It is very important to know in advance about conflicts between individuals, organizations, or groups so that inflaming conflicts and disputes can be either avoided or resolved. Expertise: Does a stakeholder have information or expertise on issues dealt within the projects, either directly or otherwise? This is critical because the stakeholder will shape the futures of the issues. Orientation: Is the view of a stakeholder towards the outcomes of the Project interventions a collaborative or a combative one? Vulnerability: To what degree will a stakeholder be impacted by the projects? Capacity: To what degree does a stakeholder have the capacity to engage at the levels desired by a project partner? To what degree is the stakeholder able to meet the commitments required by the entire engagement? Trust: What degree of mutual familiarity and trust exists between project partner and stakeholder? Is there a track 17 record of both sides adhering to commitments, respecting confidentiality and engaging in productive dialogue? Table 1: List of stakeholders identified under SLLAP Project Affected Parties Other Interested Parties Vulnerable Proponents Groups 1. Ministry of 1. Environmental Protection Agency 1. Judiciary/Police 1. Elderly Lands Housing 2. Local Councils (City/Local 2. Parliament persons & Country Council Officials/Ward 3. Ministry of Social Welfare 2. People Planning Committees) 4. Ministry of Gender & living in 2. Office of 3. National Mining Agency Children’s Affairs remote Administrator 4. Ministry of Information and 5. National Monitoring & areas and Registrar Communication Evaluation Agency 3. Children General 5. Ministry of Works and Public 6. Sierra Leone Human Rights 4. Women 3. Ministry of Assets Commission (incl. Justice & 6. Chiefdom Land Committees 7. Anti-Corruption Commission women in Anthony 7. Landowners 8. Contractors informal General’s 8. Tenants and land users 9. International Finance / marriages Office 9. Tenants Associations Development Institutions and 4. Law Reform 10. Town Planning Committees (FAO, FCDO, UNWOMEN) polygamo Commission 11. Chiefdom Planning Committees 10. Other specialized NGOs us 5. Ministry of 12. Paramount Chiefs (50:50, Rainbo Initiative, etc.) marriages Finance 13. Property Taxpayers to address project-related ) 6. Ministry of 14. Workers at construction sites SEA/SH issues 5. Illiterate Local 15. Residents & businesses around 11. Civil society organizations people Government construction areas (Green Scenery, Namati, 6. Persons and Rural 16. National Disaster Management Sierra Leone Land Alliance, with Development Agency (NDMA) National Movement for Justice addictions 7. Ministry of the 17. Freetown City Council (FCC) and Development) 7. Residents Environment 18. Ministry of Agriculture and 12. National & local politicians in 8. Technical Forestry (MOAF) 13. The general public informal Working Group 19. Public Service Commission (PSC) 14. Community & Religious settlement (TWG) on the 20. Sierra Leone Investment and Export Leaders s or Voluntary Promotion Agency (SLIEPA) 15. Media (National & Local) temporary Guidelines for 21. National Revenue Authority 16. Association of Contractors settlement the Responsible 22. Local Government Service 17. Academic Community s Governance of Commission (LGSC 18. Licensed surveyors 8. Persons Tenure of Land,23. National Public Procurement 19. Network of Excellence on with Fisheries and Authority (NPPA) Land Governance in Africa disability Forests 24. Audit Service Sierra Leone (ASSL) (NELGA) 9. Ebola (VGGT) survivors/ 9. Inter- Covid-19 Ministerial patients Task Force 10. Commerci (IMTF) for the al sex VGGT workers 11. Widows 12. Orphans 18 Table 2: List of stakeholders identified under the SPF Project Project Affected Parties Other Interested Parties Vulnerable Proponents Groups 1. Ministry of 1. Chiefdom Land Committees 1. Parliament 1. Elderly Lands Housing 2. Landowners 2. Ministry of Social Welfare persons & Country 3. Tenants and land users 3. Ministry of Gender & 2. People Planning 4. Tenants Associations Children’s Affairs living in 2. Technical 5. Town Planning Committees 4. National Monitoring & remote Working Group 6. Chiefdom Planning Committees Evaluation Agency areas (TWG) on the 7. Land Adjudication Tribunals 5. Sierra Leone Human Rights 3. Children Voluntary 8. Paramount Chiefs Commission 4. Women Guidelines for 9. Judiciary/police 6. International Finance / (incl. the Responsible 10. Civil society organizations (Green Development Institutions women Governance of Scenery, Namati, Sierra Leone (FCDO, UNWOMEN) in Tenure of Land, Land Alliance, National 7. Other specialized NGOs informal Fisheries and Movement for Justice and (50:50, Rainbo Initiative, etc.) marriages Forests Development and others) to address project-related and (VGGT) 11. Women SEA/SH issues polygam 3. International 12. People living in remote areas 8. National & local politicians ous Finance / 13. Youth 9. The general public marriages Development 10. Community & Religious ) Institution Leaders 5. Illiterate (FAO) 11. Media (National & Local) people 12. Academic Community 6. Persons 13. Network of Excellence on with Land Governance in Africa addiction (NELGA) s 7. Residents in informal settlemen ts or temporar y settlemen ts 8. Persons with disability 9. Widows 10. Orphans 3.3 Stakeholder Analysis This section presents a summary analysis of stakeholders for SEP preparation process as it helps in the identification of various stakeholder groups that are likely to influence or be influenced by the Project activities and sorting them according to their impact on the Project and the impact the Project activities have on them. The opinion of the affected persons and other stakeholders will be sought through regular public consultations and the engagement will be directly proportional to the impact of the project on particular groups or individuals and their level of influence on the Project. The interests of the different stakeholder groups and individuals, how they will be affected by the Project and to what degree and influence they could have on the Project will form the basis on 19 which to build the Project stakeholder engagement strategy. It also helps in shaping the design of stakeholder consultation activities by specifying the role(s) of each stakeholder group, thereby helping in determining which stakeholders to engage, when and where. The process may be reviewed, and new changes may be introduced as other interest groups may be identified at any later stage of the Project implementation. As presented in Table 3, stakeholder analysis determines the likely relationship between stakeholders and the Project and helps to identify the appropriate consultation methods for each stakeholder group during the life of the Project. Table 4 contains the same analysis for the SPF Project. Table 3: Analysis of stakeholder interests and likely influence in the project Stakeholder Group Role in Project Interest Influence OARG • Consultation on Legal reform and Land registration high high regulation and procedure • Potential transition of OARG’s land related functions to the proposed Land Commission Local Councils • Devolution of Land Administration Function Moderate Moderate EPA • Support on the Environmental and Social Safeguards High high implementation and compliance Ministry of Finance • Disbursement of project funds High High • Project oversight • Consultation and coordination on policy issues. Local Government • Prepare a roadmap for improved management and Moderate Moderate Service Commission capacity building of technical staff in LCs for Land (LGSC) Administration. • Capacity building of core technical staff of LCs. • Develop a human resource management policy, guidelines, and scheme of service for LC staff National Public • Provides policy guidance to enhance public procurement High High Procurement processes in the country. Authority (NPPA) • Introduce reforms and technology in public sector procurement. • Enforce public procurement laws and standards. Audit Service Sierra • Undertake performance audits of service delivery. High Moderate Leone (ASSL) • Enforce financial controls and systems for efficient service delivery. Inter-Ministerial • Land sector guidance with regard to implementation of the High Moderate Task Force (IMTF) VGGT for the VGGT Technical Working • Provide technical support to the implementation of the High Moderate Group (TWG) VGGT Contractors • Execute contracts awarded on SLLAP High High • Enforce E&S safeguards in their project sites Environmental • Support the compliance issues on Environmental and High High Protection Agency RPF/RAP/ESMF implementation of renovation or construction site Ministry of • Environmental and Social Policies implementation Moderate Moderate Environment 20 Stakeholder Group Role in Project Interest Influence Other International • Support land sector and accompany implementation of High Moderate Finance / SLLAP Development • Support in implementation of other complimentary Institutions (FAO, projects FCDO, UNDP, UNWOMEN) Other Specialized • Support SEA/SH grievance & service provision Low Low NGOs to address • Support resettlement planning & implementation Project-related Issues (50:50, Rainbo Initiative) Civil Society Groups • Hold government accountable during project High High & Community implementation Organizations • Support SEA/SH grievance & service provision (Green • Support resettlement planning & implementation Scenery, Namati, Sierra Leone Land Alliance, NMJD, etc.) National & Local • Ensure receipt of information on SLLAP Moderate Moderate Politicians • Support project implementation processes • Monitor project implementation • Ensure compliance to safeguard instruments at council/city level • Represent constituents at key decision taking platforms & or meetings. • Facilitates community mobilization initiatives to support the project Public • Recipients of information on SLLAP Low Low • Support project implementation processes Local Councils • Support project implementation on the ground High Moderate (City/Local Council • Monitor project implementation. Officials/Ward • Enforce by-laws pertaining to project implementation. Committees) • Ensure compliance to safeguard instruments at council/city level. • Represent community members at key decision taking platforms and or meetings. • Facilitates community mobilization initiatives to support the project National Mining • Demarcation of mining areas and issuing license in High Moderate Agency consultation with MLHCP Ministry of • Citizen engagement on policies and law reform processes Low Low Information and Communication Chiefdom Land • Key stakeholders on Land Policy implementation High High Committees Landowners • Consultation for the land rights Laws/ policies reform High High and land registration 21 Stakeholder Group Role in Project Interest Influence Tenants and land • Consultation for the land rights Laws/ policies reform High Moderate users and land registration Ministry of Works • Accompany MLHCP office construction and renovation Low Moderate and Public Assets Community & • Ensure compliance to safeguard instruments at Moderate Moderate Religious Leaders council/city level • Represent community members at key decision taking platforms and/or meetings • Facilitates community mobilization initiatives to support project • Support project grievance process Media • Disseminate information on SLLAP to public. Low Low • Hold leaders accountable during project implementation Association of • Support in enforcing standards during Office construction Moderate Moderate Contractors activities implementation • Support in monitoring project sites • Support in redress of complaints & grievances among its members Academic • Provides scientific data to support project implementation. Moderate Moderate Community • Provides independent critique & consultancy services to project Children • Engage on project & its