The Council for Development and Reconstruction (CDR) Lebanon: Green Agri-Food Transformation for Economic Recovery (GATE) (P180334) Draft ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 29 April 2023 1|Page Lebanon: Green Agri-food Transformation for Economic Recovery (GATE) (P180334) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Council for Development and Reconstruction (CDR) (Recipient) PCUwill implement the “Green Agri-food transformation for economic recovery (GATE) (P180334) Project� (the Project), with the involvement of Green Plan, the Ministry of Agriculture (MoA) Green Plan (GP), the Ministry of Environment (MoE), the Ministry of Economy and Trade (MoET), and Kafalat, as set out in the Loan Agreement. The World Bank has agreed to provide financing for the Project, as set out in the referred agreement. 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 Bank. The ESCP is a part of the Loan 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 Bank. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the Bank. 4. As agreed by the Bank 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 Government of Lebanon through the Council for Development and Reconstruction (CDR), and the Bank agree to update the ESCP to reflect these changes through an exchange of letters signed between the Bank and the CDR Director. The CDR shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Starting from the Effective Date, CDR PCU Prepare and submit to the Bank regular monitoring reports on environmental, social, reporting every quarter throughout the PCU health and safety (ESHS) performance of the Project and sub-projects, including but not Project implementation. Reports to be limited to the implementation of the ESCP, status of preparation and implementation of sent within 30 days after the reporting E&S instruments required under the ESCP, stakeholder engagement activities, and period ends. functioning of the grievance mechanism, including but not limited to grievance logs from workers and communities, overall E&S performance of the project, compliance to ESSs during implementation of project activities, project-related accidents and implementation plans for the project activities in the subsequent quarter. FINANCIAL INTERMEDIARIES REPORTS Participating FIs shall be required to Kafalat SAL (for Sub- FIs to prepare and submit reports on ESHS performance of subprojects supported under furnish to KAFALAT SAL quarterly Component 1.2) and Component 1 of the Project, including the operation of their respective ESMS, according progress report not later than 10 days participating financial to the format set forth in the POM. after each quarter starting from the intermediaries. Effective Date. These reports shall be provided to the Bank, at the request of the Bank. B INCIDENTS AND ACCIDENTS Notify the Bank of any incident or accident related to the Project which has, or is likely to Report any incident or accident to the CDR, have, a significant adverse effect on the environment, the affected communities, the Bank within 48 hours after becoming PCU Environmental & Social public or workers including but not limited to: aware of the occurrence of the incident Specialist. • Occupational Health and Safety Issues. or accident. Kafalat SAL and participating • Major contamination to the environment. FIs • Major impacts on ecosystem services. •Outbreak of life-threatening communicable disease, COVID-19 pandemic infection. • GBV, exploitation, discrimination, unresolved grievances. • Civil unrest, criminal and political attacks at worksites. • Forced labor and/or child labor by project contractor. • Project security personnel conflict with local communities . A report would be provided within 10 Provide sufficient detail regarding the scope, severity, and possible causes of the incident days of the initial notification to the or accident, indicating immediate measures taken or that are planned to be taken to Bank, as requested. address it, and any information provided by any contractor and/or supervising firm, as appropriate. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Subsequently, as per the Bank request, in addition to the initial notification, prepare a File a closure report within 30 days or report on the incident/accident and propose specific time-bound actions and measures to agreed time frame, as per the Bank’s prevent its recurrence. request. Request Participating FIs and stakeholders to report any incident or accident that occur in Notification/reporting requirements subprojects financed under the Project. shall be in place throughout the Project implementation. C CONTRACTORS’ MONTHLY REPORTS Prepared monthly by contractors CDR Require contractors and supervising firms to provide monthly monitoring reports on ESHS submitted to the Bank upon request. PCU Environmental & Social performance in accordance with the metrics specified in the respective bidding Specialist documents and contracts to the PCU, who will in turn submit them to the Bank upon request. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE The organizational structure will be CDR Establish and maintain, throughout the Project implementation, finalized before commencement of PCU Coordinator GP E&S an organizational structure, a Project Management Unit (PCU) including an environmental project activities. This structure shall be Focal Point, Kafalat E&S and social risks and impacts management function with qualified staff and resources to maintained throughout Project specialist support management of environmental, social, health and safety (ESHS) risks and impacts implementation of the Project with mandate, resources, and terms of reference satisfactory to the Bank. The PCU needs to hire an Environmental and Social Specialist, whom will be responsible The CDR PCU Environmental and Social for the day-to-day implementation of the outcomes of the E&S studies and instruments. (E&S) specialist and Grievance The E&S Specialist will assume overall responsibility for coordinating the management of Mechanism (GM) officer shall be hired the environmental and social aspects of the project interventions at the respective sites. before the start of project activities and In addition, PCU needs to hire a Grievance Mechanism (GM) officer who will be shall be maintained throughout project responsible for ensuring adequate functioning of the GM, and proper documentation and implementation. follow up and resolution of grievances across all implementing agencies including with Kafalat and Green Plan. The GM officer will also ensure that all staff handling grievances The Kafalat E&S specialist and Green across the implementing agencies have relevant capacity and awareness raising on the Plan E&S focal point shall be hired before principles of the grievance mechanism including referrals, and incident reporting. the start of project activities and shall be maintained throughout project Green Plan (GP) needs assign an Environmental and Social Focal Point, whom will be implementation responsible for the day-to-day implementation of the E&S studies and instruments related to GP managed activities. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY . 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS 1. Adopt the ESMF which will be CDR 1. Update, disclose, consult upon, adopt, and implement the Environmental and Social cleared and disclosed by appraisal PCU Environmental & Social Framework (ESMF), consistent with the requirements of the relevant ESSs and in a manner stage. The ESMF will be Specialist, CDR PCU GM acceptable to the Bank. implemented throughout project Officer. implementation GP E&S Focal Point Prepare, disclose, adopt and implement the following site-specific instruments consistent with the relevant ESSs: . An Environmental and Social Management Plan (ESMP) or Environmental and Social 2. Site specific ESMPs/ESIAs prepared Impact Assessment (ESIAs) for activities under component 2 of the project such as: and cleared before commencement rehabilitation and modernization of public irrigation infrastructure including small of the related activities and community-/farmer-level irrigation systems and larger agency-managed public irrigation implemented throughout project infrastructure, rural feeder roads rehabilitation and construction, optimizing the implementation period. operation of existing wastewater treatment plants (including sludge management), sewage and solid waste management systems, and construction and rehabilitation of hill lakes. 1.3 MANAGEMENT OF CONTRACTORS Prior to the Tendering /Contracting CDR Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S Phase and supervision during Project PCU and implementing instruments, the Labor Management Procedures, and code of conduct, into the ESHS implementation partners. specifications of the procurement documents and contracts with contractors and supervising firms. Thereafter ensure that the contractors and supervising firms comply and cause subcontractors to comply with the ESHS specifications of their respective contracts. 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. CDR Ensure that the consultancies, studies (including feasibility studies, if applicable), capacity PCU building, training, and any other technical assistance activities under the Project are carried out in accordance with terms of reference acceptable to the Bank, that are consistent with the ESSs. Thereafter the PCU shall ensure that the outputs of such activities comply with the terms of reference. 1.5 CONTINGENT RESPONSE FINANCING a) The adoption of the CERC manual in CDR a) Ensure that the Contingent Emergency Response Component Manual (CERCM) as form and substance acceptable to the PCU E&S Specialist specified in the legal agreement includes a description of the ESHS assessment and Bank is a withdrawal condition under management for the implementation of component 5, in accordance with the ESSs. Section [XX] of Schedule 2 of the loan agreement for the Project. