Republic of Zambia PROJECT: SCALING UP SHOCK RESPONSIVE SOCIAL PROTECTION IN ZAMBIA P179095 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN MAY 2023 Table of Contents 1 INTRODUCTION ......................................................................................................................... 5 1.1 PROJECT DESCRIPTION ................................................................................................................. 5 1.2 NEED FOR THE PROJECT ................................................................................................................ 5 1.3 PROJECT OBJECTIVES ................................................................................................................... 6 1.4 PROJECT BENEFICIARIES................................................................................................................ 6 1.5 IMPLEMENTATION ARRANGEMENTS: ORGANISATIONAL STRUCTURE/ ORGANOGRAM ................................. 6 2 ESMP STUDY METHODOLOGY.................................................................................................... 7 2.1 INTRODUCTION .......................................................................................................................... 7 2.2 LITERATURE REVIEW .................................................................................................................... 8 2.3 ENVIRONMENTAL AND SOCIAL BASELINE .......................................................................................... 8 2.4 IMPACT IDENTIFICATION AND MITIGATION MEASURES ........................................................................ 8 3 DESCRIPTION OF THE PROJECT .................................................................................................. 8 3.1 SOCIAL PROTECTION IN ZAMBIA ..................................................................................................... 8 3.2 PROJECT ACTIVITIES .................................................................................................................... 9 4 LEGAL AND POLICY FRAMEWORKS .......................................................................................... 10 4.1 NATIONAL REGULATORY FRAMEWORK........................................................................................... 10 4.1.1 THE NATIONAL CONSTITUTION ........................................................................................................ 10 4.1.2 GENDER EQUITY AND EQUALITY ACT (2015) ..................................................................................... 10 4.1.3 EDUCATION ACT (2011) ................................................................................................................ 11 4.1.4 ENVIRONMENTAL MANAGEMENT ACT .............................................................................................. 11 4.1.5 ANTI-GENDER BASED VIOLENCE ACT 1 OF 2011 ................................................................................ 11 4.1.6 OCCUPATIONAL HEALTH AND SAFETY ACT ......................................................................................... 11 4.1.7 INDUSTRIAL AND LABOUR RELATIONS ACT ......................................................................................... 11 4.2 POLICY FRAMEWORK ................................................................................................................. 12 4.2.1 NATIONAL SOCIAL PROTECTION POLICY ............................................................................................ 12 4.2.2 NATIONAL GENDER POLICY (2014).................................................................................................. 12 4.2.3 NATIONAL EDUCATION POLICY ........................................................................................................ 12 4.3 WORLD BANK ENVIRONMENTAL AND SOCIAL STANDARDS .................................................................. 13 5 DESCRIPTION OF THE BASELINE ENVIRONMENT ....................................................................... 17 5.1 LOCATION AND SIZE .................................................................................................................. 17 5.2 PHYSICAL ENVIRONMENT............................................................................................................ 17 5.3 DEMOGRAPHICS ....................................................................................................................... 18 5.4 SOCIAL, ECONOMIC AND CULTURAL ENVIRONMENT .......................................................................... 18 5.4.1 HEALTH ....................................................................................................................................... 18 5.4.2 EDUCATION.................................................................................................................................. 19 5.4.3 ECONOMIC ACTIVITIES ................................................................................................................... 19 5.4.4 TELECOMMUNICATION ................................................................................................................... 19 1 6 ENVIRONMENTAL AND SOCIAL IMPACTS ................................................................................. 20 6.1 PROJECT BENEFICIAL IMPACTS ..................................................................................................... 20 6.2 PROJECT ADVERSE IMPACTS ........................................................................................................ 20 6.2.1 OCCUPATIONAL HEALTH AND SAFETY RISKS (OHS)............................................................................. 20 6.2.2 GENDER BASED VIOLENCE, SEXUAL EXPLOITATION AND ABUSE AND SEXUAL HARASSMENT (GBV/SEA/SH) 20 6.2.3 EXCLUSION OF VULNERABLE GROUPS ............................................................................................... 21 6.2.4 SPREAD OF COVID-19 INFECTIONS AND INAPPROPRIATE DISPOSAL OF COVID-19 PPE ........................... 21 6.2.5 LABOR INCLUDING FORCED AND OR CHILD LABOUR ............................................................................. 21 6.3 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN ........................................................................ 22 6.4 ENVIRONMENTAL AND SOCIAL MANAGEMENT PLAN IMPLEMENTATION ................................................. 22 6.5 PROJECT IMPLEMENTATION UNIT ................................................................................................. 29 6.5.1 ORGANISATIONAL STRUCTURE/ORGANOGRAM ................................................................................. 30 7 STAKEHOLDER ENGAGEMENT AND GRIEVANCE REDRESS ......................................................... 30 7.1 STAKEHOLDER ENGAGEMENT ....................................................................................................... 30 7.2 GRIEVANCE MECHANISM ............................................................................................................ 32 8 ANNEXES ................................................................................................................................ 34 8.1 ANNEX 1: GBV ACTION PLAN ................................................................................................... 34 8.2 ANNEX 2: STAKEHOLDER ENGAGEMENT PLAN ......................................................................... 39 1. INTRODUCTION ...................................................................................................................... 41 1.1 PROJECT BACKGROUND .............................................................................................................. 42 1.2 ESS 10: STAKEHOLDERS ENGAGEMENT AND INFORMATION DISCLOSURE ............................................... 43 1.3 PURPOSE OF THE STAKEHOLDER ENGAGEMENT PLAN (SEP) ................................................................ 43 2. BRIEF SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES ................................................. 44 3. STAKEHOLDER IDENTIFICATION AND ANALYSIS ................................................................................... 45 3.1 PROJECT-AFFECTED PARTIES (PAPS) ............................................................................................. 46 3.2 OTHER INTERESTED PARTIES ........................................................................................................ 46 3.3 DISADVANTAGED OR VULNERABLE GROUPS .................................................................................... 48 4. IMPLEMENTATION ARRANGEMENTS FOR STAKEHOLDER ENGAGEMENT PLAN ............................................ 52 4.1 ROLES AND RESPONSIBILITIES ...................................................................................................... 52 INFORMATION DISCLOSURE FOR PROJECT .................................................................................. 53 4.2 ESTIMATED BUDGET FOR SEP ACTIVITIES ........................................................................................ 55 5. GRIEVANCE REDRESS MECHANISM ......................................................................................... 56 6. MONITORING AND REPORTING .............................................................................................. 