ancillary REPUBLIC OF MADAGASCAR MINISTRY OF PUBLIC WORKS / ROADS AGENCY CONNECTING MADAGASCAR FOR INCLUSIVE GROWTH PROJECT (P173711) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Updated version on April 2024 following CERC Activation ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Madagascar (the “Recipient) will implement the Connecting Madagascar for Inclusive Growth Project (the “Project”), through the Roads Agency (“RA” and “Project Implementing Entity” and the Project Implementation Unit for the Project (or RA PIU)), with the involvement of inter alia: the Ministry of Public Works (MPW), Ministry of Transport and Meteorology (MTM), the Ministry of Economy and Finance (MEF) and the Connectivity for rural livelihood improvement project’s project implementation unit (or PACT PIU) in charge of the implementation of the CERC Component as activated in April 2024, with the Recipient”s Agence Portuaire Maritime et Fluviale (AMPF). The International Development Association (hereinafter “the Association”) has agreed to provide financing for the Project (P173711), as set out in the referred agreement. This ESCP supersedes previous versions of the ESCP for the Project and shall apply both to the original and the CERC Component for Project referred to above. 2. The Recipient shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Association. The ESCP is a part of the Financing Agreement and the Project Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Recipient shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted and implemented under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESS, and in form and substance, and in a manner acceptable to the Association. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the Association. 4. As agreed by the Association and the Recipient, this ESCP will be revised from time to time if necessary, during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to Project performance. In such circumstances, the Recipient through the Road Agency, Project Implementing Entity and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient designated official, Secretary general of the MPW. The Recipient shall promptly disclose the updated ESCP. 2 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES MONITORING AND REPORTING A REGULAR REPORTING Prepare and submit to the Association regular monitoring reports on the state of compliance with Submit reports to the Association every six months during - Project Implementation the actions set out in the ESCP and including, without limitation the implementation of (a) the Project implementation, starting six months after the Effective Unit (RA-PIU) environmental, social, health and safety (ESHS) performance of the Project in accordance with Date and to be maintained throughout Project - PACT PIU and AMPF the ESMF, RF, ESIAs and all derived plans and instruments, (b) the Stakeholder Engagement implementation. for the CERC Component Plan (SEP), (c) the Labor Management Procedures (LMP), (d) the Grievance Mechanism (GM) and (e) the GBV/SEA-SH Action Plan. B INCIDENTS AND ACCIDENTS Promptly notify the Association of any incident or accident related to the Project which has, or is Notify the Association no later than 48 hours after learning of - Project Implementation likely to have, a significant adverse effect on the environment, the affected communities, the the incident or accident. Unit (RA-PIU) public or workers, including, inter alia, cases of sexual exploitation and abuse (SEA), sexual - PACT PIU for the harassment (SH), and accidents that result in death, serious or multiple injury. Provide sufficient Provide subsequent report to the Association within a CERC Component detail regarding the scope, severity, and possible causes of the incident or accident, indicating timeframe acceptable to the Association. immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and/or supervising firm, as appropriate. Subsequently, at the Association’s request, prepare a report on the incident or accident and propose any measures to address it and prevent its recurrence. C CONTRACTORS’ MONTHLY REPORTS Require contractors and supervising firms to provide monthly monitoring reports on ESHS Contractor Monthly reports to be submitted to the PIU, and to - Project Implementation performance in accordance with the metrics specified in the respective bidding documents and the Association upon request. Unit (RA-PIU) contracts and submit such reports to the Association. - PACT PIU for the CERC Component ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE (1) Establish and maintain an organizational structure, the RA-PIU and PACT-PIU, with qualified - The environment specialist, the social specialist, and the - Project Implementation staff and resources to support environmental and