The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) Program Information Document (PID) Concept Stage | Date Prepared/Updated: 23-Feb-2023 | Report No: PIDC275452 Feb 22, 2023 Page 1 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) BASIC INFORMATION A. Basic Program Data OPS TABLE Country Project ID Parent Project ID (if any) Program Name Pakistan P179807 Pakistan Grows Open, Resilient and Wealthy Does this operation Region Estimated Appraisal Date Estimated Board Date have an IPF component? SOUTH ASIA 14-Jun-2023 31-Jan-2024 Yes Financing Instrument Borrower(s) Implementing Agency Practice Area (Lead) Program-for-Results Islamic Republic of Pakistan Ministry of Commerce Macroeconomics, Financing Trade and Investment Proposed Program Development Objective(s) To support the growth of an open and resilient economy. COST & FINANCING FIN_SRC_TABLE1 SUMMARY (USD Millions) Government program Cost 495.00 Total Operation Cost 250.00 Total Program Cost 230.00 IPF Component 20.00 Total Financing 495.00 Financing Gap -245.00 FINANCING (USD Millions) Total World Bank Group Financing 250.00 World Bank Lending 250.00 Total Government Contribution 245.00 Feb 22, 2023 Page 2 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) Concept Review Decision B. Introduction and Context Country Context 1. Over the past two decades, Pakistan has achieved significant poverty reduction, but human development outcomes have lagged, and economic growth has remained volatile and slow. Expansion of off-farm economic opportunities and the increase in migration and associated remittances have allowed over 47 million Pakistanis to escape poverty between 2001 and 2018. Despite rapid poverty reduction, human capital outcomes have remained poor and stagnant, with high levels of stunting at 38 percent and learning poverty at 75 percent.1 Pakistan has also experienced frequent macroeconomic crises due to a growth model based on private and government consumption, with productivity-enhancing investment and exports contributing relatively limited gains. Growth of per capita gross domestic product (GDP) has been low, averaging under 2 percent in the last two decades.2 Unprecedented floods in 2022 are likely to have serious impacts on poverty, human development outcomes, and economic growth. 2. Supported by accommodative macroeconomic policy, Pakistan’s economy saw robust growth in FY22, at the cost of growing economic imbalances. These imbalances, including sizeable fiscal and current account deficits and high inflation, are recurrent in nature and symptoms of long-standing challenges of low productivity growth. This time round, the imbalances were exacerbated by surging global commodity prices and the devastating floods, that led to dwindling foreign reserves. The low levels of reserves and continued policy slippages, including exchange rate manipulation, resulted in delays in securing resources from the IMF-EFF program, that led to further loss of confidence, downward pressures on the currency, skyrocketing yields, and the eventual loss of access to international capital markets. Domestic liquidity risks have also been mounting as the Government has become increasingly reliant on domestic borrowing. The public sector now accounts for 70 percent of bank lending and continued banking sector financing of sovereign debt is predicated on liquidity injections through State Bank of Pakistan (SBP) Open Market Operations (OMOs). Despite continued hikes in the policy rate, inflation continues to accelerate in part due to the liquidity injections and the pass through from the falling exchange rate. Due to the scarcity of international reserves, imports are being restrained, choking industrial production and overall economic activity. 3. This Program aims to boost balanced and resilient growth. This Program helps to address some of the country’s long-standing economic challenges of low growth rates of potential output and boom-bust cycles by focusing on interventions supporting investment (in physical and human capital) and productivity-led growth. Sectoral (or multi-sectoral) and Institutional Context of the Program 1 World Bank. 2019. “Pakistan: Leaning Poverty Brief.� EduAnalytics. https://thedocs.worldbank.org/en/doc/214101571223451727- 0090022019/original/SASSACPKPAKLPBRIEF.pdf 2 World Bank Group. 2022. From Swimming in Sand to High and Sustainable Growth: A Roadmap to Reduce Distortions in the Allocation of Resources and Talent in the Pakistani Economy. Pakistan Economic Memorandum, World Bank, Washington, DC. p.1. https://openknowledge.worldbank.org/handle/10986/38133. Feb 22, 2023 Page 3 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) 4. Over the past two decades, Pakistan’s real GDP per capita growth has been slow, at an average of 1.7 per year – less than half the regional average. Policies supporting a growth model driven by public and private consumption, rather than by investment and exports is at the core of the growth challenge. Periods of relatively fast growth, underpinned by growth in consumption, have been interrupted by the accumulation of external vulnerabilities. Demand-driven growth spurts lead to fast increases in imports, while exports remain stagnant, resulting in balance of payments crises in the absence of significant external financing, leading to abrupt halts to growth. 