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY b) Adopt any environmental and social (E&S) instruments which may be required for b) Adopt any required E&S instrument activities under component 5 of the Project, in accordance with the CERC Manual and, if and include it as part of the respective applicable, CERC-ESMF or CERC-ESMF Addendum and the ESSs, and thereafter implement bidding process, if applicable, and in any the measures and actions required under said E&S instruments, within the timeframes case, before the carrying out of the specified in said E&S instruments. relevant Project activities for which the E&S instrument is required. Implement the E&S instruments in accordance with their terms, throughout Project implementation. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Implement the Labor Management Procedures (LMP) for the Project that have been Implement and update the LMP which CDR developed for the Project as a standalone document, including, inter alia, provisions on has been cleared and disclosed prior to PCU Environment & Social working conditions, management of workers relationships, occupational health and safety appraisal throughout Project Specialist, CDR PCU GM (including personal protective equipment, and emergency preparedness and response), implementation Officer, GP E&S Focal Point, code of conduct (including relating to Sexual Exploitation and Abuse/SEA and Sexual Kafalat PCU, participating Harassment/SH), forced labor, child labor, grievance arrangements for Project workers, financial intermediaries. and applicable requirements for contractors, subcontractors, and supervising firms. The Kafalat shall require Participating FIs to prepare and implement an LMP or adopt the LMP of the project. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish, maintain, and operate a Grievance Mechanism (GM) for Project workers, and The GM, as part of the LMP, shall be CDR Contractor/Supervising firms as described in the LMP and consistent with ESS2. The GM operational and shall be set as a PCU Environment & Social shall have the following characteristics: disbursement condition, and be Specialist, CDR PCU GM ▪ Proportionate to the nature and scale of the project and its risks and impacts. maintained throughout Project Officer, GP E&S Focal Point, ▪ Address concerns promptly, using an understandable and transparent process implementation. Kafalat PCU and participating that provides timely feedback to those concerned in a language that they financial intermediaries. understand, and without any retribution. ▪ Operate in an independent and objective manner and implement the principles of confidentiality and anonymity as warranted (in particular when the grievance concerns sexual exploitation and abuse and sexual harassment). ▪ Roles and responsibilities shall be assigned to competent staff who will receive adequate training. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 3.1 PEST MANAGEMENT PLAN 3. PCU prepares the PMP by appraisal, CDR Prepare and adopt a Pest Management Plan (PMP), as part of the ESMF mentioned under as part of the ESMF, and thereafter PCU Environment & Social action 1.2, to manage procurement and/or application of pesticides consistent with ESS3 will be implemented throughout the Specialist. requirements. project life. The PCU shall ensure as per the ESMF that any high polluting activities are not supported under the project. Contractors that undertake civil works shall be required to prepare and implement an Environmental and Social Management Plan to be eligible for funding. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Before the commencement of CDR As per the ESMF, incorporate requirements on resource conservation and pollution Component 2, ESIAs/ESMPs need to be PCU Environment & Social prevention and management, which will be defined at the sub-project level under the prepared including resource efficiency Specialist. ESIA/ESMP to be prepared under action 1.2 above for component 2 activities. and pollution prevention and GP E&S Focal Point management requirements per the cleared and disclosed ESMF. Those requirements shall be implemented, maintained, and managed throughout Project implementation. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY As part of the ESIA/ESMPs CDR Incorporate measures to manage traffic and road safety risks as required in the PCU PCU Environment & ESMP/ESIAs to be prepared under action 1.2 above. Shall be maintained and managed Social Specialist. throughout Project implementation. GP E&S Focal Point 4.2 COMMUNITY HEALTH AND SAFETY As part of the ESIA/ESMPs CDR Prepare, adopt, and implement measures and actions to assess and manage specific risks PCU and PCU Environment & and impacts to the community arising from Project activities under Action 1.2, including, Shall be maintained and managed Social Specialist. inter alia, the potential for community exposure to communicable diseases and COVID-19 throughout Project implementation GP E&S Focal Point infections, impacts on provisioning ecosystem services, noxious emissions from waste, fire