impacts on children Low Low • Recipients of information on SLLAP • Adhere to guidelines on children’s involvement in project Women • Engage women groups on project & explain impacts on High Moderate women • Recipients of information on SLLAP • Adhere to guidelines on women’s involvement in project Illiterate People • Engage illiterate population on project Low Low • Recipients of information on SLLAP • Adhere to information pertaining to implementation of project People in remote • Potential beneficiaries High Low areas Persons with • Provide information to aid delivery of project support to Low Low Addiction persons with addiction • Adhere to information pertaining to implementation of project Persons with • Engage associations of persons living with disability to High Moderate Disability factor their needs into project design • Provide information to aid delivery of project to persons with disability • Adhere to information, rights & responsibility of persons with disability in project implementation Ebola • Provide information to aid delivery of project to Ebola High Moderate Survivors/Covid-19 survivors/Covid-19 patients Patients • Adhere to information rights & responsibility of persons 22 Stakeholder Group Role in Project Interest Influence with disability in project implementation Elderly Persons • Provide information to aid delivery of project to elderly Moderate Low persons • Adhere to information affecting to implementation of project Commercial Sex • Provide information to aid delivery of project to Moderate Low Workers commercial sex workers. • Adhere to information pertaining to implementation of project Table 4: Analysis of stakeholder interests and likely influence in the SPF project Stakeholder Group Role in Project Interest Influence Local Councils • Participation in development of local multi- Moderate Moderate stakeholder platforms. Ministry of Finance • Disbursement of project funds High High • Project oversight • Consultation and coordination on policy issues. Technical Working • Provide technical support to the implementation of the High Moderate Group (TWG) VGGT and the SPF Project Environmental • Support the compliance issues on Environmental and High High Protection Agency RPF/RAP/ESMF implementation of renovation or construction site Ministry of Environment • Environmental and Social Policies implementation Moderate Moderate Other International • FAO will have major oversight, technical support and High High Finance / Development monitoring role. Institutions (FAO, FCDO, UNDP, UNWOMEN) Civil Society Groups & • Design and implement project activities through High High Community contracts with FAO. Organizations (Green • Hold government accountable during project Scenery, Namati, Sierra implementation. Leone Land Alliance, • Recipients of training NMJD, etc.) National & Local • Represent constituents at key decision taking Moderate Moderate Politicians platforms & or meetings. • Facilitates community mobilization initiatives to support the project • Participate in local MSPs Public • Recipients of information on the project Low Low • Support project implementation processes Local Councils • Support project implementation on the ground Moderate Moderate (City/Local Council • Monitor project implementation. Officials/Ward • Enforce by-laws pertaining to project implementation. Committees) • Represent community members at key decision taking 23 Stakeholder Group Role in Project Interest Influence platforms and or meetings. • Facilitates community mobilization initiatives to support the project Chiefdom Land • Key recipients of training High High Committees, Town Land • Participants in local MSPs Committees, Village Area Land Committees Landowners • Some will receive training to participate in new land High Moderate institutions Tenants and land users • Some may receive training to participate in new land Moderate Moderate institutions Community & Religious • Represent community members at key decision taking Moderate Moderate Leaders platforms and/or meetings such as new local MSPs. • Facilitates community mobilization initiatives to support project, including encouraging women and others to receive training • Support project grievance process Media • Disseminate information on the project to public. Low Low • Hold leaders accountable during project implementation Academic Community • Provides independent critique & consultancy services Moderate Low to project Children • Engage on project & its impacts on children Low Low • Adhere to guidelines on children’s involvement in project Women • Engage women groups on project & explain impacts High Moderate on women. • Potential beneficiaries who receive training to participate in land institutions and land dispute resolution. • Receive legal aid. • Adhere to guidelines on women’s involvement in project Illiterate People • Engage illiterate population on project Low Low • Adhere to information pertaining to implementation of project People in remote areas • Potential beneficiaries High Low Persons with Disability • Potential beneficiaries Moderate Low • Engage associations of persons living with disability to factor their needs into project design • Provide information to aid delivery of project to persons with disability • Adhere to information, rights & responsibility of persons with disability in project implementation Elderly Persons • Potential beneficiaries Moderate Low • Provide information to aid delivery of project to elderly persons • Adhere to information affecting to implementation of project 24 4.0 STAKEHOLDER ENGAGEMENT PROCESSES 4.1 Summary of Consultation Activities Already Undertaken Consultations for the SLLAP Project. The Project proponents have already carried out a series of stakeholder engagement as part of the preparation as presented in the table below. During the Project preparation stage, two virtual mission meetings and consultations were conducted with different stakeholder groups pertaining to the Project needs and priorities. The meetings discussed the Project areas of influence, concept, design, institutional arrangement, potential impacts, mitigation measures, SEP, GBV Action Plan, environmental and social commitment plan and MLHCP commitments. Additionally, extensive consultations, including focus group discussions and interviews, were conducted in the context of the preparation of the Project SEP, GBV Action plan and ESMF. There was general support for the project as critical for Sierra Leone now. Stakeholders advised the project to involve affected communities right from the planning stage and pay attention to women involvement in key decisions and employment opportunities. Additionally, stakeholders advised the active involvement of the Local Councils during the implementation phase of the project as they interface with the local population and have the technical capacity, with staff to conduct effective monitoring. For the land demarcation and tilting, stakeholders wanted to see keen attention on land tenure systems in the provinces and the need to ensure that any possibility of land acquisition or restrictions are properly. Details and participants list of those consultations are attached under Annex 1. Table 5 provides an overview of stakeholders met during the preparation of this SEP. The table summarizes the engagement purpose, engagement method and location of the engagement. Table 5: Summary of consultation activities undertaken during project preparation Engagement Stakeholder Engagement Purpose Location Method PROJECT PREPARATION PHASE PFMU, OARG Discuss SLLAP preparation timeline, staffing Virtual meeting Online arrangements, required documents & PPA Discuss environmental & social standards & EPA Virtual meeting Online sensitization activities Discussion on legal reform, institutional development & capacity building, OARG & MOJ Virtual meeting Online understanding first time registration of properties Identification missions conducted jointly with FAO FAO which supports Sierra Leone land sector reforms. Virtual meeting Online Support based on VGGT, mapping & land cadastral, national spatial data infrastructure Understanding VGGT technical working CSO (Green Scenery) Virtual meeting Online group based on inclusive land Sector reform Discussion potential Collaboration Understanding CSO (NMJD) VGGT technical working group based on inclusive Virtual meeting Online Network land Sector reform Director of Housing – Understand housing situation in Freetown & the Formal meeting MLHCP MLHCP Provinces City Mayors, District Understanding willingness and readiness for Chairmen & District establishing district offices once law is passed & Formal meeting MLHCP Offices of MLHCP whether premises use & staff could be seconded. MLHCP Surveys & Assessing capacity of staff (functional staff) Meeting MLHCP Lands Directorate 25 Engagement Stakeholder Engagement Purpose Location Method NELGA (Network of Explore potential collaboration opportunities with NELGA to note interest of MLHCP to include Meeting MLHCP Excellence of Land internship program in addition to Governance in Africa) formal training & education programs MOJ, LRC, OARG Discussion on legal reform Virtual meeting Online MLHCP Planning Town planning, plan availability, town planning MLH Formal meeting Dept. status of some sites for services & upgrading CP Consultations for the SPF Project. Stakeholder engagement for the SPF Project has been carried out as described in Table 6. The content of the consultations has built on and supplemented stakeholder engagement for the Project. Table 6: Summary of consultation activities undertaken during SPF Project preparation Engagement Stakeholder Engagement Purpose Location Method PROJECT PREPARATION PHASE MLHCP Several meetings to discuss project content and how Virtual meeting Online it will complement SLLAP. Meetings to discuss the project objectives and Virtual meeting; Online and in Technical Working activities and what role CSOs and other in person person at the Group SLLAP office stakeholders will play in the project. meetings Remote meetings to discuss the content of the Virtual meetings Online/Freetow FAO project and FAO’s role therein as well as in-person and in-person n/Provinces missions. missions 4.2 Stakeholder Engagement Methods The SEP includes different other types of engagement techniques to build relationships with stakeholders, consult and gather information from them and disseminate project information to all stakeholders. Stakeholder engagement is an important inclusive process conducted throughout the project cycle and is critical to the successful implementation of the projects. The engagement will be free of manipulation, interference, coercion, and intimidation. It will be conducted based on timeliness, relevance, understanding and accessibility of information and in a culturally sensitive way. The selection of any medium for consultation or engagement will be based on the level of formal education, inherent needs, and other cultural sensitivities of the stakeholder so that the purpose of each engagement will be achieved. In keeping with the applicable reference framework and expectations of the stakeholders, the projects will undertake regular engagement with key stakeholder groups identified through the life of the projects. Based on the previous engagement activities and profiles of the stakeholders thus developed, certain engagement activities have been identified for the projects going forward, as described in this section. The primary objective of these engagement activities is to allow the stakeholders to interact with the projects and contribute towards their planning and for the projects to be developed in an effective and culturally appropriate way. It is also likely that the methods of stakeholder engagement will be affected by the COVID-19 pandemic. Therefore, the methods of stakeholder engagement will be done taking into consideration all the