58 8.3 ANNEX 3: GRIEVANCE REDRESS MECHANISM .......................................................................... 60 8.4 ANNEX 4: SECURITY MANAGEMENT PLAN ............................................................................... 61 2 SECURITY MANAGEMENT PLAN ....................................................................................... 61 ABBREVIATIONS ............................................................................................................................. 62 1.OBJECTIVE OF THE SECURITY MANAGEMENT PLAN (SMP) .................................................................... 63 1A) SECURITY APPROACH ......................................................................................................... 63 2. OVERVIEW OF THE SECURITY SITUATION........................................................................................... 63 3. SECURITY MANAGEMENT PLAN...................................................................................................... 65 4. SECURITY MANAGEMENT ............................................................................................................. 70 5. INCIDENCE REPORTING................................................................................................................. 70 ANNEX 5: LABOUR MANAGEMENT PROCEDURES .......................................................................... 72 LABOUR MANAGEMENT PROCEDURES ....................................................................................... 73 1.0 INTRODUCTION .................................................................................................................... 75 1.1 OVERVIEW OF LABOUR USE ON THE PROJECT ................................................................................ 75 2.0 ASSESSMENT OF KEY POTENTIAL LABOR RISKS ....................................................................... 76 3.0 BRIEF OVERVIEW OF LABOR LEGISLATION: TERMS AND CONDITIONS...................................... 77 4.0 BRIEF OVERVIEW OF LABOR LEGISLATION: OCCUPATIONAL HEALTH AND SAFETY (OHS) .......... 79 5.0 RESPONSIBLE STAFF .............................................................................................................. 79 6.0 POLICIES AND PROCEDURES .................................................................................................. 81 SECTION 7: AGE OF EMPLOYMENT .............................................................................................. 82 SECTION 8: TERMS AND CONDITIONS .......................................................................................... 82 9.0 GRIEVANCE MECHANISM ...................................................................................................... 82 10.0 CONTRACTOR MANAGEMENT ............................................................................................. 83 11.0 COMMUNITY WORKERS/ VOLUNTEERS ............................................................................... 83 3 ACRONYMS ACC Area Coordinating Committees CERC Contingency Emergency Response Component COVID-19 Corona Virus Disease 2019 CWAC Community Welfare Assistance Committees DDMU Disaster Management and Mitigation Unit DSW Department of Social Welfare DSWO District Social Welfare Office DWAC District Welfare Assistance Committee EHSG Environmental Health and Safety Guidelines EMA Environmental Management ESF Environmental and Social Framework ESS Environmental and Social Standard ESIP Environmental and Social Impact Assessment GBV Gender Based Violence GDP Gross Domestic Product GEWEL Girls Education and Women’s Empowerment and Livelihoods GRM Grievance Redress Mechanism HQ Headquarters KGS Keeping Girls in School LMP Labour Management Procedures MCDSS Ministry of Community Development and Social Services MoE Ministry of Education NDP National Development Programme NSPP National Social Protection Policy OHS Occupational Health and Safety PIU Project Implementation Unit PPE Personal Protective Equipment PPM PayPoint Managers PSC Project Steering Committee PSWO Provincial Social Welfare Office PTA Parents Teachers Association SADC Southern African Development Community SCT Social Cash Transfer SEA-H Sexual Exploitation, Abuse and Harassment SEP Stakeholder Engagement Plan SWL Supporting Women’s Livelihoods TCLC Tripartite Consultative Labour Council ZISPIS Zambia Integrated Social Protection Information System ZEMA Zambia Environmental Management Agency 4 1 INTRODUCTION 1.1 Project Description The project will build on the existing IDA and multi-donor funded, Zambian government implemented social protection project, the Girls Education and Women’s Empowerment and Livelihoods (GEWEL) (P151451) and will continue the focus on government’s flagship cash plus social protection approach. The project aims to alleviate the negative impacts of the multiple crises Zambia has faced on household income and food security. It will support the poorest households in Zambia with cash transfers to almost one million beneficiaries of the government’s SCT program for the period of one year. This emergency financing will therefore stabilize financing for the SCT. The project will utilize the existing systems and capacity built by the GEWEL project, including a Grievance Redress Mechanism (GRM) that is functional countrywide, and the Zambia Integrated Social Protection Information System (ZISPIS), which is an integrated management information and digital payments system, among others. businesses, (see Section 3 for details) It has one main component: Component 1: Social Cash Transfer (SCT) programme: This component will finance bi-monthly cash transfers to poor and vulnerable households on the SCT and an annual education grant to households that have one or more KGS supported girls. The SCT provides a bi-monthly transfer of ZMW400 (US$24 equivalent, or US$12 monthly) for an ordinary household and double this amount for households with a person with severe disability. It will also cover activities to enhance the shock responsiveness of the SCT. SCT also provides an education grant to households that have one or more adolescent girls through the existing SCT payment system. This is to support households to cover other costs involved in adolescent girls attending school such as uniforms, books, food, and transport, among others. The value of the education grant is currently ZMW600 (around US$35) per girl per year. This represents 25 percent of the annual cash transfer value for the average household or 12.5 percent of the annual cash transfer for households with a disabled member.The component would include the design and implementation of a mechanism to scale up the SCT to channel funds to poor and vulnerable households in the case of emergencies, including droughts and food price shocks. This will provide short-term bridge financing exclusively for the immediate response and recovery needs related to an eligible emergency. It is possible that additional households may need to be targeted as a result of future shocks. Thus, this component may provide resources to finance a temporary limited horizontal or vertical expansion of the SCT, as necessary. 1.2 Need for the Project Zambia’s Gross Domestic Product (GDP) growth has fluctuated over the last decade due to shocks. The economy is returning to growth, following the global easing of COVID-19 restrictions, market confidence because of the recent national election, better rainfall, and positive copper price outlooks. However, delays in Zambia’s debt restructuring process and rising global oil and fertilizer prices due to the Russia-Ukraine war continue to pose risks to the economic recovery.1 Consumption and food security of the poor is threatened by high inflation, rising fuel and fertilizer prices in the country, and global increases in food prices. Following the COVID-19 shocks in 2020, poverty increased from 56% in 2019 to nearly 60 percent as per the international poverty line.2 Girls and women were especially vulnerable before the pandemic, and gender inequality and vulnerability to poverty has worsened since. 1 Macro Poverty Outlook, Zambia. World Bank. April 2022. 2 COVID-19, Poverty, and Social Safety Net Response in Zambia. World Bank. 2021. 5 A World Bank report shows that women and girls were disproportionately affected by the COVID-19 crisis, which reinforced unequal gender norms, child marriage, gender-based violence and decreased women’s agency, maternal health, jobs, and profit earnings.3 Multiple challenges and a shrinking fiscal space to sustain financing to the social protection sector at current levels, have weakened the Government's ability to sustain financing to social safety nets to alleviate the impact on the poor and vulnerable. This could lead to a reversal of the timely and predictable cash transfers to beneficiaries achieved in 2021 and a return of the 2019/2020 situation where beneficiaries received only some of the transfers they were entitled to. This project would provide critical financing to sustain Zambia’s investment in its safety nets and would also pre-position disaster risk financing for Zambia at this time of global price instability. 1.3 Project Objectives To protect poor and vulnerable households' consumption in response to shocks. 