ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) Common Market for Eastern and Southern Africa (COMESA) Inclusive Digitalization in Eastern & Southern Africa - Multi-Phase Programmatic Approach (MPA) (P502532) DRAFT ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) April 2024 1|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Common Market for Eastern and Southern Africa (COMESA) (the Recipient) will implement the Inclusive Digitalization in Eastern & Southern Africa Multi-Phase Programmatic Approach (P502532) (the Project), as set out in the Financing Agreement. The International Development Association (the Association) has agreed to provide financing for the Project, as set out in the referred agreement. 2. COMESA shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) of the World Bank Environmental and Social Framework (ESF) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Association. The ESCP is a part of the Financing 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 ESSs, 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 and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient through the COMESA Secretary General. The Recipient shall promptly disclose the updated ESCP. 2|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit quarterly reports to the COMESA Association throughout Project Prepare and submit to the Association regular monitoring reports on the environmental, implementation, commencing 90 days social, health and safety (ESHS) performance of the Project, including but not limited to after the Effective Date. Submit each the implementation of the ESCP, status of preparation and implementation of E&S report to the Association no later than instruments required under the ESCP, stakeholder engagement activities, and 30 days after the end of each reporting functioning of the grievance mechanism(s) including those related to Sexual Exploitation period. and Abuse and Sexual Harassment (SEA/SH). For incidents related to SEA/SH, the report should include only non-identifiable information such as the survivor's age, gender, type of incident, whether the alleged perpetrator is related to the project according to the survivor's witness, and the care services the survivor accessed, if any. B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 COMESA hours after learning of the incident or Promptly notify the Association of any incident or accident related to the Project which accident and no later than 24 hours has, or is likely to have, a significant adverse effect on the environment, the affected after any severe incident/fatal accident, communities, the public or workers, including, inter alia, cases of SEA/SH, and accidents including SEA/SH incidents. that result in death, serious or multiple injury, alleged violations of labor laws (forced and child labor) and working conditions, cases of gender-based discrimination such as Provide subsequent report within a exclusion of vulnerable people (women, youth, people with disabilities, minority and timeframe acceptable to the disadvantaged groups), etc. Association. Provide sufficient detail regarding the scope, severity, and possible causes of the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and/or supervising firm, as appropriate. For SEA/SH cases, the incident report shall respect ethical principles regarding the management of GBV-related data, in particular, the confidentiality and security of the parties involved; therefore, no identifiable information shall be shared. 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 CONSULTING FIRMS MONTHLY REPORTS Submit the monthly reports to the COMESA Association upon request and as annexes to the reports to be submitted under action A above. 3|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Require Consultants to provide monthly monitoring reports on TA ESHS performance in accordance with the metrics specified in the respective ToRs and Consulting contracts and submit such reports to the Association. These reports shall provide details on the consultants’ oversight on environmental, social, health and safety (ESHS) performance in accordance with this ESCP and the Project’s E&S instruments, including the SEP, as well as highlighting gender aspects where these are part of the consultant’s TA assignment and contract . These reports shall be generated by the project consultants and submitted through the PCU E&S Management Specialists for onward reporting to the Association. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE a) Establish and maintain the Project’s regional Program Coordination Unit (PCU) at a) Maintain PCU throughout Project COMESA the COMESA Secretariat. implementation. b) To support the management of ESHS risks and impacts of the Project, the PCU shall b) Recruit qualified environmental, recruit and maintain an environmental expert with OHS expertise, a social expert, social, and stakeholder and a stakeholder engagement/communication expert and train and sensitize them engagement/communication on the World Bank’s ESF/ESSs requirements to enable them to review consultancy experts prior to the Project ToRs and reports to ensure they are in line with the ESF/ESSs. The ESHS Effective Date and thereafter management staff should have qualifications and experience acceptable to the maintain these positions Association, i.e., at least 7 years’ experience by each expert. throughout Project implementation. c) Mobilize additional staff or consultants including interns as needed on short-term and long-term engagements in accordance with capacity building and institutional c) Throughout Project assessment needs; implementation d) Ensure the terms of reference for Technical Assistance (TA) and other activities d) Throughout Project carried out by the PCU or consultants engaged by the PCU for IDEA activities are implementation acceptable to the Association, consistent with the ESSs, World Bank EHSG (Environmental Health and Safety Guidelines), and that the consultants (to be hired as needed) possesses EHS expertise. Thereafter ensure that the outputs of the TA activities comply with the terms of reference. 