social risk management, with qualifications GBV/SEA-SH specialist within the RA PIU and within PACT Unit (RA-PIU) acceptable to the Association, including an environmental specialist, a social specialist, and PIU are already operational. The organizational structure to - GBV/SEA-SH specialist. They shall ensure the application of the provisions made in this support effective environmental and social risk management - PACT PIU for the document and all environmental and social (E&S) documents prepared within the framework of shall be maintained during the implementation of the Project CERC Component the Project. and its CERC component. (2) Mobilize additional staff (consultants) who will support the implementation of E&S aspects for - Submit the position ToR to the Association for any additional short- or long-term assignments in accordance with the assessment or institutional needs. staff need prior to launch the hiring process 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT 3 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES (1) The Project has prepared and disclosed the Environmental and Social Management The ESMF has been disclosed on January 31, 2022 and shall - Project Implementation Framework (ESMF) as well as a standalone CERC-ESMF that addresses all E&S issues thereafter be implemented throughout Project Unit (RA-PIU) associated with the project, including E&S impacts from ancillary works, accommodation camps, implementation. - PACT PIU for the access roads. Update as necessary and disclose the updated document in accordance with the The CERC-ESMF has been prepared as a condition of CERC Component provisions of ESS 1, and in a manner acceptable to the Association. withdrawal of funds under the CERC under Section I.G. of Schedule 2 of the Financing Agreement for the Project, and disclosed on 04/23/2024. It shall thereafter be implemented throughout implementation of the CERC component. Any proposed updates to the ESMF shall be submitted to the Association for approval prior to implementation. Once approved, the ESMF will be implemented throughout the implementation of the Project. (2) Carry out environmental and social studies for all sub-projects, including among others The ESIA / ESMP for RN 31 and RN10 (Section 3-4) WAP - Project Implementation Environmental and Social Impact Assessments (ESIA), and Environmental and Social have been approved and disclosed in the country and at WB Unit (RA-PIU) Management Plans (ESMP) in accordance with the ESMF, particularly to ensure that the final External website respectively on January 30, 2024 and April - PACT PIU for the ESIA / ESMP addresses the cumulative impacts associated with each project component. 10, 2024. CERC Component For parent project - ESIA and ESMP related to the rehabilitation of RN 10 and RN 31 approved and disclosed. - ESIA and ESMP related to the rehabilitation of priority national roads The C-ESMPs for the CERC component will be submitted to - ESIA and ESMP related to the rehabilitation of feeder regional and communal roads the Association for approval and shall be disclosed before the launch of the rehabilitation works. For CERC Component All subsequent updated versions of the documents shall be - C-ESMP related to the emergency rehabilitation of RN 6 submitted for approval before their implementation. Once - C-ESMP related to the emergency rehabilitation of RN 4 approved, the instruments shall be re-disclosed and - C-ESMP related to the emergency rehabilitation of Mahajanga Port implemented throughout the execution of the Project. Prepare ESIA/ESMP reports, update if necessary, and submit to the Association for approval, publish and implement in a manner acceptable to the Association. If the concerned ESIA report considers that a labor influx management plan (LIMP) and Worker Accommodation Plan (WAP) are necessary, within the C-ESMP, as needed (3) Carry out specific environmental and social assessments required for each planned activity Submit ESIA/ESMP to ONE no later than 3 months after both - Project Implementation (Technical and public evaluation by the National Office for the Environment (ONE), Screening, MPW and Association clearance. Unit (RA-PIU) environmental and social management plans, social impact assessments) in accordance with the Conduct environmental and social assessments in the - PACT PIU for the ESMF, ESIA of the Project. concerned sites before the execution the civil works. CERC Component Ensure that Permits and environmental specifications are obtained for the whole or one of the Any identified risk management plan must be prepared and components/activities of the Project in accordance with the effective legal framework and ESS1, implemented before starting the works by the contractor. and in a manner satisfactory to the Association. 