1.4 Project Beneficiaries The project will build on the GEWEL project. It will focus on stabilizing funding for the government’s national social cash transfer program while also continuing to strengthen delivery systems for the program. The project will therefore have one component, the Social Cash Transfer (SCT), which together with funding provided under GEWEL, will cover cash transfers to almost one million beneficiaries of the government’s SCT program for the period of one year. This emergency financing will therefore stabilize financing for the SCT, while also including a small buffer of funds to allow for a limited vertical or horizontal expansion of the cash transfer to respond to price shocks or other shocks as required. The project will utilize the existing systems and capacity built by the GEWEL project, including a Grievance Redress Mechanism (GRM) that is functional countrywide, and the Zambia Integrated Social Protection Information System (ZISPIS), which is an integrated management information and digital payments system, among others. Any financing not fully utilized for a vertical or horizontal expansion in the first year, will be utilized for the SCT in the following year. The SCT targets the vulnerable and incapacitated households across Zambia’s 116 districts. The unit of selection and identification of beneficiaries under the SCT programme is the household, including working age women and adolescent girls within those households. This assumes that giving a transfer to a household will benefit the entire household and at the same time promote intra household cohesiveness. 1.5 Implementation Arrangements: Organisational Structure/ Organogram The Government of the Republic of Zambia will implement the Shock Responsive Social Protection in Zambia Project (the Project), through Ministry of Community Development and Social Services (MCDSS). This project will be coordinated by a Project Steering Committee (PSC) comprised of the Permanent Secretaries of the two implementing Ministries and Cabinet Office: the Ministry of Community Development and Social Services (MCDSS), Ministry of Education (MoE) and the Gender Division. The PSC will continue to be chaired by the Secretary to Cabinet or his delegate and will focus on strategic oversight of the project, policy, and coordination with other ministries. Its role will continue to be to provide policy guidance, approve annual work plans and budgets, oversee project progress, ensure coordination across the implementing ministries, and approve the audited financial 3https://openknowledge.worldbank.org/bitstream/handle/10986/37347/IDU00c5a3da201bc80481f087a80807ea85467ea. pdf?sequence=1&isAllowed=y 6 reports. The PSC meets on a quarterly basis. The PSC will continue to be supported by a National Secretariat, housed in the Gender Division, with a Director of Planning and Information and Project Coordinator facilitating coordination across ministries and components. For SCT, the government’s SCT program will continue to be implemented by the MCD SS under the leadership of the Permanent Secretary. The Permanent Secretary, as overall controlling officer for activities and management of the funds for the program, implements the program under the guidance of the Poverty and Vulnerability Cluster Advisory Group, which oversees social protection programming in Zambia. The SCT at headquarters has a team of officers under the Programme Implementation Unit (PIU) sitting in the Department of Social Welfare, who work alongside the provincial and district levels to carry out the various functions of the program. The District Social Welfare Officers (DSWOs) work with community structures, particularly the Area Coordinating Committees (ACCs) and Community Welfare Assistance Committees (CWACs), to reach the beneficiary households. Any emergency response will also need to be closely coordinated with DMMU. The Department of Social Welfare institutional arrangements at the province, district and community levels will also be involved. To ensure shock response activities are well coordinated, the Cash Working Group under the leadership of the Director Social Welfare will act as the main coordination platform, bringing together donors and other non-state actors, donors and other non-state actors. Figure 1: Institutional arrangement for the Scaling up Shock Responsive Social Protection in Zambia 2 ESMP STUDY METHODOLOGY 2.1 Introduction The ESMP preparation involved collecting secondary data on the environmental and social situation, consultations with stakeholders and data analysis. It followed a typical process of establishing the current baseline conditions, identifying specific environmental and social risks that need to be addressed, characterization of the effects the project will have and the impacts (positive or negative) they will result in. It also determined the significance of the issues identified, establish mitigation and 7 monitoring measures, and finally proposals for management plans to ensure effective implementation of mitigation and management of the anticipated issues. The approach and methodology chosen ensures that applicable World Bank Environmental and Social Standards (ESS) processes have been followed and will be described in detail where applicable in consideration to identified environmental and social risks and impacts of ZEEP. 2.2 Literature review This included studying relevant documents including the project proposals and appraisals, legislation, and policies; national and local secondary data sources; and other reports and documents related to the proposed project including the World Bank Environmental and Social Frameworks and Environmental and Social Impact Assessments (ESIA) and associated guidelines. Key documents reviewed included: • The Project Appraisal and Project Implementation documents • The Project Environmental and Social Commitment Plan • Project Implementation Manual • GEWEL project: Challenges and Lessons Learnt • GEWEL Grievance Mechanism manual • The project draft Stakeholder Engagement Plan • World Bank Environmental and Social Framework • Gender Policy • UNESCO Zambia Country Reports 2.3 Environmental and Social Baseline Environmental and social baseline comprised secondary data collected through review of literature. 2.4 Impact Identification and Mitigation Measures The primary tool for identification of impacts and mitigation was using expert judgment and consultations including recommendations from stakeholders. Impacts were identified from the environmental and socio-economic reviews guided by the World Bank Environmental and Social Standards. Impact assessments were also based on criteria developed from Zambian legal standards, World Bank Environmental and Social Safeguards and international standards, and discussed in Chapter 6. 3 DESCRIPTION OF THE PROJECT 3.1 Social Protection in Zambia Zambia has a strong policy environment and commitment level to social protection as highlighted in its National Social Protection Policy 2014-2018 (NSPP) which provides a broad framework within which social assistance programs operate. The policy’s objectives include reducing poverty, boosting food security, and building human capital. In 2019, the Integrated Framework of Basic Social Protection Programs (IFBSP) fostered the existing social protection policy to move the sector: (a) in the direction of layering basic social assistance together with livelihoods and empowerment programmes to achieve greater impact; and (b) from programming in silos to a more complementary and comprehensive approach to reducing extreme poverty and promoting human capital development. The foundation of this approach is the Social Cash Transfer (SCT), which provides regular cash transfers to assist 8 extremely poor and vulnerable households’ consumption and enables them to make human capital and livelihoods investments through empowerment interventions. NSPP set targets to scale-up the SCT program to all districts nationally by 2016—a target that the government managed to achieve by 2017. The Seventh National Development Plan (7NDP) reinforced the NSPP with targets to increase social assistance coverage from 40 percent to 70 percent of the poor, and spending from 0.7 percent to 1.7 percent of GDP. The Eighth National Development Plan (8NDP) for 2022-2026 further outlines social protection and human development as one of the four key pillars of government’s development strategy. While the newly elected government is committed to undertaking macroeconomic reforms, the government’s fiscal space is strained making the government’s ability to finance and scale up safety nets transfer payments to the poorest constrained in the immediate term. Nonetheless, the World Bank has increased its investment and lending in the social protection sector in Zambia in a major way in recent years, resulting in a large scale up of support to the poorest and most vulnerable. The Bank’s current lending operation in the social protection sector in Zambia is the Girls Education and Women’s Empowerment and Livelihoods (GEWEL) project (P151451), a cash plus social protection program that supports the poorest families in Zambia with cash transfers and layers additional interventions to empower girls from those families to complete their secondary education, and support women in starting their own small businesses. 