recommended public health protocols. In general, a precautionary approach will be taken during the consultation process to prevent contagion, given the highly infectious nature of COVID-19. The following will be considered while selecting channels of communication in light of the current COVID-19 situation: 26 i). Avoid large public gatherings taking into account national restrictions or advisories), including public hearings, workshops and community meetings; ii). If smaller meetings are permitted/advised, conduct consultations in small-group sessions such as focus group meetings. If not permitted/advised, make all reasonable efforts to conduct meetings through online means. iii). Diversify means of communication and rely more on social media and online channels. Where possible and appropriate, create dedicated online platforms and chat groups appropriate for the purpose, based on the type and category of stakeholders. iv). Assess and deploy alternative tools to engage stakeholders such as the use of community radio, use of key community influencers and peer groups, visual aids and social media. v). Where direct engagement with project-affected people or beneficiaries is necessary, identify channels for direct communication with each affected household via context-specific combination of email messages, mails, online platforms and dedicated phone lines with knowledgeable operators. vi). Each of the proposed channels of engagement should clearly specify how feedback and suggestions can be provided by stakeholders. vii). Employ traditional channels of communications (TV, newspaper, radio, dedicated phone lines and mails) when stakeholders to do not have access to online channels or do not use them frequently. Traditional channels can also be highly effective in conveying relevant information to stakeholders and allow them to provide feedback and suggestions. The techniques to be used for the different stakeholder groups are summarized in Table 7 below. Table 7: Stakeholder engagement methods Engagement Purpose & Details Method • Distribute information to World Bank Group, Government officials, NGOs, Local Correspondence Government, impacted communities & organizations/agencies (Phone, Emails) • Invite stakeholders to meetings and follow-up • Seek views and opinions One-on-one • Enable stakeholders to speak freely about sensitive issues Meetings (via Zoom, • Build personal relationships Skype, • Record meetings Teleconference, etc.) • Resolve concerns & grievances as appropriate • Present Project information to group of stakeholders • Allow group to comment – opinions & views Formal & Informal • Build impersonal relation with high-level stakeholders Meetings • Disseminate technical information • Record discussions • Present project information to group of stakeholders Focus Group • Allow stakeholders to give views on targeted baseline information Meetings • Build relationships with communities • Record responses Website/National • Present project information & progress updates News papers • Disclose ESIA, ESMF, ESMP, RPF, SEP & other relevant project documentation Direct • Share information on project impacts & mitigation measures & implementation Communication timelines with Affected PAPs • Agree on options for neighborhood upgrade & relocation options 27 • Participatory development of community action plans • Present project information to large group of stakeholders, especially communities • Allow groups to give views & opinions • Build relationship with communities, especially the impacted Public Meetings • Distribute non-technical information • Facilitate meetings with presentations, PowerPoints, posters, brochures, etc. • Record discussions, comments & questions 4.3 Methods of Consulting Disadvantaged / Vulnerable Individuals or Groups It is particularly important to understand whether Project impacts may disproportionately fall on disadvantaged or vulnerable individuals or groups who often do not have voice to express their concerns or understand the impacts of the project. The National Disability Policy (NDP) refers to the United Nations definition of persons with disability as persons ‘who have long-term physical, mental, intellectual, or sensory impairments which in interaction with various barriers may hinder their full and effective participation in society on an equal basis with others’. Impairments are problems in body function or structure such as a significant deviation or loss. Disability may be experienced by people of any age, including children, young and older people, exacerbating sometimes the existing vulnerability of some (e.g., children and elderly people). Persons with disabilities often lack equitable access to the same opportunities enjoyed by their peers without disabilities. Disadvantaged/vulnerable individuals and groups who often do not have voice to express their concerns or understand the impacts of a project are sometimes excluded from stakeholder engagement. The table shows potential disadvantaged/vulnerable individuals/groups and limitations they may have regarding participating in the consultation process. Consultations will better determine the needs and strategy for community dialogue and awareness-raising and will be detailed. Awareness campaigns, trainings, dissemination activities about the different entry points, among other activities, will ensure the sustainability of the actions taken and will prepare the community to address cases properly in the future and after project completion. Table 8 summarizes potentially affected vulnerable groups and individuals, their needs and characteristics, preferred means of consultation and required resource. SLLAP will seek the views of vulnerable and disadvantaged groups during consultations, in a confidential manner to take their views into account during implementation of both the Project and the SPF Project. Information sharing and consultation techniques will be tailored according to the nature and common types of stakeholders, for example through visuals and sign language interpreters will be used for people with hearing disabilities and illiterate persons, where applicable; and venues will be chosen to be easily accessible to people with physical disabilities. In particular, the following tailored measures will apply. Table 8: Methods of consulting disadvantaged /vulnerable individuals or groups Preferred Vulnerable Specific Needs & Means of Additional Resources Groups & Characteristics Notification / Required Individual Consultation Focus group meetings, meeting with Engagement of local NGOs to Ebola/COVID-19 Stigma, limited voice association of embark on sensitization against Survivors Ebola/COVID-19 Survivors Ebola/COVID-19 survivors. 28 Focus group More information Stakeholders in Limited voice, low meetings, dissemination through local remote area/high representation, no engagement at local radio & town criers, posters, illiteracy including access to level, including use local language skits & the homeless information of radio & town hall discussions. community level meetings engagement & consultation at district headquarters Physically Lack of access to Meet identifiable Information translated to challenged meeting places, associations of indigenous languages, sign persons with transportation & persons with language/translators, braille, visual & hearing language barriers, disabilities accessible meeting locations impairment visual impairment Focus group Women, girls, Limited voice, low Engage local NGOs & meetings, use of poor & representation, lack CBOs who work with gender champions, disadvantaged, of access to vulnerable people at focus group meetings children, information, cultural community level to help with disadvantaged pregnant school- & traditional barriers, disseminate information & children & their age girls poverty stigma organize consultations guardians More information Limited voice, poor Focus group dissemination through local Residents in representation in meetings, radio & town criers, posters, informal decision table, lack of engagement at local local language skits & settlements & access to information, level, including use discussions, community flood-prone or inaccessible to of radio & townhall level engagement & inaccessible areas meeting places meetings consultations at district headquarters Drug addicts, Stigma, gender-based Focus group commercial sex violence, limited meetings workers voice 4.4 Stakeholder Engagement Plan (SEP) The SEP presented in Table 9 aims to (i) set out how the communication with stakeholders will be handled throughout project preparation and implementation; (ii) describe the timing and methods of the engagement; (iii) describe the range and timing of information to be communicated to project affected parties and other interested parties as well as the type of information to be sought from them; and (iv) describe measures to remove obstacles to participation and how the views of the differently affected groups will be captured.It will also provide sufficient opportunity for the various stakeholder groups to voice their opinions and concerns that may influence project decisions during the project design, implementation, and closure stages.It must be emphasized that the stakeholder engagements methods must be done in accordance with all the required COVID-19 social distancing and safety protocols. The SEP for the SPF Project presented in Table 10 has the same aims. 29 Table 9: Stakeholder Engagement Plan for SLLAP Project Topic of Engagement Application of the Target Stakeholders Responsibility Stage consultation Technique technique Project Agreeing on • Correspondence • Invite stakeholders • Ministry of Land Housing and Country Planning • MLHCP Preparation components and Phone, Emails ( to meetings and • Office of Administrator and Register General • MOF institutional Zoom, Meeting) follow-up • Ministry of Agriculture and Forestry • OARG arrangements for • Formal and • Soliciting • Ministry of Finance • WB the informalmeetings; stakeholder input • Ministry of Local Government and Rural Development implementation of into the PAD • Ministry of Works and Public Assets SLLAP organizations/ • Ministry of Environment agencies • Local Councils • Development partners • World Bank Group • CSOs/NGOs Preparation of • Correspondence • Invite stakeholders • Ministry of Lands, Housing andCountry Planning • MLHCP E&S safeguard (Phone, Emails) to meetings and • Ministry of Finance • EPA instruments • Formal and follow-up • Ministry of Local Government andRural Development • MOE informal meetings • Soliciting • Ministry of Environment • OARG stakeholder input • Environmental Protection Agency • Consultants into the safeguard • Local Councils instruments • Development partners • CSOs/NGOs • Landowners • PAPs (including informal occupants), residents/businesses in construction area • Vulnerable groups • Residents/businesses in construction area 30 Project Topic of Engagement Application of the Target Stakeholders Responsibility Stage consultation Technique technique GRM • Meetings • Dissemination • Ministry of Land Housing and Country Planning • MLHCP establishment, • radio/TV of information • Ministry of Justice and Attorney General • EPA dissemination, discussions to mass • Parliamentarians • OARG and awareness • engagement audiences • Anti-corruption Commission with • Ombudsman • Focal Person for community • National Commission for Persons withDisability (NCPD) GRM representatives’ • The General public influencers • Impacted Communities • Vulnerable groups • Persons with disabilities 31 Project Preparation of • Community • Project • Environmental Protection Agency • MLHCP Implementati MLHCP E&S site meetings, community • Ministry of Environment • EPA on specific instrument focusedgroup Liaison and • Ministry of Lands, Housing andCountry Planning discussions, communication • Ministry of Works and Public AssetsOfficials public hearing, specialist to