5. The pattern of consumption-based growth has affected the expansion of Pakistan’s productive capacity, limiting growth potential. Consumption-based growth (with resulting low domestic saving rates) is the flipside of Pakistan’s low investment rates, in turn the result of policy-induced or unaddressed distortions. The limited saving the economy can generate are largely absorbed through government borrowing which crowds out private sector credit and limits domestic investment. Trends over the past decade reveal challenges in the external and productive sector. The contribution of exports and private investment to overall growth in aggregate demand (AD) fell from 24.1 percent during 1999/00–2009/10, to 11.9 percent during 2009/10–2019/20. During 1999/00– 2009/10, exports and private investment contributed an average of 1.2 percentage points to AD growth. This contribution halved to 0.6 percentage points during 2009/10–2019/20. The economy became less export- and investment-oriented. Investment and exports are critical for future growth as they contribute to productivity growth and lead to job creation. 6. Productivity growth has stagnated, affecting firms’ growth and job creation prospects. Between 1991 and 2021, labor productivity in Pakistan increased by 40 percent, compared to 328 percent in Vietnam or 170 percent in Bangladesh. The productivity stagnation is both related to allocative and to within-firm challenges. Close to 40 percent of workers continue to be locked in in the agriculture sector, which contributes only about 20 percent of total value added. This is a typical feature of developing economies, where workers rely on the agriculture sector as a fallback option when better jobs in manufacturing and services are scarce. Firm level analysis for the 2012- 2020 period also reveals that within-firm productivity declined across sectors and types of firms.3 As firms’ productivity stagnates, their ability to grow and create jobs is limited. A formal firm in Pakistan that has been in operation for 10 to 15 years employs roughly the same number of workers as a firm that has been in operation for more than 40 years. Similarly, an average Pakistani exporter ships less than half the value annually than the average Bangladeshi exporter. 7. Distortions - either introduced or unaddressed by policies – have stunted productivity and firms’ growth and contributed to the accumulation of external vulnerabilities. Distortions have led to the misallocation of resources and talent, away from dynamic tradable sectors, thus reducing allocative efficiency (and contributing to mounting trade deficits) and have reduced incentives for firms to innovate and upgrade the quality of its products and processes, thus reducing within-firm productivity. Exposure to global markets through trade and investment is a powerful platform for productivity convergence of low- and middle- income countries. Yet, policies in Pakistan introduce distortions that reduce that exposure, therefore limiting the extent and speed of productivity convergence. Evidence suggests that, first, import tariff policies have encouraged firms to remain inward oriented, while discouraged their productivity growth. Second, export incentives have encouraged export concentration rather than diversification. Third, investment policies have limited firms’ investment (and therefore their growth) and discouraged FDI attraction. Fourth, gender norms have led to the underutilization of human capital 3 For details, see World Bank (2022) ‘From Swimming in Sand to High and Sustainable Growth’, Chapter 2. Feb 22, 2023 Page 4 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) accumulated by females in Pakistan, as female labor force participation is among the lowest in the world, at 23 percent, with even low rates at high levels of educational attainment. 8. Pakistan’s import duties are among the highest in the world, discouraging export orientation and productivity growth. High import duties discourage firms from exporting. Domestic firms have a natural advantage in their home market because of low transport costs and deep knowledge about consumer preferences relative to foreign suppliers. Further, the GoP actively encourages selling domestically at the expense of exports by shielding local firms from international competition using tariffs. This is despite the fact the global market is 318 times larger than the Pakistani market. High import duties at an average of 20 percent in Pakistan, imply high rates of effective protection of domestic industries above 100 percent for most manufacturing sectors, making profits of selling domestically artificially large by deterring import-competition.4 Import duties intended to incentivize import substitution have substituted exports instead.5 Firms in low-protection sectors in Pakistan show substantially higher export orientation than comparable firms in high-protection sectors. For these firms, exporting is only a residual option, after they have tapped into the captive domestic market. In addition, import duties on intermediates are also relatively higher than in comparator countries. Evidence shows that 85 percent of the firms’ productivity decline over the past decade can be accounted for by increases in duties on intermediates. The effects are estimated to be particularly large for small exporters.6 On a positive note, the National Tariff Policy -approved in FY20 and supported by RISE I- has improved the institutional set up for tariff setting and has resulted in a mild reversal of protectionism. 