1.3 MANAGEMENT OF CONTRACTORS 4 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES (1) Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S As part of ToR and bidding documents and respective - Project Implementation instruments, the Labor Management Procedures, and code of conduct, into the ESHS contracts Unit (RA-PIU) specifications of the procurement documents and contracts with contractors and supervising Supervise contractors throughout Project implementation. - PACT PIU for the firms. Thereafter ensure that the contractors and supervising firms comply and cause CERC Component subcontractors to comply with the ESHS specifications of their respective contracts. (2) Develop, submit for approval and implement of the following procedures applicable to Prior to the start of the civil engineering works by the - Project Implementation contractors, subcontractors and the engineer: C-ESMP, which inter alia present operations phase Contractor. Once approved, the instruments will be Unit (RA-PIU) E&S management plans for the subprojects in accordance with the ESMF, RF, ESIA/ESMP, RP, implemented throughout Project implementation. - PACT PIU for the prepared by the Contractor, Hygiene – Health – Safety and Environment Plan (HSE Plan), Codes Supervise contractors throughout Project implementation. CERC Component of Conduct, Grievance Mechanism, Social commitments on child labor and other elements provided in the GBV Action Plan. 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. - Project Implementation Ensure that the consultancies, studies (including feasibility studies, if applicable), capacity Unit (RA-PIU) building, training, and any other technical assistance activities under the Project are carried out - PACT PIU for the in accordance with terms of reference acceptable to the Association, that are consistent with the CERC Component ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. 1.5 CONTINGENT EMERGENCY RESPONSE COMPONENT - Project Implementation 1. Adopt the CERC manual and the CERC-ESMF in form and substance acceptable to the The CERC-ESMF has been prepared as a condition of Unit (RA-PIU) Association to ensure that the CERC Manual as specified the Financing Agreement includes the withdrawal of funds under the CERC under Section I.G. of - PACT PIU for the results of the ESHS assessment and management arrangements and required management Schedule 2 of the Financing Agreement for the Project and CERC Component instruments for CERC activities. disclosed on 04/23/2024. 2. Prepare, disclose, consult, and adopt a C-ESMP for each activity under CERC component of The C-ESMP RN4- RN 6 and Majunga Port rehabilitation the Project, in accordance with CERC Manual and CERC-ESMF shall be prepared, disclosed, consulted, and thereafter adopted before the carrying out of the relevant Project activities under CERC component. The C-ESMP shall be implemented in accordance with their terms, throughout Project implementation. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES (1) A LMP has been prepared by the Project (including the Codes of Conduct establishing clauses LMP has been disclosed on January 31, 2022. It will be - Project Implementation and sanctions against GBV/SEA/SH acts required for all project workers namely Project applied throughout the Project implementation including Unit (RA-PIU) Implementation Unit, contractors and subcontractors and their workers) for the entire Project and CERC activities. - PACT PIU for the the CERC activities. Any subsequent updates to the LMP shall be submitted to the CERC Component Update if necessary and disclose the updated final validated version. Implement as deemed Association for approval, and to be re-disclosed before acceptable for the Association according to disposition in the ESS2. implementation. 5 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES (2) Ensure the signing of contracts, including the Codes of Conduct, with all Project Workers Prior to engaging any Project workers Project Implementation Unit (Direct workers, contracted workers, primary supply workers, community workers…) in (RA-PIU) accordance with the LMP guidelines. PACT PIU for the CERC Component (3) Ensure the signing of contracts and Codes of Conduct by the contractors, in accordance with Prior to engaging firms and subcontractors for the Project LMP guidelines. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish and operate a Grievance Mechanism (GM) for any matter related to work or Grievance mechanism shall be operational prior to the - Project Implementation employment under the Project, as described in the LMP and in accordance with ESS 2 for the recruitment of any Project workers and to be maintained and Unit (RA-PIU) Project (including CERC activities) Implementation Units, Contractors and subcontractors. implemented throughout the Project implementation period. - PACT PIU for the CERC Component EES 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1. RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 1. Incorporate resource efficiency and pollution prevention and management measures in the Same timeframe as for the adoption and implementation of - Project Implementation Unit ESIA/ESMP and C-ESMP to be prepared under action 1.2 (2) above. ESIA/ESMP (RA-PIU) Clearance of the C-ESMPs shall be a prerequisite for the start - PACT PIU for the CERC of all civil works. Component 3.2 WASTE AND HAZARDOUS MATERIALS MANAGEMENT Adopt and implement a Waste Management Plan (WMP), to manage hazardous and non- Same timeframe as for the adoption and implementation of - Project Implementation Unit hazardous wastes, consistent with ESS3, as part of the ESIA/ESMP and C-ESMP to be prepared ESIA/ESMP (RA-PIU) under action 1.2 (2) above. Clearance of the C-ESMPs shall be a prerequisite for the start - PACT PIU for the CERC of all civil works. Component EES 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY Incorporate measures to manage traffic and road safety risks as required in the ESIA/ESMP and Same timeframe as for the adoption and implementation of - Project Implementation Unit C-ESMP to be prepared under action 1.2 (2) above. ESIA/ESMP (RA-PIU) Clearance by the Association of the C-ESMPs shall be a - PACT PIU for the CERC prerequisite for the start of all civil works. Component 4.2 COMMUNITY HEALTH AND SAFETY 6 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES Assess and manage specific risks and impacts to the community arising from Project activities, Same timeframe as for the adoption and implementation of - Project Implementation Unit including, inter alia Project worker behaviour, labor influx, risks of SEA/SH, risks related to staff ESIA/ESMP (RA-PIU) safety, response to emergency situations, and include mitigation measures in the ESIA/ESMP and C-ESMP to be prepared under action 1.2 (2) above, in accordance with the ESMF. - PACT PIU for the CERC Clearance of the C-ESMPs shall be a prerequisite for the start Component of all civil works. 4.3 SEA AND SH RISKS (1) The Project has developed the SEA-SH Action Plan for the entire Project as part as the ESMF. - The SEA-SH action plan has been disclosed on January 31, - Project Implementation Unit Adopt and implement the /SEA-SH Action Plan in accordance with ESS4, as part of the ESIA/ESMP 2022 and will be applied throughout the Project (RA-PIU) and C-ESMP to be prepared under action 1.2 (2) above. implementation, including CERC activities - PACT PIU for the CERC - All subsequent version and update to the action plan should Component be submitted to the Association for clearance before implementation. Once approved, the SEA-SH Action Plan is implemented throughout Project implementation with the same timeframe as for the adoption and implementation of ESIA/ESMP (2) Ensure that all contractual and procurement documents (ToR, bidding documents, workers' (2) as part of the preparation of the procurement documents contracts) include the Codes of Conduct and provisions for the prevention and fight against and and prior to call of tender response to GBV/SEA-SH. (3) Ensure the implementation of an adequate support and referral system for GBV survivors in the (3) GBV support system shall be in place prior the installation Project area in line with the national and international good practices and the GBV Action Plan of any firm in each sub-project area. 4.4. SECURITY MANAGEMENT: Prior to engaging security personnel and thereafter - Project Implementation Unit Assess and implement measures to manage the security risks of the Project, including the risks of implemented throughout Project implementation (RA-PIU) engaging security personnel to safeguard project workers, sites, assets, and activities, as set out in the ESMP and in the Security Management Planguided by the principles of proportionality and - PACT PIU for the CERC GIIP, and by applicable law, in relation to hiring, rules of conduct, training, equipping, and Component monitoring of such personnel. 