3.2 Project Activities The project will be comprised of the SCT component as follows: Component 1: Social Cash Transfer (SCT) This component will finance bi-monthly cash transfers to poor and vulnerable households on the SCT. SCT currently provides a bi-monthly transfer of K400 (US$24 equivalent, or US$12 monthly) for an average household and double this amount for households with a person with a disability. Beneficiaries are selected through categorical as well as poverty targeting to identify people that are poor and are not able to work due to age, disability, illness, or high dependency ratios. SCT also provides an education grant to households that have one or more Keeping Girls in School (KGS) girls through the existing SCT payment system. This is to support households to cover other costs involved in adolescent girls attending secondary school such as uniforms, books, food, and transport, among others. The value of the education grant is currently K600 (around US$35) per girl per year. This represents 25 percent of the annual cash transfer value for the average household or 12.5 percent of the annual cash transfer for households with a disabled member. To support government to ensure stable financing to the SCT, the component will provide financing to cover 100 percent of SCT transfers over the coming one year to the caseload of 1 million plus beneficiaries across Zambia’s 116 districts. This will stabilize financing to the social protection sector for the coming three years and ensure that poor and vulnerable people are protected at a time when government is facing economic and fiscal challenges. Given the undisbursed International Development Association and Multi Donor Trust Fund contributions remaining for SCT under GEWEL, together with the financing under this component, the Bank can support financing of SCT at 100 per cent in the first year and at 50 per cent in the next two years up to mid-2025. This includes an adjustment for inflation. This would allow a stabilization of financing to the sector while government improves its fiscal position and reduces the chances of volatile transfers to beneficiaries as per the situation in 2019 and 2020. Under SCT, there will be a mechanism to provide resources to finance a temporary limited horizontal or vertical expansion of the component, as necessary. This will entail channelling funds to poor and 9 vulnerable households in the case of emergencies, including droughts and food price shocks. This will provide short-term bridge financing exclusively for the immediate response and recovery needs related to an eligible emergency. As part of operational costs, the component will also finance a nutrition messaging pilot for beneficiaries that receive mobile money transfers through ZISPIS in selected districts. There is a desire that the project explores ways in which it can have an impact on nutrition beyond the impact of cash transfers on food security. ZISPIS already has this inbuilt messaging capability but this requires further investment to be activated, including setting up a bulk messaging service. The Ministry will therefore pilot this initially in 2 districts to be identified, based on areas that have mobile connectivity as well as that are prioritized in terms of nutrition indicators in the Zambia Demographic and Health Survey. The content of the nutrition messaging will be designed with the support of a nutrition consultant with input from other relevant institutions. 4 LEGAL AND POLICY FRAMEWORKS 4.1 National Regulatory Framework The proposed project activities converge with several regulatory instruments which need compliance with. Presented below is a listing of key legislation relevant to the project and requiring legal compliance were applicable. 4.1.1 The National Constitution Zambia’s Constitution of 1964 has recognised and declared that every person in Zambia has been and shall continue to be entitled to the fundamental rights and freedoms of the individual whatever his race, place of origin, political opinions, colour, creed, sex, or marital status, but subject to limitations as contained in Article 11. It makes provision for equal and adequate educational opportunities in all fields and at all levels in the form of directive principles. The Constitution of the Republic of Zambia also provides for the protection of young persons from exploitation and states that no young person shall be employed and shall in no case be caused or permitted to engage in any occupation or employment which would prejudice his/her health or education or interfere with his/her physical, mental, or moral development. In 2016, Government gazette N.A.B 37, 2016 released the “Act to amend the Constitution of Zambia�. The Constitution (Amendment) Act No.2 of 2016 includes civil, economic, political, social, cultural, and economic rights confirming the equal worth of women and men and their rights to freely participate in, determine, and build a sustainable political, legal, economic, and social order. 4.1.2 Gender Equity and Equality Act (2015) The Act strengthens the legal framework for the elimination of all forms of discrimination against women and girls; empowers women to participate fully in public and private affairs of the country. It establishes the Gender Equity and Equality Commission and provide for its functions and powers; provide for the taking of measures and making of strategic decisions in all spheres of life to ensure gender equity, equality, and integration of both sexes in society. It promotes gender equity and equality as a cross cutting issue in all spheres of life and stimulate productive resources and development opportunities for both sexes; prohibit harassment, victimization and harmful social, cultural, and religious practices and provides for public awareness and training on issues of gender equity and equality. The Act gives effect to the Convention on the Elimination of all Forms of Discrimination against Women, the Protocol to the African Charter on Human and People’s Rights on 10 the Rights of Women in Africa and the SADC Protocol on Gender and Development; and provide for matters connected with, or incidental to, the foregoing. 4.1.3 Education Act (2011) The Act firmly asserts a person’s right to early childhood care, development, and education, as well as basic education, including adult literacy education and high school education. It also recognizes a child’s right to free basic education, makes it compulsory, and places the burden of responsibility on the parent to ensure that a school-age child attends school. The Education Act provides a firm legislative basis for implementation of the Government’s free basic education policy. Under this legislation, the Government is obliged to make general and vocational education progressively more available and accessible to all people. 4.1.4 Environmental Management Act The Environmental Management Act (EMA) was enacted in 2011 to repeal the Environmental Protection and Pollution Control Act (EPPCA), 1990. The Act provides for integrated environmental management, protection and conservation of the environment and sustainable management and use of natural resources. It promotes prevention and control of pollution and environmental degradation; and public participation in environmental decision making and access to environmental information. Part 1, Section 4 (1) of the Act gives every person living in Zambia the right to a clean, safe, and healthy environment, including the right of access to the various elements of the environment for health (Part 1, Section 4, (2)). Part 2, Section 1 (Sub-section 1) of the Act gives the Zambia Environmental Management Agency (ZEMA) the mandate to ensure the sustainable management of natural resources and protection of the environment and the prevention and control of pollution. 4.1.5 Anti-Gender Based Violence Act 1 of 2011 The Anti-Gender Act is meant to provide for the protection of victims of gender-based violence; constitute the Anti-Gender Based Violence Committee; establish the Anti-Gender-Based Violence Fund; and provide for matters connected with, or incidental to, the foregoing. An act of gender-based violence shall be inquired into, tried, and otherwise dealt with in accordance with the Criminal Procedure Code, the Penal Code and any other written law. Subject to the Constitution, where there is any inconsistency between the provisions of this Act and the provisions of any other written law the provisions of this Act shall prevail to the extent of the inconsistency. In this Act, unless the context otherwise requires “ abuse � means conduct that harms or is likely to cause harm to the safety, health or wellbeing of a person; “ aggravated � in relation to gender-based violence, means any act of gender- based violence which (a) causes the victim to suffer wounding or grievous bodily harm; or (b) the court otherwise considers to be so serious as to be aggravated, taking into account (i) whether a weapon was used; (ii) evidence of pre-meditation; (iii) whether the victim is particularly vulnerable. 