lead • Development partners public community entry • World Bank Group disclosure withWard • CSO/NGO development • Security services • Formal and committees • Community representatives informal • Project Affected Persons correspondence • Consultant to • Environmental Protection Agency and meetings establish a Strategies for stakeholder • Parliamentarians enforcing E&S engagementstrategy • Ministry of Environment instruments consistent with this • Ministry of Lands, Housing andCountry Planning SEP to guide • Ministry of Works and Public AssetsOfficials consultations for the • Development partners preparation of the • World Bank Group instruments • CSO/NGO • Security services Community representatives • Formal and • Invite stakeholders informal meetings to meetings and follow-up • Soliciting stakeholder input into the PAD organisations/ agencies 32 Project Topic of Engagement Application of the technique Target Stakeholders Responsibility Stage consultation Technique Consultations for • Public hearing/ • Invite stakeholders to • OARG • MLHCP assessment, discussion meetings and follow-up • CSOs • LRC drafting of • Formal/ • Women Groups • MOJ relevant Land Informal • Landowner Association • Paramount Chiefs Laws and meetings with • Officials of LCs • Chiefdom Committees regulations technical people • The General public inthe field • Impacted Communities representative Public Awareness • Meetings • Dissemination of • Ministry of Environment • MLHCP Raising on Land • radio/TV information to mass • Local Council in 14 Districts Policies, Laws, discussions audiences • EPA and regulations • engagement • Solicit inputs into strategy • The general public withcommunity for mitigatingdisasters • Homeless representatives’ • Children influencers • Impacted communities • Persons with disability Guidelines for • Meetings • Dissemination of • Ministry of Social Welfare • MLHCP compensation • radio/TV information to mass • Anti-corruption Commission to affected discussions audiences • Ombudsman individualsand • engagement • Solicit inputs into • NCPD households withcommunity guidelines for social and • The general public representatives’ financial support to • Women influencers affected households • Children • Informal occupants • Businesses affected • Vulnerable groups 33 Project Topic of Engagement Application of thetechnique Target Stakeholders Responsibility Stage consultation Technique • Persons with disability Labour and • Formal and • Present information on • Ministry of Finance • MLHCP working informal employees’ contracts • Ministry Social Welfare • MoF conditions meetings • Display information on • Ministry of Labor • MLGRD- associated with notice boards, signposts, • MLHCP Decentralization the new office radio announcement etc. • Sierra Leone Institution of Engineers Secretariat construction or • Encourage the use of GRM • Contractors • Local Councils renovations that mechanism to • Landowners • Contractors should be address issues on labour considered and working conditions construction Project Lessons • Public online • Present Project • National Monitoring and Evaluation Agency • MLHCP Closure learned surveys information to a large • Ministry of Finance • MoF • Focus group group of stakeholders, • Ministry of Works and Public Assets meetings especially communities • EPA • Expert one-on- • Allow stakeholders to • MLGRD oneinterviews provide their views and • Development partners • Formal opinions • World Bank Group meetings • Distribute technical and • Security forces non-technical information • The general public • Record discussions, • Impacted Communities comments, questions. • Project Affected Persons (PAPs) • Persons with disabilities • Sustainability • Public online • Present Project • Ministry of Finance Officials • MLHCP surveys information to a large • Ministry of Works and Public Assets • MoF • Focus group group of stakeholders, • EPA Officials meetings especially communities • MLGRD • Expert one-on- • Allow stakeholders to • OARG oneinterviews provide their views and • MOJ • Formal opinions • LRC meetings • Distribute technical and • Development partners non-technical information • World Bank Group • Record discussions, • General public comments, questions. • Impacted Communities, • Persons with disabilities 34 Project midterm • Expert one-on- • Present Project • Ministry of Finance Officials • MLHCP review/ assessment oneinterviews information to a large • Ministry of Works and Public AssetsOfficials • MoF (FDD, PFMU) • Formal group of stakeholders, • EPA Officials • MLGRD- meetings especially communities • MLGRD key staff Decentralization • Allow stakeholders to • Development partners Secretariat provide their views and • World Bank Group • LCs opinions • Security forces • Distribute technical and • The general public non-technical information • Impacted Communities, • Record discussions, • Persons with disabilities comments, questions. Table 10: Stakeholder Engagement Plan for the SPF Project Project Topic of Engagement Application of the Target Stakeholders Responsibility Stage consultation Technique technique Project Agreeing on • Correspondence • Invite stakeholders • Ministry of Land Housing and Country Planning • MLHCP Preparation components and (Phone, Emails to meetings and • Development partners • WB institutional Zoom, Meeting) follow-up • World Bank Group • FAO arrangements for • Formal and • Soliciting • CSOs/NGOs • Consultant the informal meetings; stakeholder input implementation of into the SPF Project the SPF Project. Paper 35 Project Topic of Engagement Application of the Target Stakeholders Responsibility Stage consultation Technique technique Project Component 1: • Community • To conduct • CSO/NGO • MLHCP Implementati Strengthening meetings, research to • Community representatives • FAO on women’s land focusedgroup understand how • Project Affected Persons • Contracted rights through discussions, women’s land • Women CSO/NGOs piloting Gender public rights are affected • Youth Transformative disclosure by laws and • Paramount Chiefs Approaches. traditional norms, • Religious leaders including • Local media inheritance, but also how women’s participation, decision making, and leadership rights are realized. • Community • Implementation of meetings, an awareness raising focusedgroup campaign on the discussions, underlying causes of public gender disclosure discrimination, the importance of gender equality and women and girls’ empowerment. • Individual or • Dialogues at the small group household and meetings with community level to household and trigger reflections community on and change of members. discriminatory social and gender norms and perceptions on gender roles and identities that hold women back despite the new land laws. 36 • Community • Implementation of meetings, focused a leadership group discussions, capacity building public disclosure, program for individual and women leaders, small group traditional and meetings at religious leaders, community level. CSOs, young women and girls, men and boys, women’s organizations, and local media to reinforce their capacities, either individually or collectively, to advocate for women’s land rights. 37 Project Topic of Engagement Application of the technique Target Stakeholders Responsibility Stage consultation Technique Component 2: • Community • Analysis of the nature and • CSOs • MLHCP Improving the meetings, extent of land disputes, and • Women Groups • Academia functionality focusedgroup available dispute resolution • Landowner Association • FAO and gender discussions, mechanisms, and legal aid • Impacted Communities representatives • Contracted CSOs/NGOs responsiveness public support (accessibility, • Alternative dispute resolution • WB of the land disclosure, strengths, and weaknesses) institutions dispute individual and vis a vis the requirements • Judicial institutions resolution small group of new land laws. • Legal aid organizations system. meetings at • Law enforcement institutions community level; formal/ Informal meetings with technical people in the field and others with expertise. • Design and piloting of a program to increase the • Formal/ capacities of Informal representatives of formal meetings with and informal land dispute representatives resolution mechanisms by of land dispute using innovative gender- mechanisms, responsive and inclusive technical people participatory approaches to in the field and resolve land disputes in the others with context of the new land expertise. laws. Component 3: • Community • Conduct an institutional and • CSOs • MLHCP Promoting meetings, political economy analysis • Women Groups • FAO innovative focusedgroup at the sub-national level, • Landowner Association • Contracted CSOs/NGOs governance discussions, aimed at unpacking power • Impacted Communities representatives • WB arrangements public relations, interests and • Alternative dispute resolution for stakeholder disclosure, influence in the land sector, institutions dialogue and individual and stakeholders’ capacities • Judicial institutions improved land small group and skills as well as • Legal aid organizations governance. meetings at capacities to act • Law enforcement institutions community collectively. • Local government level; formal/ • Investors in land Informal 38 meetings with • Traditional leaders technical • Village Area Land Committees people in the • Chiefdom Land Committees field and others with expertise. • Community • Establishment of Local meetings, multi-stakeholder platforms focusedgroup (MSPs), composed of local discussions, government, traditional public authorities, Village Area disclosure, Land Committees, individual and Chiefdom Land small group Committees, CSOs as well meetings at as the private sector. community level; formal/ Informal meetings with technical people in the field and others with expertise. 39 Project Topic of Engagement Application of thetechnique Target Stakeholders Responsibility Stage consultation Technique Project Lessons • Public online • Present Project • CSOs/NGOs • MLHCP Closure learned surveys information to a large • Development partners • FAO • Focus group group of stakeholders, • World Bank Group • Contracted CSOs/NGOs meetings especially communities • Judicial institutions • Expert one-on- • Allow stakeholders to • Law enforcement institutions oneinterviews provide their views and • Women’s groups • Formal opinions • The general public meetings • Distribute technical and • Impacted Communities non-technical information • Project Affected Persons (PAPs) • Record discussions, comments, questions. 