The Government of the “Union des Comores� ***************** MINISTRY OF ENERGY, WATER AND HYDROCARBONS ***************** Direction Générale de l’Energie, de l’Eau et des Mines (DGME) ***************** COMOROS NATIONAL WATER RESILIENCE PROJECT (P504691) Draft ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 29 March 2024 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Comoros (hereinafter the Recipient) will implement the Comoros National Water Resilience project (P504691) (the Project), with the involvement of the Ministry of Energy, Water and Hydrocarbons, Directorate General for Energy, Mines and Water, with the involvement of, inter alia, the Ministry Finance (MoF), 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(s). 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. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement(s). 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 Ministry of Energy, Water and Hydrocarbons 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 Directorate General for Energy, Mines and Water of the Ministry of Energy, Water and Hydrocarbons. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit quarterly reports to the PIU Prepare and submit to the Association] regular monitoring reports on the Association commencing after the environmental, social, health and safety (ESHS) performance of the Project, including but Effective Date and throughout Project not limited to the implementation of the ESCP, status of preparation and implementation semi-annual reports. implementation of E&S instruments required under the ESCP, stakeholder engagement Submit each report to the Association activities, and functioning of the grievance mechanism(s) [specify other aspects that the no later than 15 days after the end of reporting would need to consider, as relevant]. each reporting period. B INCIDENTS AND ACCIDENTS PIU Promptly notify the Association] of any incident or accident related to the Project which Notify the Association no later than 48 has, or is likely to have, a significant adverse effect on the environment, the affected hours after learning of the incident or communities, the public or workers, including, inter alia, cases of sexual exploitation and accident. abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or multiple injury [specify other examples of incidents and accidents, as appropriate for the Provide subsequent report to the type of operation]. Provide sufficient detail regarding the scope, severity, and possible Association within a timeframe causes of the incident or accident, indicating immediate measures taken or that are acceptable to the Association. 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 Submit the monthly reports to the PUI PIU Require contractors and supervising firms to provide monthly monitoring reports on and quarterly reports to the Association ESHS performance in accordance with the metrics specified in the respective bidding upon request. documents and contracts and submit the consolidated reports to the Association. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Establish and maintain a PIU as set out Directorate General for Establish and maintain a PIU into the Directorate General for Energy, Mines and Water in the legal agreement. Hire one Energy, Mines and Water with qualified staff and resources to support management of ESHS risks and impacts of Environmental and social specialist no (DGEME) the Project including an environmental and social specialist. later than three months after effective date, and thereafter maintain this position throughout Project implementation. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS 1) and 2) Adopt the ESIAs/ESMPs 1. Adopt and implement Environmental and Social Impact Assessment (ESIAs), and approved by the association before DGEME corresponding Environmental and Social Management Plan (ESMP) for Part 1 of the launching the bidding process for the Project, consistent with the relevant ESSs. respective subprojects’ activities and prior to the carrying out of subprojects 2. Cause the Directorate General for Energy, Mines and Water that would need to adopt activities that require the adoption of the ESMPs, to adopt and implement the subprojects Environmental and Social Impact such ESMPs. Once adopted, implement Assessment (ESIA) and Environmental and Social Management Plan (ESMPs). The the respective ESMPs throughout proposed activities described in the exclusion list set out in the ESMPs shall be ineligible Project implementation. to receive financing under the Project. 1.3 MANAGEMENT OF CONTRACTORS PIU Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S As part of the preparation of instruments, the Labor Management Procedures, and code of conduct, into the ESHS procurement documents and respective specifications of the procurement documents and contracts with contractors and contracts. supervising firms. Thereafter ensure that the contractors and supervising firms comply Supervise contractors throughout and cause subcontractors to comply with the ESHS specifications of their respective Project implementation. contracts. 1.4 TECHNICAL ASSISTANCE PIU Ensure that the consultancies, studies including feasibility studies, if applicable, capacity Throughout Project implementation. building, training, and any other technical assistance activities under the Project are carried out in accordance with terms of reference acceptable to the Association], that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. 1.5 CONTINGENT [EMERGENCY] [EARLY] RESPONSE FINANCING a) The adoption of the CERC manual Ministère de finances du a) Ensure that the CERC Manual as specified the legal agreement includes a description and, if applicable, other instruments, as budget et du secteur of the ESHS assessment and management arrangements including, if applicable, insert relevant in form and substance bancaire name of any CERC-ESMF that will be included or referred to in the CERC Manual for the acceptable to the Association is a implementation of CERC component, in accordance with the ESSs. withdrawal condition under Section [XX] of Schedule 2 of the of legal agreement for the Project. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project 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 CERC component of the Project, in accordance with the CERC Manual and include it as part of the respective and, if applicable, CERC-ESMF and the ESSs, and thereafter implement the measures and bidding process, if applicable, and in actions required under said E&S instruments, within the timeframes specified in said E&S any case, before the carrying out of the 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 Adopt the LMP no later than three PIU Adopt and implement the Labor Management Procedures (LMP) for the Project, months after effective date, and including, inter alia, provisions on working conditions, management of workers thereafter implement the LMP relationships, occupational health and safety (including personal protective equipment, throughout Project implementation. and emergency preparedness and response), code of conduct (including relating to SEA and SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish grievance mechanism prior PIU Establish and operate a grievance mechanism for Project workers, as described in the engaging Project workers and LMP and consistent with ESS2. thereafter maintain and operate it throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Same timeframe as for 1.2 PIU Adopt and implement a Waste Management Plan (WMP), to manage hazardous and non-hazardous wastes, consistent with ESS3. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the adoption PIU Incorporate resource efficiency and pollution prevention and management measures in and implementation of the ESMPs the ESMP to be prepared under action 1.2 above. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY Same timeframe as for the adoption PIU Incorporate measures to manage traffic and road safety risks as required in the ESMPs to and implementation of the ESMPs. be prepared under action 1.2 above. 4.2 COMMUNITY HEALTH AND SAFETY Same timeframe as for the adoption PIU Assess and manage specific risks and impacts to the community arising from Project and implementation of the ESMPs. activities, including, inter alia, behavior of Project workers, risks of labor influx, response to emergency situations, and include mitigation measures in the ESMPs to be prepared in accordance with the ESSs. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 4.3 SEA AND SH RISKS Adopt the SEA/SH Action Plan no later PIU Adopt and implement a standalone SEA/SH Action Plan to assess and manage the risks of than three months after effective and SEA and SH. thereafter implement the SEA/SH Action Plan throughout Project implementation. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK Adopt the RF no later than three PIU Adopt and implement a Resettlement Policy Framework (RF) for the Project, consistent months after effective date, and with ESS5. thereafter implement the RF throughout Project implementation. 5.2 RESETTLEMENT PLANS Adopt and implement the respective PIU Adopt and implement a resettlement action plan (RAP) for each activity under the RAP, including ensuring that before Project for which the RPF requires such RAP, as set out in the RPF,] [and] consistent with taking possession of the land and ESS5. related assets, full compensation has been provided and, as applicable, displaced people have been resettled and moving allowances have been provided. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS Modified habitats and anthropic and urbanized areas in project areas. No Impacts to Same timeframe as for the adoption PIU critical and natural habitats. Ineligible activities, subprojects to any significant conversion and implementation of the ESMPs. or degradation of critical habitat. The ESIA will include an analysis of risks and potential Implement the procedures throughout impacts on biodiversity and natural habitat to comply with the provisions and guideline Project implementation. consistent with ESS6.. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES NOT RELEVANT ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS Describe the chance find procedures in No tangible and intangible cultural heritage in potential project areas. Describe the ESMPs. Implement the procedures PIU and implement the chance finds procedures, as part of the ESMPs of the Project. throughout Project implementation. ESS 9: FINANCIAL INTERMEDIARIES [This standard is only relevant for Projects involving Financial Intermediaries (FIs).] NOT RELEVANT ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Draft SEP has been developed and will Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent be disclosed by appraisal. Finalize and PIU with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, adopt the SEP prior to the Negotiation relevant, understandable and accessible information, and consult with them in a and thereafter implement the SEP culturally appropriate manner, which is free of manipulation, interference, coercion, throughout Project implementation. discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism no Establish, publicize, maintain, and operate an accessible grievance mechanism, to later than six months after effective PIU receive and facilitate resolution of concerns and grievances in relation to the Project, date, and thereafter maintain and promptly and effectively, in a transparent manner that is culturally appropriate and operate the mechanism throughout readily accessible to all Project-affected parties, at no cost and without retribution, Project implementation. 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 Develop and submit to the Association a Capacity Building Plan for PIU staff including: Adopt the Capacity Building plan no PIU • stakeholder mapping and engagement later than 06 months after the Effective • Occupational Health and Safety date and implement during the • Incident reporting implementation of the Project. • ESF, ESS and World Bank Group EHS Guidelines • Health and safety of workers and communities • SEAH risk mitigation • Inclusion of vulnerable and disadvantaged groups in the consultation process • Grievance Mechanism • Development, implementation, monitoring and reporting in accordance with the PIM. • Awareness and prevention on sexually transmitted infections: HIV/AIDS, etc. • Awareness on GBV, SEA-SH and child protection 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY CS2 Develop and submit to the Association a Capacity Building Plan for Contractors and Adopt the Capacity Building plan no PIU sub-contractors on: later than 06 months after the Effective - Training on: date and implement during the o Introduction to the ESF, ESS and World Bank Group EHS Guidelines implementation of the Project. o Health and safety of workers and communities (including Personal Protective Equipment (PPE)) o SEA-SH awareness, control and prevention o Emergency preparedness and response o Grievance mechanism o Development, implementation, monitoring and reporting in accordance with the LMP. o Awareness and prevention of sexually transmitted infections: HIV/AIDS etc. o Road safety and traffic management. o Safe management of borrow pits and open water structures. - Occupational health and safety including on: o Emergency prevention and preparedness o Response arrangements to emergency situations o Incident reporting 8|Page