4|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS a) Adopt the SEP by the Project COMESA Effective Date and thereafter a) Develop, adopt, and implement the SEP in a form and substance acceptable to the implement it throughout Project Association. implementation. b) Prepare a Project Operations Manual (POM) that will cover ESS2 OHS, SEA/SH and b) Prepare and adopt a POM to be other ESS requirements. reviewed and cleared by the c) Ensure all TA supported activities are consistent with the ESF, and that those Association prior to the Project activities resulting in preparation of E&S instruments establish a process and timing Effective Date, and thereafter for preparing relevant E&S instruments during Project implementation, specifying implement POM guidelines and the requirements for consultation and disclosure of these instruments, and setting review and update them as needed forth the institutional arrangements. throughout Project implementation. d) ToRs for TA activities to be prepared by the PCU or consultants shall include provisions for identifying potential E&S risks of downstream subprojects, in line with c) Condition for TOR approval applicable ESF provisions and relevant requirements of the WB EHS Guidelines d) Condition for TOR approval 1.3 MANAGEMENT OF CONSULTANTS As part of the preparation of COMESA procurement documents and respective Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S consultancy contracts. instruments, labor and other relevant provisions in the POM, and SEA/SH code of conduct, into the ESHS specifications of the consultancy procurement ToRs and contracts with consultants and other service providers. Thereafter ensure that consultants and service providers comply with the ESHS specifications of their respective contracts, including SEA/SH aspects. 1.4 TECHNICAL ASSISTANCE a) Throughout Project COMESA implementation. a) Ensure that the consultancies, studies (including feasibility studies, if applicable), capacity building, training, and any other Type 2 and 3 technical assistance activities b) Prior to disbursement for TA under the Project are carried out in accordance with terms of reference acceptable activities to the Association, that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. 5|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY b) Ensure that the planning process for Type 1 and Type 2 TAs includes adequate assessment of environmental and social risks and impacts, and that the advice provided through the TA for addressing those risks and impacts is consistent with the ESF ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Adopt the labor management COMESA procedures contained in the Project Adopt and implement the Labor Management Procedures (LMP) developed for the POM prior to Project Effective Date and ASCENT Project’s COMESA operations, key relevant provisions of which shall be included thereafter implement throughout the IDEA COMESA Project POM including, inter alia, provisions on working conditions, Project implementation. management of workers relationships, occupational health and safety plans (including personal protective equipment, and emergency preparedness and response if applicable), code of conduct (including relating to SEA/SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for consultant firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS a) Adopt and operate key provisions COMESA a) Adopt, adhere to and operate for the IDEA COMESA Project the Worker Grievance of the worker grievance mechanism Mechanism established under the ASCENT COMESA LMP, key provisions of which contained in the Project POM prior shall be included in the IDEA COMESA Project POM and consistent with ESS2. The engaging Project workers and Grievance Redress Mechanism (GRM) shall be sensitive to SEA/SH, through a thereafter maintain and operate it transparent, non-discriminatory and easy-to-understand process that provides throughout Project feedback to affected parties in a language they understand, without retaliation, and implementation. shall operate in an independent and objective manner. This GRM shall be available to b) As part of the preparation of all direct and contract workers associated with IDEA COMESA Project (and their procurement documents and organizations, if any) to express their work-related concerns. These workers shall be respective contracts. informed of the existence of the GRM at the time of hiring and of the measures taken to protect them from any retaliation for having used it. b) Include in the bidding documents for the recruitment of consulting firms, the terms of reference for the selection of consultants, service providers and any consultancy subcontractors of the Project, as well as in the project implementation manual, clauses relating to the GRM in connection with any labor or employment issue within the framework of the Project and in compliance with the ESS2 and national labor legislation. 6|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT NOT RELEVANT ESS 4: COMMUNITY HEALTH AND SAFETY NOT RELEVANT ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT NOT RELEVANT ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES NOT RELEVANT ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES NOT RELEVANT ESS 8: CULTURAL HERITAGE NOT RELEVANT ESS 9: FINANCIAL INTERMEDIARIES NOT RELEVANT ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Adopt the SEP prior to Project appraisal, COMESA and thereafter implement and update Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent as necessary the SEP throughout Project with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, implementation. relevant, understandable and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 7|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 10.2 PROJECT GRIEVANCE MECHANISM Adapt and establish the grievance COMESA mechanism prior to the Project Adapt, adopt and operate the grievance mechanism implemented by COMESA under Effective date, and thereafter maintain the ASCENT project, in coordination with ASCENT, to receive and facilitate resolution of and operate the mechanism throughout concerns and grievances in relation to the IDEA Project COMESA operations, promptly Project implementation. and effectively, in a transparent and non-discriminatory manner that is culturally appropriate and readily accessible to all Project-affected parties, at no cost and without retribution, including concerns and grievances filed anonymously, in a manner consistent with ESS10. The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 PCU staff and consultant training on: Within 12 months of project COMESA with World Bank effectiveness. support a) Stakeholder Engagement Plan (SEP) – stakeholder mapping and engagement, and the functioning of the project’s grievance mechanisms b) Specific relevant aspects of environmental and social assessment, gender considerations c) Emergency preparedness and response d) Labor Management Procedures (LMP) including a Code of Conduct for project workers in relevant languages and Labor Specific GRM e) World Bank ESHS requirements for ESF and WB EHS Guidelines (including those for Telecommunications and (where relevant) Electric Power Transmission and Distribution), f) SEA/SH Action Plan including GBV issues g) Project wide GRM h) Occupational Health and Safety (OHS) Plan 8|P a g e