40 4.5 Stakeholder Engagement Strategy A stakeholder engagement strategy identifies the needs of key groups and the sponsor plays a vital role in ensuring those business needs are met. At each of the stages identified above, the PCU and, for the SPF Project, FAO will ensure meaningful engagement and consultation and disclosure of project information to allrelevant stakeholders. The disclosure and consultation activities will be designed along with some key guiding principles, including the following: • Consultations must be widely publicized particularly among the project affected stakeholders/communities, preferably 2 weeks prior to any meeting engagements • Ensure non-technical information summary is accessible prior to any event to ensure that people are informed of the assessment and conclusions before scheduled meetings • Location and timing of meetings must be designed to maximize stakeholder participation and availability • Information presented must be clear, and non-technical, and presented in all appropriate local languages where necessary • Engagements must be facilitated in ways that allow stakeholders to raise their views and concerns • Issues raised must be addressed, at the meetings or at a later time. Table 11: Stakeholder Consultations Conducted During Project Preparation Key Activities Target Stakeholders Expected discussions anddecisions Locations Responsibilities Project identification World Bank, FAO, Joint Identify the proposed project and its June 2021: WB missions for the Government department components, Identify the key results expected Virtual WB MOF Sierra Leone Land and Agencies- MLHCP, to be achieved under the proposed project; mission MLHCP administration project MOJ, OARG, EPA, PFMU, Discuss overall expected project expenditures, MOF, TWG on the type of activities and implementation October 2021: voluntary guidelines for the responsible Governance of arrangements; discuss a project preparation WB Mission to Tenure of Land, Forests advance; and agree on the next steps of Freetown, Sierra (VGGT) and CSOs preparation of the proposed project Leone 41 KEY Activities Target Expected discussions Locations Responsibilities Stakeholders and decisions Quarterly Consultation MOF, MOJ, OARDG VGGT implementation MLHCP MLHCP meeting with TWG MOE. Local Council, and Compliance MOFMR, CSOs NMJD, Land for Life, FAO SLIPLA, HRC, NAMITTA, WONNES Consultation Partnership MOF-PFMU, MLHCP, Established Technical PCU MLHCP to establish partnership arrangement for project OARG, EPA- Inter Working Group IMTF collaboration, working group implementation Ministerial Task Force/ and PSC with clear mandate and work TWG plan Consultation for ESMF MLHCP, Land sector ESMF Finalized and Country levels MLHCP contract Consultants to RPF, SEP drafts stakeholder approved by World develop the ESMF RPF, SEP, development Bank gender assessment, GBV assessment and GBV action plan drafts Pre-operational studies Land owning families, Land and access MLHCP sites, Land owning families identify for the construction/ EPA, construction site, effect Freetown, and compensation and resettlement Renovation of MLHCP on infrastructure of public provinces -EPA, packages; EPAlead discussions on Office utilities MLHCP regulations and guidelines governing Construction Management companies discuss on links between transit points and office construction sites for effective housing for MLHCP staff Assessments, drafting MLHCP, MOJ, Land Policies, Law MLHCP/ Country / MLHCP: Lead the policies and Laws and validation for OARG, MoAG, CSO, development and adoption Office formulation in collaboration with other relevant land policies, Landholders, Local stakeholders as EPA, OARG, MOJ Laws and regulation Councils, review legal framework and coordinated country-wide consultations on the land bills with CSOs Establishment of Land MLHCP, OARG, ICT System equipment and MLHCP MLHCP will prepare TORs in this Information System DSTI, FAO, FCC Digitalization of Land regard Record, Base mapping, National Spatial Data Infrastructure, establishment 42 of a Geodetic Network Consultation on Freehold Paramount Chiefs, Contributed to the MLHCP and Country Digital land information system (LIS) and state land in Western Landholders, OARG, Prevention and resolution of Office- Local with automated Land Administration Province for recording FCC, NMA, SLLAP intra and inter communal Councils process land disputes in mining and registration Tenure communities Rights Advocacy and Public Media, Houses Increased awareness and PCU- MLHCP and Creating awareness and understanding Awareness raising on Electronic outlet and understanding of Land Legal Country Office- Local of Land Legal Framework Land Rights and Land written Framework Councils Administration legal reform and laws, regulatory framework and procedure for conducting cadastral survey. site specific awareness Media, Houses, Make the Land registration PCU- MLHCP, OARG, Creating awareness and understanding raising on land Electronic outlet and and survey of parcels more Country Office- Local of Land registration and mapping in registration and mapping written Community efficient and trustworthy and Councils and chiefdom project target areas under component 3 ensure public will be keen to Committee in project target areas Outreach, utilize it to protect their under component 3 property rights Disclosure of Environmental Media, EPA, Environmental and social Offices of MDAs, LCs, Share information on Environmental and social risk management Communities risk management plans PAPs Communities, and social risk management plans plans offices of CSOs/CBOs/NGOs For SPF Project, consultation MLHCP, CSOs/NGOs, Identify the proposed project SLLAP office; online FAO and WB share information on meetings with TWG private sector, FAO, and its components, Identify proposed project. development partners the key results expected to be achieved under the proposed project; 43 4.6. Proposed Strategy for Information Disclosure Stakeholder consultation and information disclosure is key to project implementation process which shall be consciously carried at every phase of the project implementation. The project implementation team shall ensure that each consultation process is well planned and inclusive which must be documented and communicate feedback on all follow up issues, concerns, and actions emanating from the stakeholder consultation processes. The engagement and consultation will be carried out on an ongoing basis to reflect the nature of issues, impacts, and opportunities emanating from the implementation of the project. Table 12: SLLAP Information Disclosure and Consultation Plan PROJECT LIST OF METHOD FOR TARGET TIMELINE STAGE DOCUMENTS FOR DISCLOSURE STAKEHOLDERS PROPOSED DISCLOSURE Project • ESMF • News paper • MLHCP • Before Preparation • RPF • Website • OARG appraisal • SEP • Online • PCU Throughout • GRM • Community • TWG/IMTF project • GBV meetings/Outreach • LCs implementation • Traditional Leader (Paramount Chief • Development partners • World Bank Group • Landholders • Land users Project • Detailed • Radio and phone in • Landholders • During Implementati information interaction with • Land users project on about SLLAP public • LCs implementati (Beneficiary • Television • Traditional Leader on Landholders, • Social media (Paramount Chief, LCs,likely • News paper section chiefs, town impact of • Posters and chiefs, Mama Queen project, etc.) brochures and Youth Leader) • ESIA, ESMF, • Chiefdom Land RPF, Committee LRP, ESMP, representatives RAP,SEP, GRM Construction/ • ESMF, ESMP, • Engagement with Vulnerable Groups: Two months Rehabilitation RPF, LRP, RAP, specialized • Physically afterproject of MLHCP SEP, GRM agencies dealing challenged effectiveness. Office and other with these persons with Throughout relevant project stakeholders to visual and project documentation. employ the most hearing (or implementation • Project appropriate other) information and means of impairment progress engagement. • Women, girls, updates • Limited poor and Informal disadvantaged 44 meetings childrenpregnant • Website school age girls • National news • Ebola/COVID-19 papers Survivors • Notice • Stakeholders in boards high illiterate atconstruction areas sites/communities • Drug addicts, commercial sex workers • Elderly people • Landowners • PAPs (including informal occupants), • Residents/busines ses in construction area • Vulnerable groups, • The public • OARG • MLHCP • Contractors Table 13: SPF Information Disclosure and Consultation Plan PROJECT LIST OF METHOD FOR TARGET TIMELINE STAGE DOCUMENTS DISCLOSURE STAKEHOLDERS PROPOSED FOR DISCLOSURE Project • SEP • News paper • MLHCP • Before appraisal Preparation • Website • OARG • Throughout • Online • PCU project • Community • TWG/IMTF implementation meetings/Outreach • LCs • Traditional Leader (Paramount Chief • Development partners • World Bank Group • Landholders • Land users 45 Project • Detailed • Social media • Landholders • During project Implementation information • Newspaper • Land users implementation about SPF • Posters and • LCs (Beneficiary brochures • Traditional Landholders, Leader LCs,likely (Paramount impact of Chief, section project, etc.) chiefs, town • SEP chiefs, Mama Queen and Youth Leader) • Chiefdom Land Committee representatives 46 5.0 RESOURCES AND RESPONSIBILITIES FOR IMPLEMENTING STAKEHOLDER ENGAGEMENT ACTIVITIES 5.1 Resources The MLHCP has established a PCU to handle the day-to-day coordination of Project activity will provide oversight and supervision in implementing the SEP. The MLHCP- PCU ill also ensure the hiring of the required personnel to implement the project including the roll out of activities related to SEP, i.e., a Community Engagement and Communications Specialist who will work closely with a Social and Gender Specialist and an Environmental Specialist. In addition, the MLHCP will ensure that the required funds are allocated and disbursed for the implementation of the SEP. For the SPF, MLHCP will recruit the Food and Agriculture Organization of the United Nations (FAO) to implement SPF activities through a Standard Form Agreement for the Provision of Technical Assistance by FAO under Bank- Financed Projects. FAO will hire a social specialist to support the FAO project team in implementing the parts of this ESCP that FAO is responsible for and liaise with the PCU. A proposed budget for the stakeholder engagement activities is outlined below, which will be financed from Component 4 (Project Management): The SEP budget seeks to define the most appropriate approach to meaningfully engage, consult, and disclose information about the project to all relevant stakeholders. The main goal of this SEP is to ensure inclusivity in the decision-making processes at every stage of the project preparation to implementation completion which will create an atmosphere o f understanding that actively involves project-affected people and other stakeholders in a timely manner.It will also provide sufficient opportunity for the various stakeholder groups to voice their opinions and concerns that may influence project decisions during the project design, implementation, and closure stages Table 14: Proposed Budget for the SEP Stakeholder Engagement Plan - Estimated Budget (5 Years) Stakeholder Engagement Quantity/ Unit Cost Times/ Total Cost Remarks Activities Number (USD) Years (USD) Fuel, Per diem, for Project staff and Local Travel 20 1500 5 150,000 stakeholder per quarter for 5 years ($7,500 X 20) Production and installation of 16 billboards at cost Printing - including IEC of materials Poster, 50 200 3 30,000 ($1,500X16=$24, / Billboard, Flyers, T-Shirt 000) Other IEC (Flyers, T-Shirt Lump summed of $6,000 15 CEM X $ Community Engagement 15 2000 5 150,000 10,000= $150,000 meetings (CEM) (3 CEMs per year) Specific expenses on Food and transport logistics related to SEP 25 2000 5 150,000 refunds for 2000 activities transport Refund, participants in 25 47 Refreshment stakeholder events ($75 per participant) Additional expenses on 10 Resource resource persons on SEP 10 2000 5 100,000 persons at ($10 X activities 10=$100,000.00) Other (contingency) Lump Sum 30,000 5% of total budget Grand Total 624,750 5.2 Management Functions and Responsibilities The Ministry of Land Housing and Country Planning (MLHCP) PCU will provide overall oversight for the implementation of the stakeholder engagement activities. MLCHP will collaborate with FAO to provide oversight of the SPF Project. A Project Steering Committee (PSC) will be established to provide guidance throughout project preparation and implementation. The PSC will be co-chaired by MoF and MLHCP and will be based on an existing land sector Inter-Ministerial Task Force (IMTF) structure within Sierra Leone’s VGGT implementation framework. Due to the multi-sectoral nature of land issues, a wide range of stakeholders will participate including Ministry of Environment; Ministry of Local Government and Rural Development; Ministry of Fisheries and Marine Resources; Ministry of Justice; Ministry of Agriculture and Forestry; Ministry of Gender and Children’s Affairs; Ministry of Mines and Mineral Resources; OARG; Environment Protection Agency (EPA); and the Sierra Leone Import and Export Promotion Agency.3 The IMTF may be expanded with the National