4.5 INVOLVEMENT OF THE MILITARY a) Ensure the following measures are carried out before deploying the Recipient’s Carry out a, b), c), and d) before deploying police/military/Gendarme in the implementation of Project activities for the provision of police/military/Gendarme under the Project and implement security to Project workers, sites and/or assets, consistent with the ESSs: throughout Project implementation. b) Assess and implement measures to manage the security risks of engaging the military/Gendarme, as set out in the ESIA and ESMP, guided by the principles of 7 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES proportionality and GIIP, and by applicable law, in relation to screening, hiring, rules of conduct, training, equipping, and monitoring of such military; c) Adopt and implement standards, protocols, and codes of conduct for the selection and assignment of military/Gendarme to the Project, and screen such military to verify that they have not engaged in past unlawful or abusive behavior, including sexual exploitation and abuse (SEA), sexual harassment (SH) or excessive use of force; d) Enter into a memorandum of understanding (MoU), with the ministry in control of military/Gendarme as relevant, setting out the arrangements for the engagement of the military in the Project, including the relevant actions and measures set out in this ESCP; e) Provide adequate instruction and training to the Recipient’s police/military/Gendarme, prior to deployment and on a regular basis, on the use of force and appropriate conduct (including in relation to civilian-military engagement, SEA and SH, and other relevant areas), as set out in the ESMP, Security Management Plan, MoU, as relevant; f) Ensure that the stakeholder engagement activities under the Stakeholder Engagement Plan (SEP) include communication on the involvement of Recipient’s police/military/Gendarme] in the Project; g) Ensure that any concerns or grievances regarding the conduct of [name military] are e) and f) as set out under actions 10.1 and 10.2 respectively. received, monitored, and documented (taking into account the need to protect Notify the Association after receiving the concern or grievance confidentiality) by the Project’s grievance mechanism (see action 10.2 below), which shall in the timeframe specified in action B above. facilitate its resolution, in accordance with ESS4 and ESS10. Notify Association after receiving the concern or grievance, as set out under action B above; and h) Where the Association so request in writing, after consultation with the [Borrower/Recipient]: (i) promptly appoint a third-party monitor consultant, with terms of reference, qualifications and experience acceptable to the Association, to visit and monitor the Project area where Recipient’s police/military/Gendarme] are deployed, g) within the timeframes requested by the Association. collect relevant data and communicate with Project stakeholders and beneficiaries; (ii) require the third-party monitor consultant to prepare and submit monitoring reports, which shall be promptly made available to and discussed with the Association; and (iii) promptly take any actions, as may be requested by the Association upon its review of the third- party monitor consultant reports. 4.6 MANAGEMENT OF CONTRACTORS Management of Contractors and include the following: The minimum E&S Clauses to be included During the preparation of bidding document - Project Implementation Unit in the bidding documents should cover: (I) Contractor past performance on ESHS aspects (RA-PIU) including sexual, exploitation and abuse and gender based violence; (ii) ESHS staff with the contractor; (iii) Performance security; (iv) Mitigation measures to address construction impacts; (v) - PACT PIU for the CERC Payments for implementation of ESHS measures; (vi) Code of conduct of Contractor’s personnel Component addressing SEA/SH behaviors and sanctions in case of non-compliance, regular training for workers on SEA/SH risks, and procedures to handle SEA/SH incidents in line with those 8 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES established by the project; (vii) Management Strategies and Implementation Plan to manage the ESHS risks. ESS 5: LAND ACQUISITION, LAND USE RESTRICTIONS AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT PLANS (1) The Project has prepared the Resettlement Framework (RF). Update as necessary and disclose The RF has been disclosed on January 31, 2022 and will be - Project Implementation Unit the updated document in accordance with the provisions of ESS 5, and in a manner acceptable to applied and maintained throughout the implementation of the (RA-PIU) the Association. Project. - PACT PIU for the CERC Any subsequent versions of the RF update must be submitted Component to the Association for approval prior to implementation. Once approved, the updated RF is to be implemented throughout the execution of the Project. (2) Prepare, disclose, consult, adopt Resettlement Plans (RP) (including Livelihood restoration Resettlement Plan for RNT31 and Resettlement Plan for - Project Implementation Unit plan) as necessary, in accordance with the requirements of the Resettlement Framework (RF) itself RNS10 (section 3-4) have been approved and disclosed in the (RA-PIU) established in accordance with the national provisions in force and the provisions of ESS 5, and in country and at WB External website respectively on November a manner acceptable to the Association: 