9. The few Pakistani firms that choose to export despite high effective protection, are discouraged to diversify the export bundle. The existing export incentive infrastructure deters diversification. The Drawback of Local Taxes and Levies (DLTL) – effectively an export incentive – targets a subset of products for rebates of between 1 and 4 percent of exports free-on-board (FOB). Eligibility is biased against diversification and quality upgrading, and because rebate rates are calculated on levels of exports, rather than growth, they tend to reward larger firms. An impact evaluation of the scheme shows limited impact, substantial reallocation away from new products into traditional ones, to secure high rebate rates, and limited uptake, with most of beneficiaries being large firms. While the scheme has the potential to incentivize exports, its current design and implementation requires updating. In addition, compliance with standards and certification processes, increasingly important to fetch higher export prices in demanding markets, is costly for small firms due to the fragmentation of the Quality Infrastructure ecosystem and the lack of systematic information on requirements and procedures. 10. While credit is crucial for export-led growth, large public-funded export finance schemes have had only small effects in boosting exports. The State Bank of Pakistan (SBP) currently runs two large export finance schemes: The Export Finance Scheme (EFS) and the Long-Term Finance Facility (LTFF). Outstanding loans under the schemes account for almost 20 percent of exports. These schemes, which are currently in the process of being transferred to the Export Import (EXIM) Bank of Pakistan, are highly concentrated in a subset of large firms, have had very small effects in boosting exports, and are costly. A cost-benefit analysis conducted for these schemes reveals that each additional dollar of extra exports that is brought in because of the EFS and LTFF costs the SBP 83 cents and 8 cents, respectively.7 4 See Varela, G. et al (2020) “Import Duties and Performance: Some Stylized Facts for Pakistan�. 5 Systematic evidence of the link between output tariffs and untapped export potential for Pakistan is presented in “Pakistan’s Export Potential: Some Estimates and Implications�, Policy Note, World Bank, Islamabad; and in World Bank (2022) “From Swimming in Sand to High and Sustainable Growth�. 6 See Lovo, S & G. Varela (2022) “Internationally Linked Firms and Productivity in Pakistan: A Look at the Top End of the Distribution �. The Journal of Development Studies, vol 58(10), pp. 2110-2131. 7 See Defever, Riano, and Varela (2020) “Evaluating the impact of export finance support on firm -level export performance: Evidence from Pakistan�, Feb 22, 2023 Page 5 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) 11. A complex investment climate along with policy uncertainty increases the costs of doing business and limits the potential of attracting FDI. Slow automation in government-to-business (G-2-B) interactions is both a cause and a consequence of institutional weaknesses. Pakistan needs to speed up the process of automating G-2-B interactions, improve federal-provincial-local coordination, eliminate unnecessary procedural steps, move away from paper-based licensing and registration compliance, and introduce digital payments. The incipient initiative (i.e., Pakistan Regulatory Modernization Initiative) on automating the Government’s regulatory interface with the private sector will increase licensing and registration efficiency through a centralized database and data-sharing among entities, eliminating arbitrariness, opacity, and discretion to speed otherwise lengthy processes. This will increase investors’ confidence, reduce investment costs, and incentivize export-oriented undertakings that rely on just-in-time processes. In addition, policy uncertainty with respect to investment protection limits the ability of Pakistan attracting the estimated US$2.8 billion annually of untapped FDI inflows. 12. The misallocation of female talent in Pakistan is a further disabler of growth, estimated to drag down GDP by 5 to 23 percent.8 While females in Pakistan have made strides in terms of educational attainment, gender norms often mean that this accumulated human capital is underused because females do not participate to their potential in the labor force. But those who are willing to participate face a coordination problem. On the demand side, in the case of manufacturing, the share of females in employment is only about 4 percent. It therefore may not pay off for firms to make the necessary investments to accommodate female workers (e.g., dedicated spaces in plants, restrooms, transport, etc.) if female employment does not reach a certain level. From the supply side, females might not be willing to work in a factory without dedicated spaces for females (or where there is not a critical mass of women working), and then decide to not work at all. The distortion here is related to a market or coordination failure that is in turn associated with a gender norm, and unaddressed by policies. 