risks, response to emergency situations, and include these measures in the ESIA/ESMP in a manner acceptable to the Bank. 4.3 SEA AND SH RISKS CDR Prepare, adopt, and implement e Sexual Exploitation and Abuse/Sexual Harassment Include the SEA/SH Prevention and PCU Environment & Social (SEA/SH) Prevention and Response Plan (GBV Action Plan) as part of the ESMPs/ESIAs to Response Plans as part of the Specialist, CDR PCU GM be prepared under action 1.2 above, to assess and manage the risks of SEA/SH associated ESIAs/ESMPs to be prepared under Officer with the Project action 1.2 above.. GP E&S Focal Point The SEA/SH Prevention and 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Response Plan to be implemented throughout Project implementation 4.4 Emergency Response Measures CDR Part of the LMP and ESIAs/ESMPs PCU E&S Specialist Develop and implement measures to address emergency events and ensure coordination GP E&S Focal Point with measures under 2.4. Measures will be defined in the ESIAs/ESMPs and disseminated as part of the SEP. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY 5.1 RESETTLEMENT POLICY FRAMEWORK CDR RF will be prepared cleared and Prepare, clear, adopt, and implement a Resettlement Framework (RF) as applicable and PCU Environment & Social disclosed by appraisal. The RF will be in accordance with ESS5. Specialist. implemented throughout project implementation . 5.2 RESETTLEMENT PLANS As required, a RP will be prepared and CDR As needed, prepare, adopt and implement the respective RP following the Resettlement submitted for the Bank approval; once PCU Environment & Social Framework before carrying out the associated activities, in a manner acceptable to the approved, the RAP will be implemented Specialist. Bank prior to commencing Project activities and will be implemented throughout project implementation. 5.3 GRIEVANCE MECHANISM Prior to commencing Project activities CDR The grievance mechanism (GM) shall address resettlement and land use restrictions (if and during the implementation of the PCU Environment & Social applicable) related complaints, which is described in the SEP. Project. Specialist and CDR PCU GM Officer. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS Management measures for the CDR Activities that would have risks natural habitats, ecosystem services and Greenfields will protection of natural habitats are PCU Environment & Social be managed according to the requirements of the ESMF and site specific instruments as included in the cleared and disclosed Specialist. indicated under action 1.2 ESMF. Those requirements shall be GP E&S Focal Point implemented, maintained, and managed throughout Project implementation. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not Applicable 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 8: CULTURAL HERITAGE Not Applicable ESS 9: FINANCIAL INTERMEDIARIES 9.1 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM (ESMS) The ESMS shall be updated, as needed Implement, and update as appropriate, the ESMS to meet the requirements of ESF as per by appraisal, and implemented CDR ESS9. This shall include ensuring that there is adequate capacity to maintain it through the throughout project implementation PCU E&S Specialist, Kafalat, appointment of the E&S specialists. where required. PCU Environment & Social Specialist, and participating KAFALAT SAL and each of the FIs participating from the project shall assign both a senior financial intermediaries. management representative to have overall accountability for environmental and social Participating FIs shall establish, adopt performance and a staff member or consultant as E&S Focal Point to manage the day-to- and implement their respective ESMS day implementation of ESMS. The Terms of Reference of the E&S Focal Point, including before the selection of any subproject to required technical skills and experience shall be included in the ESMS and Project be supported under Part 1 of the Project. Operations Manual (POM). KAFALAT SAL shall ensure that the project’s exclusion list, following action 1.4, is adhered to in accordance with the Grant Agreement. During the implementation stage of this project, all candidate MFIs and MSEs receiving grants shall be screened against the project’s exclusion list of the ESMS, categorized and assessed for their E&S risks and impacts prior to receiving any financing under the project. 9.2 EXCLUSIONS During the ESMS updating process Exclude the following types of activities as ineligible for financing under the Project: conducted under action 9.1. above and Kafalat and participating • Activities that may cause long term, permanent and/or irreversible adverse impacts (e.g. during implementation. financial intermediaries. loss of major natural habitat). • Activities that may have significant adverse social impacts and may give rise to significant social conflict. • Activities that may affect lands or vulnerable minorities. • Activities, including new constructions or expansions that may involve, physical and economic displacement or adverse impacts on cultural heritage. • All the other excluded activities set out in the ESMS of the Project. 