11, 2023 and April 19, 2024. - PACT PIU for the CERC Component - Resettlement Plan for RNT31 All RP will be submitted to the Association for approval and - Resettlement Plan for RNS10 shall be disclosed before the launch of the call for tenders for - Resettlement Plan for feeder regional and communal roads. the implementation of the related activities. All RPs must be disseminated locally and, on the Association, and Project websites. The approval of RPs will be a prerequisite for disbursement/call for bids of the respective subproject (3) Develop, and update if necessary "an Expropriation and Compensation Manual" applicable to Manual to be developed, to be sent for validation by the - Project Implementation Unit the entire Project in accordance with ESS5 and the RF Association no later than 3 months after the effectiveness of (RA-PIU) the Project - PACT PIU for the CERC Component 9 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES (4) Develop separate monitoring reports of RP implementation, for sub-projects requiring land Monthly progress report of the RP to be sent to the PIU and - Project Implementation Unit acquisition, disruption of a source of income. Submit these reports to the Association for approval the Association upon request, (RA-PIU) during RP implementation. Develop a final implementation report documenting the full implementation of the RP to the satisfaction of the Association prior to the start of work. Mid-term report, with the evidence documents in the appendix - PACT PIU for the CERC must be sent to the Association before the closure of the RP Component under consideration. The PIU will include a summary of RP progress reports in the quarterly reports to be submitted to Final implementation report to be sent to the Association for the association per item A above prior to the start of work. approval prior to start physical works for the respective subproject 5.2 GRIEVANCE MECHANISM An overall GM is developed for the Project as a whole in the ESMF/RF/SEP. However, when During development of RPs - Project Implementation Unit developing any RP, ensure that the GM into the RP is in compliance with GM developed into (RA-PIU) RF/SEP. - PACT PIU for the CERC Component ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS 1. Ensure that biodiversity and natural habitat screening and assessment process for Project - Project Implementation Unit activities to ensure that impacts on biodiversity are identified and minimized in all ESIA/ESMP in During the preparation of ESIAs/ESMPs. (RA-PIU) accordance with the ESMF, and as part of the ESIA/ESMP and C-ESMP to be prepared under action 1.2 (2) above. - PACT PIU for the CERC Component 2. Prepare, disclose, consult upon and adopt specific ESIA/ESMPs in accordance with the As indicated in 1.2, submit for the Association’s prior approval measures described in the ESMF for substantial risk activities to avoid and/or minimize potential prior to civil works in or near the site that may affect natural or impacts from Project activities that will be conducted in the vicinity of these habitat types. These critical habitats. ESMPs shall be developed in accordance with the provisions of ESS 6, in a manner acceptable to the Association. Once validated, the ESIA/ESMP shall be implemented throughout Project implementation. ESS 7: INDIGENOUS PERSONSS / TRADITIONAL LOCAL COMMUNITIES OF HISTORICALLY DISADVANTAGED SUB-SAHARAN AFRICA NOT RELEVANT ESS 8: CULTURAL HERITAGE 8.1 CHANCE FIND PROCEDURE 10 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES (1) Ensure that “chance-find” clauses as defined in the Project ESMF shall be included in all works (1) Before the signing of each works contract with the awarded - Project Implementation Unit contracts, even in cases where the probability of discovery is low. works Contractor. (RA-PIU) 2. PIU will include chance find procedures in all works contracts and require each contractor to (2) Include CFP in bidding documents; screen site and prepare - PACT PIU for the CERC include and implement measures to manage chance finds in their Project approved C-ESMP, in a CHM prior to start of work where needed; in case of a chance Component manner acceptable to the Association. The Contractor ESMP is a complement to the ESMP find during construction, suspend works and restart only after prepared by the PIU. the respective management plan/procedure is in place (3) Apply the “chance-find” procedures described in the ESMF, in accordance with ESS8. (3) Procedures applicable throughout the implementation of the work and continuously until the end of Project. 