Revenue Authority; Law Reform Commission; and the National Minerals Agency to ensure the PSC requirements of broad stakeholder representation is fully met. The project will report to the PSC/IMTF on a regular basis, including the implementation status of the SEP. Technical Working Group. A VGGT Technical Working Group (TWG) has been created in 2014 to support land sector reforms and consists of government, CSOs and private sector representatives. Development partners join the TWG as observers as needed. The TWG has updated its TORs to include as one of the key tasks to monitor and advice MLHCP on the implementation of donor funded projects, including the SLLAP. The TWG will provide technical advice during project implementation based on regular reports to be provided by the Project. The TWG will provide advice on the implementation of the SEP. 3 And/or the National Investment Board – new legislation is under consideration 48 6.0 GRIEVANCE REDRESS MECHANISM (GRM) FOR SLLAP This is the comprehensive project-wide Grievance Redress Mechanism (GRM) that will be instituted by the PCU before the commencement of project implementation to enable a broad range of stakeholders to channel their concerns, questions, and complaints tothe various implementation agencies, through multiple grievance uptake channels.. Particularly, the GRM will have a trained specialist to address any related issues and complaints. This will address RFP, SEP, ESMP and GBV complaints. Essentially, the GRM will assist in resolving complaints and grievances in a timely, effective, and efficient manner that satisfies all parties involved. It outlines a transparent and credible process for fair, effective, and lasting outcomes. Similarly, it builds trust and cooperation as an integral component of broader community consultation that facilitates corrective actions. Specifically, the GRM will: ▪ Ensure that appropriate and mutually acceptable redress actions are identified and implemented to the satisfaction of complainants. ▪ Avoid the need to resort to judicial proceedings as a way of seeking redress. ▪ Provide affected people with avenues for making a complaint or resolving any dispute that may arise during the project implementation. 6.1 The Grievance Redress Mechanism Process for SLLAP Grievances will be coordinated at the PCU level with a multi-channel grievance uptake process, through which project related grievances shall be received and resolved. The GRM will provide for anonymous reporting channels of logging complaints and grievances that will ensure confidentiality and anonymity of complainants. This will largely create an enabling environment to allow for grievances to be raised by project-affected persons without fear of victimization. The Project GRM process will b e coordinated by the PCU to ensure transparency and accountability in financial flow and distribution of relief items/supplies/consumables to people affected by the project. Grievances will be recorded at all levels, including communities and project sites. A focal person (s) within the PCU shall be assigned to coordinate all the grievances and complaints coming from all levels, man the call/documentation centre and ensure timely escalation of complaints and grievances to the resolving officers. The GRM process will also be integrated into the Anti-Corruption Commission platform. The GRM will include the following steps: ▪ Receiving and registering a complaint; ▪ Screening and investigating the complaint; ▪ Formulating a response; ▪ Selecting a resolution approach; ▪ Implementing the solution; ▪ Announcing the result; ▪ Tracking and evaluating the results; ▪ Learning from the experience and communicating back to all parties involved; and ▪ Preparing timely reports to management on the nature and resolution of grievances. 6.2 Scope of the GRM The GRM for the SLLAP will be available for use by all project stakeholders including those directly and indirectly impacted, positively or negatively, and the general public. This will offer an opportunity to 49 project affected persons to submit questions, concerns/complaints, comments, suggestions and obtain resolution or feedback. Basic rights and interests of every person affected by poor environmental performance or social management of the project are protected; and concerns arising from the poor performance of the project during the phases of design, construction and operation activities are effectively and timely addressed. While recognising that many complaints may be resolved immediately, the Complaints Register and Grievance Redress Mechanism encourages mutually acceptable resolution of issues as they arise. The Complaints Register and Grievance Redress Mechanism will be designed to be a legitimate process that allows for trust to be built between stakeholder groups and assures stakeholders that their concerns will be assessed in a fair and transparent manner, allow simple and streamlined access to the Complaints Register and Grievance Redress Mechanism for all stakeholders and provide adequate assistance for those that may have faced barriers in the past to be able to raise their concerns, provide clear and known procedures for each stage of the Grievance Redress Mechanism process, and provides clarity on the types of outcomes available to individuals and groups, ensure equitable treatment to all concerned and aggrieved individuals and groups through a consistent, formal approach that, is fair, informed, and respectful to a concern, complaints and/or grievances, to provide a transparent approach, by keeping any aggrieved individual/group informed of the progress of their complaint, the information that was used when assessing their complaint and information about the mechanisms that will be used to address it, and enable continuous learning and improvements to the Grievance Redress Mechanism. Through continued assessment, the learning may reduce potential complaints and grievances. Below is the list of persons/groups the project’s GRM will be targeted and informedabout the existence of the GRM and provided with the necessary support to access the GRM: • People potentially losing land due to office construction; • People that feel negatively affected by land registration and mapping outcomes; • Traditional Leaders; • Local Councils; • CSO; • Community leaders and the clergy; • Disability association • Women and girls centred groups; • Officers working at city councils; • Workers at construction sites; • Tax/dues payers; • Persons affected by or otherwise involved in project-supported activities. 6.3 Implementation Steps of GRM A Grievance Redress Committee shall be established to ensure timely and appropriate resolution of grievances arising as a result of project activities. The coordination responsibility of the GRM shall rest with the Social Safeguards and Gender Specialist with support from the Community Engagement and Communications Specialist in addition to focal persons in the affected communities, contractor and supervising teams and service providers (for SEA/SH complaints) or directly through a call/report center (Toll free line). Complaints can be registered through multiple accessible channels including phone calls, text messages, emails or voice mail, letters, verbal narration, reports during field visits, media reports, and suggestion boxes etc. at all project sites and communities. The project will collaborate with Anti-Corruption Digitalized Complaints System through a (Toll Free Line), PMU will sign a Memorandum of Understand with Anti-corruption. Once complaints are received at any levels, they will be forwarded the call or report centre(s) (with customised MLHCP/project website section) for sorting, to the GRM Committee or the appropriate bodies, persons or pillar leads for resolution and tracking of resolution process. Specifically, the following responsibilities shall be adhered to by the team; 50 i. Ensure that committees investigate grievances and propose appropriate measures to avoid or minimize adverse impacts of the interventions. ii. Ensure that the processes comply with existing safeguard procedures and policies. iii. Build the capacity of focal persons in effective community engagement, grievance handling, and negotiation and conflict resolution. iv. Build trust and maintain rapport by providing affected persons and the wider public with adequate information on the project and its GRM procedures. v. Follow up with GRM committee on the status of investigations and resolution of grievances, as well as communicating outcomes with complainants. vi. Keep and maintain up to date complaints and grievances register vii. Regularly provide a report on GRM results to the project proponents and the World Bank. The GRM implementation process steps which are summarized in table 15. Table 15: Steps in project-specific grievance handling processes GRM stages Description of tasks Responsibility Timeline Assign Focal The Social and Gender Specialist and the SLLAP-PCU Prior to project Persons(FP) Community Engagement and Communications implementation Specialist will constitute the GRM officers at the PCU level and will liaise with stakeholders to identify Focal Persons at the district and community levels and grievance committees Train assigned Train Focal Persons on grievance redress processes PCU, Social and Before Project focal persons on Gender Specialist Implementation the design and and the operation of the Community GRM Engagement and Communications Specialist Receive, The GRM will have several tiers fromthe Focal Persons 1 working day acknowledge community level by establishing the Local after receiving receipt and Mediation Groups, District level Mediation Groups, complaint transfer and PCU level and Project Steering Committee. GRM register Focal Persons/ officers will be assigned at the complaints n district a dcommunity levels to receive and register complaints into the complaintsand grievances register. PublicInformation Communications (PIC) Campaigns will be used to create awareness of the GRM. Complaints and A customized section on the Anti- Corruption Focal persons 1 working day grievance Digitalized complaints mechanism, MLHCP or after receiving register project website will be created to establish a complaint database to register complaints atthe PCU with access to GRM focal persons to transmit complaints received at project sites and communities. This will be complemented with a simple manual complaint form for use at the local levels. 