13. Interventions that use public funds to support private sector development are not fully costed or evaluated. The GoP invests in various ways aiming at supporting sectors to develop, firms to grow or export. Yet, there is limited monitoring of these investments and there are rarely rigorous impact evaluations to guide evidence-based decisions on their scaling or phasing out. 14. The relatively large real depreciation of the Pakistani Rupee (PKR) observed since the beginning of FY23 can facilitate an export surge if complementary interventions are implemented. The real depreciation of the PKR can help reallocate resources into more dynamic, export oriented tradable sectors, as it increases the relative profitability of tradables to non-tradables. The depreciation also opens an opportunity for import duty reforms as it provides temporary, non-distortionary protection from imports. The size and the speed of the reallocation of resources towards dynamic, export oriented tradable sectors will depend on three factors: the costs firms face in building new trade relationships (connecting to global markets), the availability a pool of skilled workers, and the strength of firms’ capabilities to implement an export-oriented business model and upgrade productivity.9 Relationship to CAS/CPF Policy Research World Bank Working Paper Series, Working Paper No. 9362. 8 See Section 3 of World Bank (2022) “From Swimming in Sand to High and Sustainable Growth�. 9 Brun et al (2022) show that in Pakistan, lifting information barriers can increase the export response to real exchange rate depreciations. Jensen and Lanz (2014) show the importance of transferable skills for export competitiveness. Iacovone et al (2022) show evidence of group-based interventions on consulting services for firms’ capabilities upgrading, a pathway to scaling up management improvements. Feb 22, 2023 Page 6 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) 15. The proposed P-GROW Program is consistent with the World Bank Group’s (WBG) Country Partnership Strategy (CPS) FY15–19 for the Islamic Republic of Pakistan (Report No. 84645-PK), discussed by the Board of Executive Directors on May 1, 2014. The CPS was extended to FY20 under the corresponding May 2017 Performance and Learning Review (Report No. 113574). The preparation of the new CPF was deferred in FY21 due to the COVID-19 crisis and paused due to the recent unprecedented and catastrophic monsoon floods. A new CPF is expected to be delivered for the consideration of the Board of Executive Directors in the second half of FY24. The focus areas and objectives of the CPS remain relevant and are reflected in the ongoing engagement in the country. The Program is also consistent with the World Bank Group’s Green, Resilient, and Inclusive Development (GRID) approach.10 16. The proposed Program will directly contribute to two CPS results areas. These areas include Results Area 2: Private sector development, in particular outcome 2.1: improved business environment and outcome 2.4: Improved trade tariff, and Results Area 3: Inclusion. The Program is also aligned with the CPS’ cross-cutting theme of climate change. 17. The proposed Program also contributes to the implementation of the WBG’s Global Crisis Response Framework (GCRF).11 Activities and interventions under the Program contribute directly to pillar 2 (Protecting People and Preserving Jobs), pillar 3 (Strengthening Resilience) and pillar 4 (Strengthening Policies, Institutions and Investments for Rebuilding Better). Two proposed interventions (i.e. wage subsidies to promote women employment and upskilling of labor in qualified firms) will directly contribute to supporting gender equality and promoting labor market programs under pillar 2. The activities, especially in the medium to long term, will also contribute macro-fiscal sustainability under pillar 3. Lastly, the activities will also support green and sustainable growth, in addition to institutional strengthening and capability building under pillar 4. Rationale for Bank Engagement and Choice of Financing Instrument 18. The World Bank Group’s value added is both financial and technical. On the financial side, budgetary constraints have been an impediment to investing in the soft infrastructure required to tilt relative profits in favor of dynamic tradable sectors, to boost sustainable growth. The technical and implementation support provided through this Program will draw on the Bank’s long-term engagement on the trade, growth, and productivity, and on reform roadmap outlined in the recently released Country Economic Memorandum. 19. The Program is responding to and has potential to address the underlying causes of the current and recurrent macroeconomic challenges, linked to microeconomic policies and incentives frameworks. Longstanding structural weaknesses have been exacerbated by the recent floods, undermining the country’s ability to recover. This risk is compounded by worsening external conditions that include high global commodity prices, for which the country is a net importer, and increasing interest rates. Supporting measures to increase private investment, export competitiveness and growth will be key, in parallel to the immediate measures to address the current ‘poly-crises’, if Pakistan is to shift from patterns of booms and busts towards a virtuous cycle of resilient growth in the medium term. C. Program Development Objective(s) (PDO) and PDO Level Results Indicators 10World Bank Group. 2021. Green, Resilient, and Inclusive Development. https://openknowledge.worldbank.org/handle/10986/36322 11World Bank Group. 