4.1.6 Occupational Health and Safety Act This Act provides for the protection against risks to health or safety arising from, or in connection with, the activities of persons at work. Therefore, it is important that the activities of the project must protect the workers. Part IV, Section 16 (1 and 2) outlines the duties of the employer which are generally: providing a safe working environment; making sure that the employees are healthy and fit to work in the provided work environment; providing protective clothing or equipment; making sure there are health, safety, emergency and first aid measures; and providing information on safety and health. Nonetheless, employees have the responsibility for their personal health and safety (Part IV, Section 17 (1). 4.1.7 Industrial and Labour Relations Act The Industrial and Labour Relations Act, Chapter 269, provides for the formation of workers and employers representative organizations and the constitution of the Tripartite Consultative Labour 11 Council (TCLC). The TCLC provides a national forum for employers, workers, and government to discuss and resolve labour issues, including occupational safety and health, which may be affecting the labour market. The Act also provides for the formulation of recognition and collective agreements, settlement of disputes, strikes and lockouts. 4.2 Policy Framework Three main sector policies are identified as relevant to the proposed program and need to be complied with, namely the National Social Protection Policy, the National Gender Policy, and National Education Policy. 4.2.1 National Social Protection Policy The National Social Protection Policy 2014-2018 (NSPP) provides a broad framework within which social assistance programs operate, highlighting the objectives of reducing poverty, boosting food security, and building human capital. NSPP, in fact, sets forth concrete targets to scale-up the SCT program to all districts nationally by 2016—a target that the government managed to achieve by 2017. The Seventh National Development Plan (7NDP) reinforced the NSPP with targets to increase social assistance coverage from 40 percent to 70 percent of the poor, and spending from 0.7 percent to 1.7 percent of GDP. The forthcoming Eighth National Development Plan (8NDP) for 2022-2026 further outlines social protection and human development as one of the four key pillars of government’s development strategy. In 2019, the Integrated Framework of Basic Social Protection Programs (IFBSP) built on existing social protection policy to move the sector in the direction of layering basic social assistance together with livelihoods and empowerment programming to achieve greater impact through focusing on complementary and comprehensive approaches to reducing extreme poverty and promoting human capital development. 4.2.2 National Gender Policy (2014) The National Gender Policy ensures the attainment of gender equality by redressing existing gender imbalances. It further provides for equal opportunities for women and men to actively contribute to national development. The Policy document provides guidelines for addressing barriers that prevent equal and effective participation of men and women in national development. Some of its key priority areas of focus are empowerment of women by facilitating participation in education and economic activities as well as addressing issues that hinders women’s rights such as Gender Based Violence, forced early child marriages and child-teenage pregnancies. 4.2.3 National Education Policy Zambia’s Education Policy upholds the principle that every individual has an equal right to educational opportunity. The Government’s commitment to education has been clear since it passed the 1964 Education Act governing the financing and management of education in Zambia. Education development has been among the Government’s main priorities, as indicated by the stable share of government spending devoted to education, as well as successive education sector plans and associated policy reforms. Nonetheless, issues around need for continuous improvements to access and equity, further enhancement of the quality and relevance, effectiveness and efficiency of the education system have been raised4. Through a Ministry of Education circular in December 2021, the Government highlighted that the provision of free education from early childhood to secondary education would start in January 2022, with the government paying tuition fees through a compensatory grant. The government also announced abolition of Parent Teachers Associations, examination, and tuition fees in all government schools, in a bid to eradicate key obstacles to accessing education for all. 4 UNESCO Education Policy Review: Zambia https://unesdoc.unesco.org/ark:/48223/pf0000246408 12 4.3 World Bank Environmental and Social Standards In addition to the national environmental legal framework, this ESIA takes into consideration the World Bank applicable Environmental and Social Standards (ESS). Table 4-1 lists the ESS that are applicable to this project. Table 4-1 Environmental Social Standards (ESS) Environmental and Social Standard Applicability ESS1: Assessment and Key social risks relating to the project include (1) exclusion of vulnerable Management of Environmental and households, including persons with disability, (ii) elite capture, (iii) Social Risks and Impacts labour risks (iv) increased incidence of GBV/SEA/SH and (v) lack of meaningful consultations. Required measures to address these risks will be stipulated in the Environmental and Social Commitment Plan (ESCP). A draft Stakeholder Engagement Plan (SEP) has been prepared and disclosed prior to appraisal. The SEP contains guidance on identification of project stakeholders, channels of engagement for different groups, including a grievance process for registering complaints. Labour risks may arise and therefore a Labor Management Procedures (LMP) has been prepared including measures for prevention of GBV/SEA/SH. The environmental risks for the project include (i) theft and physical violence towards PPMs (ii) transmission of Covid-19 and (iii) disposal of Covid-19 PPE waste. Based on these known risks this project ESMP has been prepared to include updated OHS risk mitigation measures to address PPM security risks and Covid-19 related PPE waste management measures based on the ESSs. The Labor Management Procedures (LMP) will include terms and conditions of employment, nondiscrimination, and equal opportunity (which includes a safe work environment free from violence and sexual harassment), workers’ organizations, restrictions on child and forced labor, and occupational health and safety (OSH), drawing on national laws and regulations, the World Bank ESF Environmental and Social Standard ESS2 on Labor and Working Conditions, and other international best practices. Implementation of the prepared SEP is necessary to strengthen project ownership and prevent potential conflicts between beneficiaries, local government and health providers. As committed in the ESCP, the environment and social risks of the project will be managed by appointing a designated focal person (an environmental and social safeguards specialist) within the PIU, who can be supported or trained by the World Bank’s environmental and social specialists. There will be no construction activities, occupation of land and, therefore, the project will not directly impact on biodiversity conservation or interfere with sustainable management of living natural resources or will have a direct impact on tangible or intangible cultural heritage. ESS2: Labor and Working ESS2 is considered relevant for this project. Workers engaged will Conditions include: (i) direct workers who will all be civil servants including PIU 13 staff/specialists, at national and provincial level and (ii) community workers. Labor risks may arise due to failure to abide by national legislation on employment in relation to working hours, wages, overtime, non-discrimination in recruitment and employment, as well as compensation and benefits, and workplace sexual harassment. Civil servants, whether full-time or part-time, will remain subject to the terms and conditions of their existing public sector employment agreement or arrangement. A Labor Management Procedure (LMP) that includes preventive measures for GBV/SEA/SH and PPM security will be adopted from GEWEL and this will be committed in the Environmental and Social commitment Plan (ESCP). The spread of COVID-19 may be heightened during cash payouts activities and empowerment orientation activities could expose communities and workers alike. COVID prevention measures which include: (i) social distancing and enhanced hygiene; and (ii) provision of Personal Protective Equipment (PPE) in the form of facemasks, washbasins, and soap; (iii) encouraging frequent handwashing or disinfection with an alcohol-based hand sanitizer, and (iv) PPM security measures will continue to include (i) limiting the amount of cash carried by any one PPM (ii) PPM security training that includes risk awareness and safe mode of travel iii) introducing the digital method of payment (iv) using two PPMs per cash transfer (principle and deputy PPM) to increase personal security, (v) reduce the number of bank visits and the amount stored at any one time (vi) maintaining a low profile during beneficiary payments by