51 GRM stages Description of tasks Responsibility Timeline Screen and refer Once complaints are received, the social safeguards Social and 2 working days complaints specialist or Focal Person will undertake preliminary Gender after receiving assessment of the eligibility of complaints, Specialist of the complaints categorize the grievance and assign priority (high, PCU medium, andlow severity and acknowledge receipts of complaints to complainant. The complaint will also be referred at this stage to the resolving officer or grievance redress committees if it cannot be resolved immediately by theSocial and Gender Specialist or focal person. The Social and Gender Specialist focal person will assign timelines for investigating. Oncetransferred to the appropriate resolvingofficer or GRM committee, the Social and Gender Specialist/ focal person will track the resolution process to ensure timely feedback. Assessment/ The resolving officer or Grievance committee will Social and 2 weeks after investigation of undertake further assessment to establish the merits Gender receiving the complaint or demerits, undertake fact finding and outline Specialist of complaints options for resolving the PCU, Grievance complaint. Committee Formulate an Once the assessment/ investigation is completed, the Social and initial response social safeguards/focal person will receive the report Gender and formulate a response and communicate to the Specialist /Focal 2 working days complainant. The communication should state Persons whether the grievance has been accepted or rejected, providing reasons for the decision, and indicate next steps. Select a Where the complaint is not of fraud or corruption, Social and 3 working days resolution working with the Social and Gender Specialist, the Gender after receiving approach GRM Committee will investigate and resolve Specialist / complaints complaints and where applicable to a specialised Focal Person body or an appropriate pillar focal person will assign GRM the complaint for mediation at different levels, Committee engage in direct negotiations and dialogue, facilitate negotiations through a third party, conduct further investigation through the review of documents, etc. Settle the issues The Social and Gender Specialist will ensure that Social and (or further the GRM Committee takes appropriate measures to Gender 5 working days escalate the remove the cause of the grievance and initiate a Specialist / after issues) monitoring process to assess any further Focal Person registering impacts of project-related work. Once settled, the GRM complaint Social and Gender Specialist and focal person Committee record the complaint in the system as ‘resolved’ and inform the complainant of the outcome of the resolution process. Where the complainant is not satisfied with the outcome, the complainant will be informed about the appeal process and the outcome recorded accordingly. 52 GRM stages Description of tasks Responsibility Timeline Monitor and The PCU through the Social and Gender Specialist Social and evaluate Focal Person will monitor the grievance redress Gender Throughout grievance redress process and the implementation of the decisions Specialist /Focal implementation process made. The Social and Gender Specialist will work Person with focal persons to ensure that redress is granted to GRM affected persons in a timely and efficient manner. Committee They will also provide regular reports to the Bank, noting the progress of implementation of grievance resolutions, timelines of grievance redress, documentation procedures, etc. Feedback to The GRM System will be updated once the PCU Throughout complainant and complaint has been resolved so as to close the implementation other interested complaint in the GRM System. The PCU will parties contact the complainant, to evaluate if the complainant is satisfied with the resolution before the complaint is closed in the GRM system. If the complainant is not satisfied with the outcome of the investigation, a judiciary alternative could apply. Public This will be used to raise awareness of the GRM on PCU, Throughout Information where to submit complaints and the resolution Community implementation Communications process. Engagement and (PIC) Campaigns Communication s Specialist The coordination responsibility of the GRM shall rest with the SLLAP Social and Gender Specialist. Complaints can be registered through calls, text messages, emails or voice mail, and suggestion boxes, etc. at all project sites and communities. Once they receive complaints from the call or report centre, they will be responsible for logging all complaints, the fraud/corruption complaints will be investigated and resolved by the PSC. All other complaints will be forwarded to the GRM Committee, or the appropriate bodies, persons or pillar leads for resolution. Specifically, the followingresponsibilities shall be adhered to by the team. 1) Ensure that committees investigate grievances and propose appropriate measures to avoid or minimize adverse impacts of the interventions 2) Ensure that the processes comply with existing safeguard procedures and policies 3) Build the capacity of focal persons in effective community engagement, grievance handling, and negotiation and conflict resolution 4) Build trust and maintain rapport by providing affected persons and the wider public with adequate information on the project and its GRM procedures 5) Follow up with GRM committee on the status of investigations and resolution of grievances, as well as communicating outcomes with complainants 6) Regularly provide a report on GRM results to the PSC and the World Bank. The SLLAP GRM will include confidential mechanisms to gather and respond to GBV and Sexual Exploitation and Abuse (SEA) related grievances. The GRM process will provide survivors of GBV/EA with channels to report a GBV service provider, the project Social and Gender Specialist with encrypted section for data protection, The SEA/SH response will include case management and linking to services such as Psycho-social, health, legal etc. 53 The project will maintain an up-to-date grievance log and all supporting documents and will institutes regular reporting of the grievance data as part of the project quarterly monitoring to the Bank. The project will track the types of complaints received, response times, offers of resolution, and acceptance and complaints resolved vs. appealed etc. For SEA/SH, the project will report on the number of SEA/Complaints (without any identifiers), whether complaints are related to the project workers, type, and effectiveness of service provision. Through annual surveys and community engagements, the project will assess the effectiveness of the GRM and make changes as appropriate. 6.4 Key Stakeholders Roles and Responsibilities in the GRM Process Specific roles and responsibilities of key stakeholders in the GRM Process are outlined in table 16 below. Table 16: Stakeholder Roles and Responsibilities in GRM Processes Actor Role Provides implementation oversight of Government of Sierra Leone and MLHCP other Donor Partners on the SLLAP funding GRM focal person Detect or investigate and resolve any complaint pertaining to the project Responsible for project management including social and environmental PCU – MLHCP issues on project NGO (Rainbo Initiative, Appropriate partners/NGOs with capacity to provide the necessary 50:50, etc.) technical backstopping to project implementation process CSOs (Namati, Green Assist with monitoring of GRM and provide advice as needed with regard to land Scenery, NMJD, Sierra related disputes Leone Land Alliance, etc.) Local councils/Ward WCs would be responsible for community mobilization, facilitating community Committees/Chiefdom planning, support community level grievance uptake & other community Committee capacity building initiatives to support project implementation Police/Judiciary Appropriate police/judiciary body with capacity to receive/record/log/document, re-investigation and resolve all SLLAP related complaints when resolution fails at the first level. PSC The PSC will meet at least every quarter to resolve strategic issues affecting the Project execution, provide policy guidance, and reviewproject implementation progress and results indicators Contractor/supervising consultants Contractor will be obligated through contractual clauses to make availablea GRM for workplace and community complaints. The PCU will ensure this is established while making available the project GRM channelsavailable at the site level as next tiers available to workers to escalate complaints. The contractor and supervising consultants will maintain staff at the site level for management of community complaints. 54 7.0 GRIEVANCE REDRESS MECHANISM (GRM) FOR SPF GRM associated with the implementation of the SPF will be specified in detail in the Standard Project Agreement signed between FAO and MLHCP, including purpose of GRM and guiding principles, as well as resolution mechanisms and contacts. FAO will be responsible for documenting and reporting as part of the ESF performance monitoring on any grievances received and how they were addressed. FAO is committed to ensuring that its projects and programs are implemented in accordance with the Organization’s environmental and social obligations. Concerns of non-compliance must be addressed at the closest appropriate level, i.e., at the project management/technical level, and if necessary, at the FAO Country Office or Regional Office level. If a concern or grievance cannot be resolved through consultations and measures at the project management/technical level, a grievance requesting a Compliance Review may be filed with the FAO Office of the Inspector General in accordance with the Guidelines for Compliance Reviews Following Grievances Related to the Organization’s Environmental and Social Standards4. Project Managers will have the responsibility to address concerns brought to the attention of the officially designated project grievance focal point. 4 https://www.fao.org/3/i4439e/i4439e.pdf 55 8.0 MONITORING, EVALUATION AND REPORTING A project monitoring and evaluation system will be established by the PCU-MLHCP to assess progress on indicators in the Project’s results framework. Similarly, FAO will establish a monitoring and evaluation system for the SPF Project. Data on activities and outputs will be included in regular monthly and quarterly reports prepared by the PCUs based on inputs from the implementing agencies, including MDAs’ focal points and at the local councils’ level, in accordance with the format in the Project’s Implementation Manual (PIM). FAO will deliver periodic quarterly reports on the SPF Project, as detailed in the Standard Project Agreement, including Inception Report, and Annual Narrative and Financial reports. The M&E Specialist at the PCU will be responsible for collating the data from project stakeholders and providing quality assurance as well as overall reporting. Citizen engagement will be ensured by the development and implementation of a digital citizen engagement platform in which citizens can access the status of activities funded under the Project and provide feedback. This will be complemented by a continuous iterative beneficiary monitoring and regular compliance audits to allow the project to adjust the implementation approach on a real-time basis. 8.1 Involvement of Stakeholders in Monitoring Activities A participatory system of monitoring and reporting on all project activities and related impacts shall be adopted. Participatory monitoring and evaluation will involve bringing stakeholders at different levels (national, regional, district, Chiefdom, ward, community) to work together to collect and analyse information on project activities and results and generate recommendations on how to improve project delivery. The key stakeholders to be involved in the participatory monitoring system will comprise representatives from the PCU, traditional leaders, Local Councils, Implementing Agencies, Affected Communities, and Development Partners, Ward Committees, Counsellor’s representatives of identifiable associations, CSOs, etc. This is expected to promote strong, constructive and responsive relationships among the key Project stakeholders and the implementingagency. Effective involvement of relevant stakeholders in the monitoring and reporting of project activities will not only improve the environment and social sustainability of the projects but will also enhance stakeholder acceptance of the project thereby improving the design and implementation of the project. The monitoring framework for the project will also include putting in place data capture and storage systems to keep track of the commitments made to various stakeholder groups at various times, and communicate the progress made against these commitments on a regular basis. The MLHCP shall provide overall coordination, monitoring, and evaluation of the project by putting in place the requisite tools and systems (GRM section on relevant websites, M&E systems, reporting templates, etc.) in place to collect, analyse, and report all information to relevant stakeholders. This Stakeholder Engagement Plan (SEP) will be published on the MLHCP and MOF official websites, and updated regularly detailing public consultations, disclosure information and grievances throughout the project, which will be available for public review on request. The PCU and third-party monitoring consultant should evaluate the Stakeholder Engagement Plan periodically to reflect relevant changes as may be required. 