[International Federation of Accountants] DRAFT ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Developing International Public Sector Accounting Standards Board Sustainability Reporting Standards Project (P181576) March 27, 2024 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The International Federation of Accountants (IFAC) (the Recipient) will implement the Developing International Public Sector Sustainability Reporting Standards Project (the Project) as set out in the Grant Agreement. The International Reconstruction and Development (the Bank), acting as the administrator of the Recipient-Executed Trust Fund (RETF) has agreed to provide financing for the Project (P181576), as set out in the referred agreement. This ESCP shall apply to the Project referred to above. 2. The Recipient shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Bank. The ESCP is a part of the Grant 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 Recipient and the Bank agree to update the ESCP to reflect these changes through an exchange of letters signed between the Bank and the Recipient, represented by the Program and Technical Director, IFAC. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Open Government Partnership Country Capacity Support Project (P171667) and Additional Financing (P[x]) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit six-monthly reports to the Bank IFAC throughout Project implementation, Prepare and submit to the Bank, as part of the overall project progress reports, regular commencing after the Effective Date. monitoring reports on the environmental, social, health and safety (ESHS) performance Submit each report to the Bank no later of the Project, including but not limited to the implementation of the ESCP stakeholder than 30 days after the end of each engagement activities, and functioning of the grievance mechanism. reporting period. B INCIDENTS AND ACCIDENTS Notify the Bank no later than 48 hours IFAC after learning of the incident or Promptly notify the Bank of any incident or accident related to the Project which has, or accident. is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers, including, inter alia, cases of sexual exploitation and Provide subsequent report to the Bank abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or within a timeframe acceptable to the multiple injury. Provide sufficient detail regarding the scope, severity, and possible Bank. 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 consultants and/or supervising firm, as appropriate. Subsequently, at the Bank’s request, prepare a report on the incident or accident and propose any measures to address it and prevent its recurrence. C CIVIL SOCIETY ORGANIZATIONS’ QUARTERLY REPORTS Submit quarterly reports to the Bank as IFAC annexes to the reports to be submitted Require consultants and supervising firms/IFAC to provide half yearly monitoring reports under action A above. on ESHS performance in accordance with the metrics specified in the respective terms of reference and contracts and submit such reports to the Bank. D Recipient Guidelines on implementation of ESF standards Submit prior to the Effective Date. IFAC Submit Recipient institutional guidelines and procedures in place vis-à-vis the relevant ESF standards and include these details in the Project Operations Manual (POM) in form and substance and in a manner acceptable to the Bank. This includes the IFAC Due Process and Working Procedures and the Employee Handbook which includes the Code of Conduct, Safeguarding and Sexual Exploitation Policy, Sexual Harassment Policy, Travel and Expense Policy, and Whistleblower Policy. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Open Government Partnership Country Capacity Support Project (P171667) and Additional Financing (P[x]) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE No later than 30 days after the IFAC Establish and maintain qualified staff and resources to support management of ESHS effectiveness date and thereafter risks and impacts of the Project. maintain these positions throughout Project implementation. 1.2 MANAGEMENT OF CONSULTANTS As part of the preparation of IFAC procurement documents, including Incorporate the relevant aspects of the ESCP. The consultants and contractors will abide terms of reference, and respective by Recipient’s guidelines, including IFAC Due Process and Working Procedures and the contracts. Employee Handbook which includes the Code of Conduct, Safeguarding and Sexual Exploitation Policy, Sexual Harassment Policy, Travel and Expense Policy, and Supervise Consultants throughout Whistleblower Policy. Thereafter ensure that the consultants comply with the ESHS Project implementation. specifications of their respective contracts. 1.3 TECHNICAL ASSISTANCE Throughout Project implementation. IFAC Ensure that the consultancies, studies, capacity 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 ensure that the outputs of such activities comply with the terms of reference. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Incorporate relevant labor management IFAC policies and procedures into the Project The project will implement TA activities in accordance with ESS2, the IFAC’s relevant Operations Manual no later than 30 policies and procedures linked to labor and working conditions, and the labor-related days of the Effective Date, and policies and procedures of beneficiary countries. Relevant labor management policies thereafter implement the policies and and procedures will be incorporated into the Project Operations Manual. procedures throughout Project implementation. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Open Government Partnership Country Capacity Support Project (P171667) and Additional Financing (P[x]) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY One member of the Secretariat project management team will be assigned to take up Require consultants to complete the the responsibility for managing labor-related issues, such as sexual exploitation and code of conduct before project abuse/sexual harassment (SEA/SH) and discrimination, to ensure compliance with their activities, including needs assessments, governing policies and procedures. workshops and other events (under Component 1) commence. For SEA and SH risks at the workplace, the Project will: i) hold training to raise awareness among its staff on the risks and the policy requirements; ii) maintain an accountability and response framework to address any incidents of SEA/SH; and iii) address any incidents of SEA/SH through its assigned staff. For consultant firms to be engaged for the in-country consultation workshops and for the additional financing activities, the Secretariat will ensure that: a) the relevant requirements in compliance with ESS2, including SEA/SH risk mitigation, will be included in their consultancy contracts; b) contract workers will agree to comply with a code of conduct that prohibits SEA/SH; and c) specific mitigation actions are included in their Sub-Grants’ assignment implementation action plans. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS IFAC Established within 30 days of the There will be one grievance redress mechanism under the Project. Key actions are Effective Date and maintained described under ESS10 below. Labor-related grievances will be handled through this throughout project implementation. mechanism. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Not relevant 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Open Government Partnership Country Capacity Support Project (P171667) and Additional Financing (P[x]) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 4: COMMUNITY HEALTH AND SAFETY 4.1. GBV AND SEA RISKS Throughout Project Implementation IFAC To address any GBV and SEA/SH risks and impacts, i) hold trainings to raise awareness among Project workers on the risks and applicable policy requirements, and ii) address any such issues through assigned staff, all consistent with ESS4. 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 Screen and determine if Project activities will involve indigenous peoples once the Before the finalization of SEP, no later IFAC selection of countries are finalized. If indigenous peoples are involved, propose than 30 days after the Effective Date. measures in the activity design to engage with these groups in a manner consistent with the requirements of ESS7. Relevant indigenous people’s policies and procedures will be incorporated into the Stakeholder Engagement Plan and Project Operations Manual. ESS 8: CULTURAL HERITAGE Not relevant ESS 9: Financial Intermediaries Not relevant ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE IFAC Ensure that the grant activities incorporate stakeholder engagement and information Submit the final SEP for the disclosure in a manner consistent with ESS 10. Consultations will follow the Association’s prior review and no requirements of ESS 10, namely: objection, and thereafter adopt and 1. IFAC will engage with stakeholders throughout the project life cycle, commencing such disclose the SEP no later than 30 days engagement as early as possible in the project development process and in a timeframe after the Effective Date. that enables meaningful consultations with stakeholders on project design. The nature, scope and frequency of stakeholder engagement will be proportionate to the nature and scale of the project and its potential risks and impacts. 2. IFAC will engage in meaningful consultations with all stakeholders. IFAC will provide stakeholders with timely, relevant, understandable and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Open Government Partnership Country Capacity Support Project (P171667) and Additional Financing (P[x]) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 3. The process of stakeholder engagement will involve the following, as set out in further detail in this ESS: (i) stakeholder identification and analysis, particularly the disadvantage and vulnerable groups; (ii) planning how the engagement with stakeholders will take place; (iii) disclosure of information; (iv) consultation with stakeholders; (v) addressing and responding to grievances; and (vi) reporting to stakeholders. 4. IFAC will maintain, and disclose a documented record of stakeholder engagement, including a description of the stakeholders consulted, a summary of the feedback received and a brief explanation of how the feedback was taken into account, or the reasons why it was not. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism IFAC In addition to IFAC’s GRM policies, a project specific GRM mechanism will be set up to prior to the first disbursement and make sure that any potential complaints are addressed. This GM mechanism will receive thereafter maintain and operate the and facilitate resolution of concerns and grievances in relation to the Project, promptly mechanism throughout Project and effectively, in a transparent manner that is culturally appropriate and readily implementation. accessible to all parties affected by the Project, at no cost and without retribution, including concerns and grievances filed anonymously, in a manner consistent with ESS10. A project manager will be hired to be the central focal point for GRM. All grievances will be registered in a grievance log and addressed in a transparent and timely fashion. The complainants will be informed of the resolution response. Employees can also file a complaint with a government agency or in court under federal, state, or local antidiscrimination laws. Handling of grievances will be done in a culturally appropriate manner and be discreet, objective, sensitive and responsive to the needs and concerns of the project-affected parties. The mechanism will also allow for anonymous complaints to be raised and addressed. The grievance mechanism will also include a separate process for handling sensitive complaints, such as those involving SEA/SH (as outlined under ESS2). The grievance mechanism will include the following: • Different ways in which users can submit their grievances, which may include submissions in person, by phone, text message, mail, e-mail or via a web site. 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Open Government Partnership Country Capacity Support Project (P171667) and Additional Financing (P[x]) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY • A log where grievances are registered in writing, classified and maintained as a database. • Publicly advertised procedures, setting out the length of time users can expect to wait for acknowledgement, response and resolution of their grievances. • Transparency about the grievance procedure, governing structure and decision makers; and • An appeals process (including the national judiciary) to which unsatisfied grievances may be referred when resolution of grievance has not been achieved. • The project will maintain the GRM users’ identity as confidential and accept anonymous complaints. • All grievances will be deliberated and addressed in a transparent and timely fashion. The complainant will be informed of the resolution response. • Maintain an updated list of SEA/SH service providers, which can be used to refer potential survivors of SEA/SH-related events. The above GRM will be summarized in a separate document. Following the Bank’s clearance, this document will be uploaded and disclosed publicly on IFAC’s website. 8|Page