irregular payment patterns and maintaining privacy between PPM and beneficiary during payments. In addition, the LMP will adopt Codes of Conduct (including SEAH), and for direct workers ( civil servants) they will continue using existing public service mechanisms. Community workers grievance mechanism will draw upon the GEWEL grievance redress mechanism, and their already existing community structures ensuring principles of responsiveness, confidentiality, objectivity, independence, simplicity, fairness and timeliness. The GEWEL grievance redress mechanism (GRM) shall be used to receive, register, and address concerns and grievances related to the GBV/SEA-H in a safe and confidential manner and shall include the referral of survivors to GBV/SEA-H service providers. Individuals under the age of 18 will be prohibited from working on the Project by national laws and regulations and this prohibition will be contained on the LMP. The ESMP will also guide on procedures to be followed for COVID-19. ESS3: Resource Efficiency and ESS 3 is relevant. PPE waste will be generated because of COVID-19 Pollution Prevention Management personal protection requirements when engaged in upscaled project activities. PPE waste may consist of single use face masks and hand sanitizer bottles. COVID-19 related solid waste mitigation measures should include (i) all noninfectious PPE should be disposed of as solid waste through the municipal solid waste collection systems and (ii) at all projects related events PPE should be segregated and placed in 14 strong plastic waste bags, secured and disposed of in the municipal solid waste stream and (iii) project related participants infected with COVID- 19 should have already visited a medical facility for assessment (if possible) and (iv) all those who are infected with COVID-19 their PPE should be disposed of in the medical waste stream at that medical facility and (v) further advice about Covid related PPE waste should be obtained from local health care providers. COVID-19 related solid waste mitigation measures will be implemented as documented in the project ESMP. ESS4: Community Health and Safety ESS4 is considered relevant. The risks are limited to issues arising from training activities and cash transfer payment initiative both involving workers of the project and targeted community members. The project will ensure that necessary PPE are provided to all participants, hygiene standards and distancing are observed as a measure to COVID 19 response. World Bank’s Technical Note on Public Consultations and Stakeholder Engagement in WB-supported operations when conducting meetings and trainings will also be applied. A PPE protocol will be included to ensure safe application of reusable PPEs and proper final disposal of single use PPEs to prevent further transmission and infection of COVID-19 to the community. Proper training on the risk management procedures including OHS measures will be provided by the project’s environmental and social focal points. The project will establish an appropriate reporting format as a measure to identify and address negative health and safety issues. GBV/SEA/SH is a community health and safety risk. To manage this risk, active implementation of the LMP, SEP and the GRM will be rigorously undertaken to ensure awareness among community members. The project will ensure regular sensitization of project workers and local communities regarding the risk of GBV/SEA/SH in relation to interactions among project workers and between project workers and local communities. The project will identify focal persons to oversee prevention and management of GBV/SEA/SH risks at project and community level. The project will adopt a code of conduct for all workers engaged by the project and will include provisions to address GBV/SEA and will outline the process of addressing such complaints in line with guidance from the World Bank Good Practice Note (GPN) on GBV. Transmission of HIV/AIDS is also a community health and safety risk given that project personnel will also be interacting with the community. The project will ensure regular sensitization of direct workers and local communities regarding the risks related to transmission of HIV/AIDS. ESS5: Land Acquisition, Restrictions ESS 5 is not currently relevant to the project, as no land acquisition, on Land Use and Involuntary restriction on land use and involuntary resettlement is anticipated. Resettlement 15 ESS6: Biodiversity Conservation and As no land use or civil works or infrastructure construction activities are Sustainable Management of Living expected in this project the likely impacts of the project on living natural Natural Resources resources, critical habitats and biodiversity are low. ESS7: Indigenous Peoples/Sub- ESS7 is not considered relevant to this project as there are no distinct Saharan African Historically social and cultural groups in the project area that exhibit characteristics Underserved Traditional Local of indigenous or traditionally under-served communities as spelled out Communities under this standard. ESS8: Cultural Heritage ESS 8 is not currently relevant to project. Since there is no land use or involvement of any community there will be no impact on tangible or intangible cultural heritage ESS9: Financial Intermediaries ESS 9 is not currently relevant to project as there will no financial intermediaries involved. ESS10: Stakeholder Engagement The project adopted a draft Stakeholder Engagement Plan (SEP), and Information Disclosure prepared for the Scaling Up Shock Responsive Social Protection (SSRSP) that builds on the Girls Education and Women’s Empowerment and Livelihoods (GEWEL) project (P151451). Since commencing implementation in 2015, GEWEL has embedded regular consultations with its various stakeholders into its programming, hence, preliminary stakeholder mapping was conducted For the purposes of this Project, affected stakeholders are poor, vulnerable and labor constrained households across Zambia’s 116 districts, and working age women and adolescent girls within those households. They may include the elderly (above 65 years old), severely disabled, chronically ill, child-headed households, female headed households, adolescent girls from SCT households. The SEP shall be updated to include activities to be implemented under this project, consistent with ESS10. The SEP will then be continuously updated during project implementation. Project, other interested parties are described as institutions and organizations that will be directly involved in the delivery of the project from national (or HQ), district to community level. At national level, the Gender Division acts at a coordinating institution while MCDSS, MOE implement the Project. At district level, the District Commissioners of the target districts, Members of the council, the executive committee and its sub-committees and nongovernmental organisations working in such districts will be direct interested parties. The traditional leaders, area and village development committees and their subcommittees and community volunteers constitute some of the direct interested parties at community level. Cooperation Partners at national level, representatives of NGOs at district and community level, religious groups and their leaders and communities in areas where the project will be implemented are some of other interested parties. 16 5 DESCRIPTION OF THE BASELINE ENVIRONMENT The baseline information includes a description of the current situation in terms of the socioeconomic environment, physical environment, health, education, economic and telecommunications. Zambia is divided into ten provinces namely, Central, Copperbelt, Western, North-Western, Eastern, Northern, Muchinga, Luapula, Lusaka and Southern. The proposed SSRSP project will be implemented in a total of 116 districts across all the ten provinces. 5.1 Location and Size Zambia is a landlocked country that lies at the end of the Great Rift Valley between latitudes 8° and 18° S and longitudes 22° and 33° E. It shares the political borders with eight neighbours, namely Angola, Democratic Republic of Congo, Tanzania, Malawi, Mozambique, Botswana, Namibia, and Zimbabwe. The political boundaries have several shared biodiversity resources because of the common habitats. The country covers an area of 752,618 km2 (Dowsett et al., 2008). A man-made Lake Kariba now forms part of the river border with Zimbabwe. The long border with the Democratic Republic of the Congo starts at Lake Tanganyika, crosses to Lake Mweru, and follows the Luapula River to the Pedicle, a wedge of Congolese territory that cuts deep into Zambia to give the country its distinctive butterfly shape. Westward from the Pedicle the frontier follows the Zambezi- Congo watershed to the Angolan border. Zambia has 10 provinces and a total of 116 districts. 