8.2 Reporting back to Stakeholder Groups Managing stakeholder expectations is a sine qua non to determining the success of people centred project like SLLAP. The SEP will be periodically revised and updated as necessary in the course of project implementation in order to ensure that the information presented herein is consistent and 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. Any major changes to the project related activities and to its schedule will be duly reflected in the SEP and communicated to key stakeholder of the project in a timely manner. Key Performance Indicators (KPIs) for SLLAP will be monitored by responsible staff and monthly 56 summaries and internal reports on public grievances, enquiries, related incidents, together with the status of implementation of associated corrective/preventative actions generated and conveyed to the World Bank and all other relevant stakeholders. Publication of status/annual report on stakeholder interaction on the project among others shall constitute one of the possible ways of conveying information to stakeholders. 57 Table 17: Monitoring and Evaluation Plan for SEP Methodology for Data Responsibility Indicator Name/ Topic Definition/Description Frequency Data source Collection for Data Collection Goal: This measures the extent to Conduct stakeholder MLHCPMU Inclusive delivery of project which project results are satisfaction survey on through effective stakeholder Bi-annual Bi-annual delivered without any major implementation of consultations and engagements environmental and social risks project Outcomes: Conduct bi-annual This measures the extent to stakeholder satisfaction Stakeholders satisfied with project Bi-monthly which key stakeholders are Bi-annual survey on project MLHCP activities/outputs survey satisfied with project activities. activities in their localities This measures the rate at which MLHCP complaints and grievances Complaints and Complaints and grievances Review statuses of arising from the project are Monthly grievances resolved amicably grievances resolved resolved peacefully to the register satisfaction of all parties This measures the extent to Zero or minimal incidences of Monthly review of which the project is implemented GBV gender-based violence during Monthly project reports for MLHCP without any reported cases of records/reports project implementation incidences of GBV gender-based violence Outputs: Review project Key stakeholders identified This measures the number and Biannually SEP for SLLAP documents at MLHCP MLHCP &C/L types of stakeholders identified Cs 58 for engagement during project Stakeholders implementation register for project This measures the number of Stakeholder Review project consultations carried out with Key stakeholders consulted Monthly consultation documents at MLHCP MLHCP key stakeholders before and reports duringproject implementation This measures the number and Review projectdocuments Reports on types of stakeholders during at MLHCP Key stakeholders engaged Monthly stakeholders MLHCP project preparation and engaged implementation This measures the number and SEP, reports on Review project Key project information disclosed type of project information Monthly information documents at MLHCP, MLHCP disclosed disclosure OARG & C/LCs This measures the number and SEP Review project Key issues/topics stakeholders are types of issues or topics Monthly documents at MLHCP MLHCP consulted or engaged on stakeholders are consulted or ESCP engaged on This measures the number and GRM reports Review project Grievances recorded types of grievances recorded as a Monthly documents at MLHCP MLHCP result of project activities E&S reports Creating foundation of successful Monthly GRM reports Review project Grievances resolved resolution of concern and documents at MLHCP MLHCP complaints related to project E&S reports affected person 59 9.0 ANNEXES Annex 1: Stakeholders consulted during the assignment NO NAME LOCATION TITTLE/ORGANIZATION CONTACT Dr. Alphajoh Cham Freetown Director, Policy,Planning and Project alphajohcham@yahoo.com 1 Development- MLHCP 2 Buawa Jobo Samba Freetown MLHCP- Director, GIS andRemote Sensing jobosamba@yahoo.com 3 Tamba Dauda Freetown MLHCP- Director, Surveysand Lands tambadauda673@gmail.com 4 Sahr Kanawa Freetown MLHCP- Director, Country Planning sahrmarkkanawa@gmail.com 5 RasheedCharles Ngiawee Freetown MLHCP - Director, Housing lansanacharles@gmail.com 6 Abu BakarrJalloh Freetown MLHCP-Deputy Director,Housing abaja5282@gmail.com Mohamed Momoh Banya Freetown MLHCP- Deputy Director, Country samabanya08@gmail.com 7 Planning 8 Edward Sam Freetown MLHCP- ICT Manager edward.sam@mlhe.gov.sl 9 Bob Lucas Freetown MLHCP- Ag. Deputy Director, Policy 10 Sellu MacCarthy Freetown MOF- Senior Economist sellumacarthy@gmail.com 11 MARTIN BOCKARIE HANGHA M & E OFFICER 078516182 12 ABIBATU AMARA HANGHA GENDER &CHILD PROTECT 076114251 13 AHMED S KOROMA KENEMA CA 076303054 14 MOHAMED E. NGEVWO KENEMA ENV.& SOCIAL OFFICER 079662455 15 JOSEPH G.T GANDO KENEMA CHIEF ADMINISTRATOR 078435339 16 HAWA B. VANGAH HANGHA SECTOR CHIEF 079440745 17 MOIJAMA GBENYAWA HANGHA TRIBAL AUTORITY 18 ROSALINE J. MUSA KENEMA TRIBAL AUTHORITY 076806717 19 ZAINAB LAVALLEY KENEMA LAND OWNER 072598126 20 TENNEH SHERIFF KENEMA LAND OWNER 076177500 21 KADIATU JONJON KENEMA LAND OWNER 076533578 22 JULLIET MUSA KENEMA CHAIR LADY 079525375 23 COMFORT LAHUN KENEMA CHAIR LADY 078328845 24 HAJA A KALLON KENEMA CHAIR LADY 076272846 25 ADAMA JUANA KENEMA CHAIR LADY 079655686 26 MUSU KARGBO MAKENI PROJECT OFFICER 077755715 IBRAHIM FATU KAMARA MAKENI PROGRAMME DIRECTOR 076692769 27 NO NAME LOCATION TITTLE/ORGANIZATION CONTACT 28 MARIE M.K THULLAH MAKENI PROJECT OFFICER GFP – SGFP 076704419 29 MOHAMED KARGBO MAKENI PROJECT OFFICER 076830860 NABIEU DARLINGTON MAKENI GRANT MANAGER 076620913 30 LAVALIE 31 JOSEPH DECKER MAKENI VOLUNTEER 076125225 32 GIBRILLATU M. BANGURA MAKENI PROJECT OFFICER 077527714 33 ALIE MANSARAY MAKENI PROJECT OFFICER 033915602 34 EVELYN KAMARA-DARKO MAKENI PROJECT ACCOUNTANT 077456155 35 ALHASSAN MORLAI KAMARA MAKENI MLHCP 076492823 36 ALIMAMY MANSARAY MAKENI MLHCP 075570486 37 TEJAN I BANGURA MAKONTEH Chiefdom Committee Member 08897012 38 BAI KANU MAKONTEH HEAD MAN - 39 ABDULAI KANU MAKONTEH ELDERS 030373885 40 JOSEPH KAMARA MAKONTEH - 41 MOHAMED KAMARA MAKONTEH YOUTH LEADER 076890454 42 FOUAD KAMARA MAKONTEH YOUTH LEADER 079918617 43 AMADU B. TURAY MAKONTEH ELDER 074149608 44 MOHAMED D SANKOH MAKONTEH Youth Chairman 077726639 45 MOHAMED D. BANGURA MAKONTEH Land Owner 030369655 46 DAVID SESAY MAKONTEH Land Owner 088898436 47 MOHAMED KANU MAKONTEH Disability person - 48 BAI BANGURA MAKONTEH Traditional Chief - 49 GIBRILLA O. BANGURA MAKONTEH TRADITIONAL HEALER 077892223 50 LAHAI K. MACAVORAY BOMBALI DISTRICT DEPUTY CA 079040929 51 MOHAMED QUEE BOMBALI DISTRICT ENVIRONMENTAL OFFICER 099107647 52 VIVIAN S. SENESIE BOMBALI DISTRICT CA 076602583 53 DANIEL KPUKUMU MAKENI CITY COUNCIL CA 076130529 54 RICHMOND M. KPANGE MAKENI CITY COUNCIL CWG 076193198 55 AMINATA TURAY MAKENI CITY COUNCIL ACCOUNTANT 079611778 56 EMMANUEL Y. SAMURA MAKENI CITY COUNCIL PO 079227941 57 YUSUF TEJAN KAMARA MAKENI CITY COUNCIL DPO 076533174 58 GEORGE ALIMAMY KABBA MAKENI CITY COUNCIL VALUATOR 030368880 59 ABDULAI BAYO MANSARAY MAKENI CITY COUNCIL M & E OFFICER 077580954 60 KARIM KARGBO MAKENI MLHCP 076775648 61 VICTOR NGEGBA PORT LOKO M & E OFFICER 076200227 NO NAME LOCATION TITTLE/ORGANIZATION CONTACT 62 AISHA M. KABBA PORT LOKO GENDER OFFICER 078276676 63 HAWA T. COOMBER PORT LOKO DEPUTY CA 078811239 64 ALHAJI BANGURA PORT LOKO CA 076608618 MADAM UMA SESAY SS CAMP COMP. MAMMY QUEEN 030606852 65 MANSARAY DR MADUSU KAMARA SS CAMP COMP. COUNCILLOR & MIDWIFE - 66 MANSARAY DR CHIEF YABOM POSSEH KANU SS CAMP COMP. FARMER/GARDENER 088989423 67 MANSARAY DR 68 CHRISTIANA BUCK MANSARAY DRIVE HOUSE WIFE 075966331 69 CHRISTIANA KOROMA MANSARAY DRIVE CHAIR LADY CBO REP. 088967318 70 CECILIA KANU MANSARAY DRIVE YOUTH 080157421 71 MAMMY FATU REGENT COMMUNITY STONE BROKER 077447490 72 SALAMATU BANGURA KAMACHENDEH DRIVE FARMER 73 CHIEF MOHAMED S. KOROMA NEWTON/4MILE MENDE TRIBAL HEAD 088149155 74 ALIMATU H. KAMARA NEWTON/4MILE COUNCILOR/TEACHER - 75 MUSA SAMURA NEWTON/4MILE WARD COMMITTEE MEMBER 088799625 76 SALIEU A. KAMARA NEWTON/4MILE YOUTH COMMITTEE 074620113 77 MOHAMED O KAMARA NEWTON/4MILE CHAIRMAN DRIVERS 079369117 78 MUSTAPHA JAMES NEWTON/4MILE COMMUNITY STAKEHOLDER 079651272 79 IBRAHIM KOROMA NEWTON/4MILE TEACHER 088811134 80 YUSIFU SAM BANGURA NEWTON/4MILE YOUTH 077376371 Annex 2: List of People Consulted for Preparation of RPF No. Name Designation Phone number Freetown 1. Alphajoh Cham Director, PP&PD, MLHCP 2. Buawa Jobo Samba Director, GIS 3. Kaweni Kargbo Procurement Specialist, PFMU 4. Sheku Mark Kanneh Acting Director, EPA 5. Mamudu M Jalloh Assistant Staff Surveyor. MLHCP 6. Alhaji B Dumbuya Assistant Staff Surveyor, MLHCP Bo 7. Joseph Bindi Bo District Chairman +23276275897 8. Sellu Ansumana Lappia Youth Leader +232 78292626 9. Jarai Barrie CSO, District Director +232 76622508 10.Amara Young Bockarie Regional Housing Officer, MLHCP +232 79462919 11.Joseph Kpanabom Regional Surveyor, MLHCP +232 76882607 12.PC Prince Lappia Boima Paramount Chief, Bo Kakua Chiefdom 13.Harold Tucker Mayor, Bo City Council +232 76 639235 14.Veronica Fortune Chief Administrator, Bo City Council +232 76 654986 15.Joseph Borbor Nallo Gender Officer +232 78 322324 16.Haja H Lukulay Development and Planning Officer, Bo +232 78 367109 City Council 17.Doris Fambulleh Women’s Leader +232 76 994544 18.Abu Bakarr Kamara Disability Group +232 78 842211 19.Fatmata Rogers Market Women +232 76 346631 20.Mohamed Bundu Chief Marketing Officer, Bo +232 76 114251 Kenema 21.Alhaji Mohamed Mansaray Youth Chairman +232 78 382364 22.Alie H D E Koroma Secretary General +232 78 250338 23.Abubakarr Kamara Regional Surveyor, MLHCP +232 76 795252 24.Ella M Goba District Women’s Leader +232 76 659250 25.Augustine A Sannoh Regional Head Civil Society Movement +232 76 643117 26.Thomas Baio Mayor, Kenema City Council +232 76 641538 27.Dugba Ngombu Regional Training Facilitator, +232 79 609720 Decentralisation Secretariat No. Name Designation Phone number 28.Mohamed Gevao ESO +232 79 662435 29.Joseph G T Gando Chief Administrator +232 78 435589 30.Patrick Jakima Deputy Chief Administrator +232 76 768595 31.Mohamed O Sesay Kenema District Council Chairman +232 76 784642 32.Ibrahim Bockarie ESO +232 78 336938 33.Abibatu Amara Gender Officer +232 76 114251 Makeni 34.John Shanghai Koroma Bombali District Council Chairman +232 88 155003 35.Isatu Fofanah Deputy Mayor, Makeni City Council +232 76 690616 36.Abdul S Mansour Deputy Chief Administrator +232 76 726512 37.Yusuf Tejan Kamara Development and Planning Officer +232 76 533174 38.Yusuf Kargbo Waste Manager +232 76 268428 39.Abdul Karim Regional Surveyor, MLHCP +232 76 775648 40. Town Planning Officer 41.Frank Kanu Development and Planning Officer +232 76 277570 42.John D Kamara GDO +232 77 504411 43.Konta Marah M&E Officer, Makeni City Council +232 76 448824 Port Loko 44.Augustine Sam Chief Administrator, Port Loko District +232 76 925555 Council 45.Zakaria Bangura Deputy Mayor +232 78 821930 46.Sheikh Gibril Sesay Council Engineer +232 76 787373 47.James Rogers ESO +232 78 512826 48. Procurement Officer, Port Loko District Council 49.Hawa T Coomber Deputy Chief Administrator, Port Loko +232 78 811 239 District Council 50.Cecilia F Sesay ESO +232 76 758249 51.Aisha Mariam Kabba Gender Officer +232 78 276676 52.Victor Ngegba Ag. Development and Planning +232 78 200227 Officer/M&E Officer 53.Simbo Regional Surveyor, MLHCP +232 79 803848 Annex 3 : List of People Consulted for Preparation of ESMF