9.3 FI ORGANIZATIONAL CAPACITY By Effective Date and Maintained Kafalat, PCU Environment & Establish an organizational capacity and competency for implementing the ESMS with throughout Project implementation. Social Specialist and clearly defined roles and responsibilities as per the requirements of ESS9. participating financial intermediaries. 9|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Present an organizational structure to the Bank that identify the specific positions and resources for E&S management. Participating MFIs shall also establish and maintain the organizational capacity and competence to implement ESMS with functions and responsibilities in accordance with ESS9 and in a manner acceptable to the Association. 9.4 SENIOR MANAGEMENT REPRESENTATIVE By Effective Date the senior Kafalat, PMU Environment & Designate a senior management representative to have overall accountability for management representative needs to be Social Specialist and environmental and social performance of subprojects that receive support from the designated. participating financial Project. intermediaries. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION The SEP will be disclosed prior to project CDR Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent appraisal, and will be updated as PCU Environment & Social with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, needed, throughout project Specialist and CDR PCU GM relevant, understandable and accessible information, and consult with them in a culturally implementation. Officer. appropriate manner, which is free of manipulation, interference, coercion, discrimination The SEP will be implemented throughout and intimidation. The PCU shall ensure that the SEP is amended and updated as required the Project. during the Project implementation following inclusive stakeholder consultations. 10.2 PROJECT GRIEVANCE MECHANISM A GM shall be established and CDR Publicize, maintain, and operate an accessible grievance mechanism, to receive and operationalized and shall be set as a PCU Environment & Social facilitate resolution of concerns and grievances in relation to the Project, promptly and disbursement condition and shall be Specialist and CDR PCU GM effectively, in a transparent manner that is culturally appropriate and readily accessible to maintained throughout the Project Officer. all Project-affected parties, at no cost and without retribution, including concerns and implementation period as described in grievances filed anonymously, in a manner consistent with ESS10. the SEP. Grievance Mechanisms shall also be established within each of the Participating FIs to handle complaints and grievances relating to the project, in accordance with the requirements of ESS10 and in a manner acceptable to the Bank. The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 Training and information dissemination to the public and community groups as well as To be implemented during the first year CDR PCU E&S specialist and local authorities, and others as identified in the SEP on the following as relevant to them: of project implementation and as CDR PCU GM Officer • Stakeholder mapping and engagement needed thereafter throughout the course of the project life-cycle. 10 | P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Lebanon: Green Agri-food transformation for economic recovery (GATE) Project Version 1 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY • specific aspects of environmental and social assessment including GBV SEA/SH risks, impacts and mitigation measures that require feedback from the public and local authorities and for their own awareness so that community health and safety can be improved • Emergency preparedness and response • Grievance redress mechanism • Training on occupational health and safety including on emergency prevention and preparedness and response arrangements to emergency situations. Emergency preparedness and response and OHS measures related to COVID-19 as per the national health requirements • Financial Intermediaries ESMS preparation, implementation, and monitoring. CS2 Training shall be conducted for project workers and contractors, while maintaining Prior to commencing works and CDR PCU E&S specialist and training records on the following: throughout project implementation. CDR PCU GM Officer • Occupational health and safety including on emergency prevention and preparedness and response arrangements to emergency situations. • Training on implementation of environmental and social due diligence documents (e.g., OHS, environmental and social assessments, community health and safety, stakeholder engagement, grievance, codes of conduct, etc.) to all staff working with contractors and sub-contractors that are responsible for project’s environment and social issues • ESIA/ESMP implementation • LMP • GBV AND SEA/SH • Grievance mechanism 11 | P a g e