5.2 Physical Environment Although Zambia lies within the tropics, its climate is modified by the altitude of the country and is generally favourable to human settlement. In January, the rainy season is at its peak; by June the weather is dry. Precipitation (concentrated in just five months) varies according to agroecological region but generally comes in storms with heavy raindrops that lead to a hard soil surface and surface erosion. The driest region receives annual precipitation of less than 30 inches (800 mm), while precipitation in the wettest region normally exceeds 40 inches (1,000 mm); precipitation occasionally exceeds 55 inches (1,400 mm) in the northeast. Temperature is modified by elevation, with the 17 highest mean daily maximum temperatures occurring in the Luangwa valley and the southwest. The coolest area overall is the high Nyika plateau, in the northeast on the border with Malawi. During the cold months (June and July), the area west of the Line of Rail is coolest, with mean minimum temperatures mostly below the mid-40s F (about 7 °C). Sesheke, in the southwest, has frost on an average of 10 days per year. 5.3 Demographics Zambia's population is 18.38 million as of 2020. Lusaka Province has the highest proportion of the population, at 17.9 percent, followed by Copperbelt Province, at 15.3 percent. North-western Province has the lowest proportion of the population, at 5.4 percent. The average household size in Zambia is 5.1 persons. Overall, the average household size tends to be larger in rural areas with an average of 5.2 persons compared to 5.0 persons in urban areas. Male headed households tend to have a larger average household size than female headed households. The average household size for male headed households was 5.4 persons compared to 4.3 persons for female headed households Zambia’s population is small relative to the country’s area, and its growth rate is lower than that of many of its neighbours in sub-Saharan Africa. Life expectancy in Zambia is below the global average. The country’s population is relatively young, nearly half under age 15. Zambia’s birth rate is significantly higher than the world average, and its death rate is among the highest in the world. Zambia’s lower life expectancy and higher death rate are attributable in part to the prevalence of HIV/AIDS in the country. Large parts of Zambia are thinly populated. Much of population is concentrated in the country’s most developed area—known as the Line of Rail—which is served by the railway linking the Copperbelt with Lusaka, the capital, and with the border town of Livingstone. 5.4 Social, Economic and Cultural Environment The general welfare of any society largely depends on the active economic participation of its citizens. The engagement of individuals in gainful economic activities directly influence households’ well-being. Human beings have always exchanged their labour with income to access various basic needs such as, food, shelter, health, and clothing. According to the 2015 Zambia Living Conditions Monitoring Survey Report, 58.5 percent (5, 925,412) of the population are in the labour force, while 41.5 percent (4, 203,497) are economically inactive. Of those that are in the labour force, 43 percent, 6.3 percent and 9.2 percent are in paid employment, unpaid family workers and not working, respectively. Zambia has a vast collection of cultures, language dialects and customs. It is home to more than 70 ethnic groups, including the Bemba in the Northern, Luapula and Copperbelt provinces, Tonga in the Southern province, and Lozi in the Western province, the Ngoni in Eastern province, the Lunda, the Luvale and the Kaonde in North-western province. Thirteen languages are spoken in Zambia and its contemporary culture is a blend of values, norms, material, and spiritual traditions of the diverse ethnic groups. 5.4.1 Health Zambia has a well-developed private and public health care system which provides specialized medical services such as diagnostic, curative, etc. The private health sector has earned the reputation as providers of good quality health care. Government has declared health care system as a priority sector. Health systems in Zambia are classified into three major categories: • First Level comprising of Health Posts, Rural Health Centre, and District Hospitals, where primary health care and preventive health services are provided. • Second Level comprising the provincial and general hospitals, which provide the curative care • Tertiary level comprising Central hospital and the National University teaching Hospital. Provide specialized care. 18 The arrangement of health services is along the same administrative lines with the district as the focus of service delivery, the provincial as the secondary level and central and the University Teaching Hospital as the tertiary level of care. The disease burden in Zambia varies according to climates with the most prevailing diseases being malaria, HIV/AIDS, and tuberculosis, diarrhea, skin diseases, respiratory tract infections and malnutrition. Recently Zambia is experiencing a sudden rise in non- communicable diseases namely cancer, cardiac, diabetes and renal diseases. This new pattern of diseases has brought with it numerous challenges for the health sector in Zambia, whose service delivery is predominantly public. The ill-equipped public health facilities often lack capacity to handle these cases thereby causing the Ministry of Health and individual patients to seek treatment abroad. 5.4.2 Education Zambia has achieved near universal primary school completion levels - national statistics indicate a completion rate of 91.8 per cent at Grade 7. But this masks considerable regional disparities, with the northern region recording 81.3 per cent (72 per cent for female students) and Lusaka a rate of 78.6 per cent. For children in the early years, the coverage of care, learning and education services remains persistently low. Overall, girls continue to be at a disadvantage with many dropping out in the upper primary and secondary grades, and poorer levels of transition to junior secondary and senior secondary levels. Transition rates from primary to secondary school continue to remain low at 67.5 per cent, mainly due to the lack of places to accommodate all primary school graduates. Other barriers to children transitioning and completing secondary school include school fees introduced in Grade 8, other costs related to education (such as the cost of not otherwise contributing to household income), and the long distances to many schools. For girls at secondary level, there are also barriers around the lack of menstrual hygiene facilities, the low value placed by some communities on girls’ receiving a secondary education, teenage pregnancy, and child marriage. The quality of education also continues to be a challenge, though national assessments have shown significant improvement in this area. Nevertheless, the country's targets for achievement have not yet been met, for instance the target of an average score of 40 per cent in language and mathematics was not reached in either Grade 5 or Grade 9. The number of children passing the Grade 9 and Grade 12 examinations continues to be low, at 55.3 per cent and 64.8 per cent respectively. 5.4.3 Economic Activities Zambia’s economy has experienced mixed development in the years since its independence in 1964. Nonetheless, economic performance has been impressive over the past decade, with an average annual real GDP growth rate surpassing 7 per cent during this period. This has largely been driven by growth in construction, transport, communications, the public sector, trading, and mining. Mining remains a driver of investment to other sectors, especially construction, transport, and energy. Copper is the country’s mainstay, contributing about 70 per cent to export earnings, but employs less than 2 per cent of the population. However, over the last few years, non-traditional exports have grown substantially. Most people in Zambia (60 per cent) live in rural areas, where they depend on subsistence agriculture for their livelihoods. Inflation increased from 9.8 per cent in 2019 to 13.4 per cent in 2020. Poverty is most prevalent in rural areas (76.7 %) compared to 23.4% in urban areas5. In both rural and urban households, poverty levels are highest among female-headed households, with extreme poverty levels of over 60 % in rural areas6. 5.4.4 Telecommunication The capacity to communicate and access to information in Zambia have significantly increased with the provision of digital satellite, internet, and mobile networks in the country. The providers include Zamtel, MTN and Airtel. Internet connectivity, though of intermittent service, is provided by the three 5 Zambia Central Statistical Office. 2015. 2015 Living Conditions Monitoring Survey (LCMS. 6 Living Conditions Monitoring Survey 2006-2011 19 cellular service providers. Internet penetration in Zambia however remains low at 15.4% which includes both domestic and corporate users. The number of mobile phone subscribers in the country has grown at a rate of 19.5% per annum in the last 8 years, which has reached 11.6 million people out of a population over the 14 million and a service penetration of 83.4% in 2018. 6 ENVIRONMENTAL AND SOCIAL IMPACTS 6.1 Project Beneficial Impacts The project will generate direct positive social and environmental impacts. Positive social impacts will entail supporting vulnerable women and girls from poorest families through provision with cash transfers plus social protection to empower girls to complete their secondary education, and support women in starting their own small businesses for sustainable livelihoods. The predictability of cash transfers, particularly during emergencies, is critical to avoid further negative coping strategies and an irreversible impact on food security and human capital. 