2022. Navigating Multiple Crises, Staying the Course on Long-term Development: The World Bank Group’s Response to the Crises Affecting Developing Countries. https://documents.worldbank.org/en/publication/documents- reports/documentdetail/099640108012229672/idu09002cbf10966704fa00958a0596092f2542c Feb 22, 2023 Page 7 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) Program Development Objective(s) To support the growth of an open and resilient economy. PDO Level Results Indicators 1. Unweighted average of the sum of customs, regulatory and additional customs duties decreased from 20 to 16 percent by the end of the program. 2. Number of firms satisfactorily supported by the National Compliance Center 3. Number exporters increases by 10 percent by the end of the program D. Program Description PforR Program Boundary 20. The Government of Pakistan has embarked on a program to boost private sector-led growth. The program aims at accelerating innovation and increasing exports across existing and new sectors. The program combines firm- level, sector specific, and cross-cutting interventions to provide a coherent incentive regime for export-led growth. The program is embedded in the 2020-25 Strategic Trade Policy Framework (STPF) that aims to “transform Pakistan from a factor-driven to an efficient-driven economy integrated into the regional and global value chains� and to make Pakistan “a dynamic and efficient domestic market as well as a globally competitive export driven economy�. 21. The program identifies a series of critical enablers across four areas: i. Competitiveness enhancement measures with a focus on a reduction of doing business costs, tariff rationalization, innovation, workforce development, and quality upgrading. ii. Trade related investment measures with a focus on FDI attraction and the formulation of an integrated framework for trade and investment policy. iii. Integration into Global Value Chains through enhanced market access and export diversification across product and markets, increased innovation, and improved branding. iv. Export Ecosystem strengthening measures with a focus on trade facilitation institutional strengthening, and the development of sector specific roadmaps. 22. A key pillar of the Program is the enhancement of exports via a collaborative and cohesive national effort that engages all relevant ministries, departments, government agencies, and private sector stakeholders. Exports are crucial for economic resilience for three reasons. First, they constitute a genuine source of foreign exchange in an economy that has experienced perennial current account deficits. Second, exporting is strongly associated with productivity growth and investment (exporters are more productive in the first place, but their productivity increases by exporting through interactions with more sophisticated clients and through economies of scale. Third, exports in Pakistan are an important platform for employment growth, especially female employment, given the patterns of specialization of the economy.12 12 For details, see World Bank (2022) ‘From Swimming in Sand to High and Sustainable Growth’ Feb 22, 2023 Page 8 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) PforR Program 23. This is a hybrid PforR operation. It consists of three results areas under the Results Component (US$230 million) and a Technical Assistance Component (US$20 million) to support investment in systems, capacity building, outreach and communications and consulting and non-consulting services required for successful implementation. Component 1: Program for Results (US$230 million) 24. The proposed Program for Results component will support a subset of the GoP’s program to boost private sector-, export-led growth as captured across the STPF, NPSES, and SR. Selected activities will leverage World Bank's experience in previous projects and expertise in existing engagements and support intervention areas which that have been identified as key for Pakistan’s growth success in the World Bank’s analytic and diagnostic work program. To this end, the Program is structured around three results areas (RAs). i. Improving the enabling environment under which firms operates, so that the relative profitability of investing and exporting increases. ii. Supporting firms and workers to take advantage of an improved enabling environment, by contributing to narrowing the gender gap in employment. iii. Improving the governance of public support to firms through mandatory monitoring and evaluation and impact evaluation for large government-supported programs, and supporting the creation of good quality statistics. Component 2: Technical Assistance (US$20 million) 25. The Program includes a technical assistance component. The purpose of the technical assistance component is to support implementing agencies that require input-based specialized expertise and capacity building. E. Initial Environmental and Social Screening IPF Component 26. The overall E&S rating of the IPF component is assessed as low. The environmental rating of IPF component is assessed as low due to low quantum of ICTs procurement. Activities to be financed under IPF component will lead to increased procurement and use of ICTs by the implementing partners of the program. This will generate e- waste at the beginning of the program due to replacement of obsolete ICTs and at the end of life of ICTs procured under the program. Recycling and disposal of ICTs will result in environmental, health and safety impacts. Such risks will be managed by adopting and endorsing e-waste management SOPs prepared for other World Bank financed programs. 