8.2 CULTURAL HERITAGE 1. Develop a specific communication and awareness strategy, considering the procedures Before the start of relevant civil works, and throughout Project - Project Implementation Unit described in the ESMF, to avoid and/or mitigate the potential impacts of the implementation of implementation thereafter. (RA-PIU) Project activities on cultural heritage of the concerned areas (Based on past experiences, these can include sacred trees or rocks, among others.) - PACT PIU for the CERC Component (2) Develop and implement, if necessary, a Cultural Heritage Management Plan, in case of a chance discovery, in accordance with the provisions of ESS8, and in a manner acceptable to the Association ESS 9: FINANCIAL INTERMEDIARIES NOT RELEVANT ESS 10: STAKEHOLDERS ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 PREPARATION AND IMPLEMENTATION OF THE STAKEHOLDER ENGAGEMENT PLAN (SEP) The Project has updated a SEP to cover the CERC component, consistent with ESS10, which The original SEP has been disclosed on January 31, 2022. The - Project Implementation Unit include measures to, inter alia, provide stakeholders with timely, relevant, understandable and updated SEP including CERC activities has been prepared (RA-PIU) accessible information, and consult with them in a culturally appropriate manner, which is free of and shall be applied and maintained throughout the manipulation, interference, coercion, discrimination and intimidation. implementation of the Project. - PACT PIU for the CERC Component Any subsequent updates to this SEP shall be submitted to the Association for clearance before implementation. Once cleared, the SEP is to be implemented throughout the Project implementation. 10.2 GRIEVANCE MECHANISM 11 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES The Project GM was developed under the SEP. This GM shall have the capacity to handle SEA/SH GM to be applied and maintained throughout the Project Implementation Unit (RA- allegations. Adopt and implement the (GM) as described in the Stakeholder Engagement Plan implementation of the Project. PIU) (SEP) As needed, the GM to be updated periodically: any update of the GM shall be submitted to the Association for approval prior to implementation. Once approved, ensure operationalization PACT PIU for the CERC and monitoring throughout the implementation of the Project. Component CAPACITY SUPPORT (TRAINING) CS1 Themes within the framework of workers' capacity building Organize and train direct Project workers to increase their understanding of the potential risks and When RA-PIU E&S specialists and GBV specialist are hired. Project Implementation Unit (RA- impacts associated with Project activities and their roles and responsibilities in assessing and PIU) managing those risks and impacts. Before the start of civil works and, as needed, during the implementation of the Project in accordance with a Capacity Also ensure that contract workers are trained to be more aware of the potential environmental and building Plan developed by the Project implementation Unit social risks and impacts associated with Project activities and to be aware of measures to mitigate PACT PIU for the CERC adverse effects on working conditions. Component For direct workers, training will cover the following topics (non-exhaustive list): - ESF, ESS and World Bank Group EHS Guidelines - Stakeholder Engagement - Health and safety of workers and communities - GBV and SEA/SH risk mitigation - Emergency preparedness and response - Training on inclusion of vulnerable and disadvantaged groups in the consultation process, GM, Project mitigation and benefits - Grievance mechanism - Development, implementation, monitoring and reporting in accordance with the LMP, ESMF, RF, ESCP - Sensitization, awareness and prevention on infectious and sexually transmitted infections: COVID-19, HIV/AIDS, ... - Raising awareness on GBV including SEA-HS and child protection - Raising awareness on barrier measures against the spread of Covid-19 - Implementation of RP CS2 Themes in the framework of capacity building of work an engineering Contractors (non-exhaustive list) For contract workers, training will include (but not be limited to): Before the start of the civil engineering works, upon notification Project Implementation Unit (RA- of the works Contractor PIU) - Introduction to the ESF, ESS and World Bank Group EHS Guidelines - Implementation of ESMPs, including: Specific training 12 RESPONSIBLE ENTITIES / MATERIAL MEASURES AND ACTIONS TIMEFRAME AUTHORITIES - Health and safety of workers and communities Regular recycling PACT PIU for the CERC - GBV awareness, control and prevention Component - Emergency preparedness and response - Complaints management mechanism - Development, implementation, monitoring and reporting in accordance with the LMP, ESMPs - Sensitization, awareness and prevention of sexually transmitted infections: HIV/AIDS ... - Sensitization on measures against the spread and control of Covid-19 and other infectious diseases 13