27. The social rating of the IPF component is assessed as low. The minor social risks anticipated related to the IPF component are occupational health and safety risks to workers who will help carry out the TA activities such as SEA/SH at the workplace and exclusion and marginalization risks to workers with low IT literacy and skills. These risks will be mitigated through the adoption of worker codes of conduct (CoCs), additional training for workers with low IT skills, and ensuring access to a labor GRM for all workers involved with TA activities. Additional measures related to labor management, GRMs and CoCs will be included in the ESCP. 28. The E&S management capacity of Ministry of Commerce and implementation partners will be further assessed during the preparation of the Program. As they have not implemented a Program with the Bank before, their capacity can be considered low. During the project preparation, there capacity would be further assessed, and capacity building activities will be planned for implementing agencies during project implementation for managing Feb 22, 2023 Page 9 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) and implementing environmental and social risks and impacts. Such activities are covered under TA (IPF component). The program will need to hire environmental and social specialists for overall project covering both IPF and P4R components and in the interim period appoint a focal point to support project preparation and meet ESF and ESSA recommendations. Accordingly, the program will prepare and adopt e-waste SOPs, Stakeholder Engagement Plan (SEP), Labor Management Plan (LMP), Gender Action Plan (GAP), and Grievance Redressal Mechanism (GRM). Program for Results Component 29. The RAs under the PforR aim at boosting private sector- and export-led growth in Pakistan. An increase in private sector investment and exports can potentially increase environmental and social risks and impacts due to an increase in industrial production in the country. ESSA will be prepared in accordance with the core principles of ESSA and would make recommendations which would form part of program action plan. Based upon the information currently available, environmental risks and impacts are expected to increase industrial pollution at existing and new production sites as well as supply chain networks; change in land uses due to new industrial establishments, expansion of trunk and micro industrial infrastructure, occupational health and safety concerns and public health issues etc. These risks and impacts would be addressed through the recommendations of ESSA. Some positive aspects are also expected from the Program due to greening through the National Tariff Policy through reduction of duties on environmental goods. This would promote sustainable development and help country to address air pollution, promote resource efficient and cleaner production technologies, etc. While environmental policy and legislature is relatively comprehensive, there are compliance issues. The capacity of MoC and partners organization for environmental management of program activities will be assessed during program preparation. 30. The Program is likely to enhance social development. Social risks are likely to be moderate as the impact from a shift in the growth model towards private sector- and export-led growth will provide more livelihood opportunities specially for women. It can, however, also lead to, labor management issues, gender issues-sexual harassment, and social conflicts. The capacity to implement social policies, legislations, and safeguards instruments will be assessed during project preparation and the recommendations for improving systems and managing risks will be addressed through ESSA. The ESSA would also help determine the social risks, implications and required actions in the program action plan on E&S capacity development, management, and compliance. Wage subsidies to increase female labor force participation will on the one hand increase female empowerment but may also increase the probability of incidences of female specific workplace grievances related to workplace amenities for females, Gender Based Violence (GBV) and Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH). 31. The Program will ensure that female amenities are available in the job sites. These include separate washrooms, common areas, children play areas, etc. and should be provided by employers as per the requirements of local legislation and the World Bank guidelines. To mitigate the SHV issues, the program will include organizational system improvement at workplaces in line with local legislation and the World Bank guidelines. The Grievance Redressal Mechanism of the program will provide special focus to address female grievances and referral mechanisms for counseling and support in instances of GBV and SEA/SH will also be provided. The program will also include capacity enhancement through trainings of employers and men to create a conducive co-gender working environment. Feb 22, 2023 Page 10 of 11 The World Bank Pakistan Grows Open, Resilient and Wealthy (P179807) . Legal Operational Policies Triggered? Projects on International Waterways OP 7.50 No Projects in Disputed Areas OP 7.60 No Summary of Screening of Environmental and Social Risks and Impacts of the IPF Component . Feb 22, 2023 Page 11 of 11