6.2 Project Adverse Impacts 6.2.1 Occupational Health and Safety Risks (OHS) There is potential OHS risks associated with the Social Cash Transfer (SCTs) method of payment mainly Payment Point Mangers (PPMs) carrying substantial amounts of cash being vulnerable to theft and physical harm. Mitigation Measures: • For PPMs, a Security Management Plan has been developed (see Annex 4) which articulates mitigations measures including: (i) limiting the amount of cash carried by any one PPM (ii) PPM security training that includes risk awareness and safe mode of travel iii) introducing the digital method of payment (iv) using two PPMs per cash transfer (principle and deputy PPM) to increase personal security, (v) reducing the number of bank visits and the amount stored at any one time (vi) adopting irregular payment patterns and (vii) maintaining privacy between PPM and beneficiary during payments, amongst others. 6.2.2 Gender based Violence, Sexual Exploitation and Abuse and Sexual Harassment (GBV/SEA/SH) GBV/SEA/SH is a potential impact that may occur during implementation of the project. There is a likelihood that the project might change local power dynamics on the project area of influence. Altering power dynamics at household level has tendency to contribute to increased risks of Gender Based Violence (GBV) and illicit sexual relations with minors from local communities. This is further worsened by the fact that rural communities have limited access to health facilities and support services for GBV/SEA survivors are usually lacking. Workers and community volunteers may also be at risk of GBV/SEA/SH. Mitigation Measures: • To manage this risk, active implementation of the LMP (Annex 5), SEP (Annex 2) and the GRM (Annex 3) will be promoted to ensure awareness among community members. • Ongoing preventive measures currently being implemented on the parent project will be extended to this operation see GBV Action Plan (Annex 1) including sensitization, awareness, and training strategies with clear referral pathways in collaboration with communities and local women groups and women rights organizations. • Civil servants to be guided by the public service Code of Conduct 20 6.2.3 Exclusion of Vulnerable Groups Gender exclusion and lack of meaningful consultations and limited participation with some stakeholders (such as people living with disabilities, marginalized women, the young and elderly) resulting in the risk of elite capture and existing social and cultural norms which may limit participation of women during community consultations is a potential risk. Exclusion could also be due to individual’s availability challenges limiting participation. Various reasons can include being constrained by access to transportation to project venues and competing responsibilities and lack of time. They may also be constrained by lack of support from their household or other groups who hold influence and power, especially over adolescent girls. Mitigation measures: • Implement the SEP and ensure regular dissemination of information on project status, using appropriate means such as use of local language to cater for different groups and promote inclusivity of all beneficiary stakeholders. • Implement SEP on use of various media for project information dissemination including use of written forms of communication such as letters and electronic mails, community radio stations where available, public meetings, visual media (posters, billboards, community videos) and mobile public address system (ZANIS). Where possible use of social media platforms and groups. 6.2.4 Spread of COVID-19 Infections and Inappropriate disposal of COVID-19 PPE The risk of Covid-19 transmission is highly likely for all activities. The risk of inappropriate disposal of Covid-19 related PPE waste is elevated by scaling up under the SCTs. Mitigation Measures: • Covid- 19 mitigation measures for project activities already include, under GEWEL (i) social distancing and enhanced hygiene; and (ii) increased Personal Protective Equipment (PPE) such as facemasks, washbasins and soap, etc (iii) encouraging frequent handwashing or disinfection with an alcohol-based hand sanitizer (iv) physical distance of at least 2 meter (v) regular environmental cleaning and disinfections of project locations (schools, offices etc) (vi) use of digital payment methods for SCT activities to reduce face to face contact (vii) ensuring that policies, training, messaging and education in all project related areas are increased to improve awareness of COVID-19 and (viii) that management of people with COVID-19 or their contacts are treated critically e.g. requiring project related staff, workers and participants who are unwell or who develop symptoms to stay at home, self-isolate and contact a medical professional or the local COVID-19 information line for advice on testing and referral. • As under GEWEL and to avoid the inappropriate disposal of Covid-19 PPE into the environment (i) all non-infectious PPE should be disposed of as solid waste through the municipal solid waste collection systems and (ii) at all project related events PPE should be segregated and placed in strong plastic waste bags, secured and disposed of in the municipal solid waste stream and (iii) project related participants infected with Covid-19 should have already visited a medical facility for assessment (if possible) and (iv) all those who are infected with Covid-19 their PPE should be disposed of in the medical waste stream at that medical facility and (v) further advice about Covid- 19 related PPE waste should be obtained from local health care providers. 6.2.5 Labor including forced/trafficked and or child labour Poor labor and working conditions may impact adversely on the workers in the project. The labor and working conditions risks may be due to possibility of failure by contractors to abide by national legislation and ESS2 requirements in relation to working hours, discrimination, compensation, overtime, and benefits. Risks may also include, gender-based violence and/or sexual exploitation, 21 abuse and harassment, inadequate implementation of occupational health and safety measures among other. The project workforce is expected to include: • Direct workers (i.e., project implementation unit mainly civil servants). Civil servants working for the project will remain subject to the terms and conditions of their existing sector employment. • Contracted workers (consultants) • Community workers such as community-based volunteers. Mitigation Measures: • A Labour Management Procedure (LMP) has been developed to address the OHS and labour issues relating to direct and contracted workers and community volunteers ( see Annex 5) 6.3 Environmental and Social Management Plan The E&S risks are moderate. The project will be implemented in accordance with the Environmental and Social Management Plan (ESMP) (Table 1) below and will apply the relevant requirements of the Environmental Health and Safety Guidelines (EHSGs) to achieve positive occupational and health, community health and safety as well as environmental outcomes. Different stakeholders including project managers, officers, school staff, voluntary community workers have different responsibilities in ensuring the implementation as well as monitoring of the ESMP as described in Table 6-1. 6.4 Environmental and Social Management Plan Implementation The table 6-1 below outlines the monitoring of the ESMP implementation plan. It follows the impacts and mitigations identified in Section 6.2 above and provides the performance indicators, monitoring requirements, frequency as well as responsibility for monitoring 22 Table 6-1Implementation Matrix 23 Project IMPACT TYPE POTENTIAL MITIGATION MEASURES RESPONSIBLE MONITORING ESTIMATED activities IMPACT DEPARTMENT INDICATORS COST OF ACTIVITY ($) Component 1: Social Cash Transfer (SCT) Provision of Occupational Thefts; Security • Limiting the amount of cash carried by any one SCT PIU Incidents reports cash transfers Health and Safety threats for PPM to poor and (OHS) PPMs • PPM security training that includes risk $308,6267 vulnerable awareness and safe mode of travel households • introducing the digital method of payment • using two PPMs per cash transfer (principle and deputy PPM) to increase personal security • reduce the number of bank visits and the amount stored at any one time • adopt irregular payment patterns and • maintaining privacy between PPM and beneficiary during payments. Provision of bi- OHS COVID-19 • Implement ongoing prevention Covid-19 SCT PIU SCT reports monthly cash exposure prevention measures under GEWEL as follows: $236,445 transfers to • social distancing and enhanced hygiene; and; poor and increased Personal Protective Equipment (PPE) vulnerable such as facemasks, washbasins and soap, etc; households encouraging frequent handwashing or disinfection with an alcohol-based hand sanitizer; physical distance of at least 2 meter; regular environmental cleaning and disinfections of project locations (schools, offices etc.; use of digital payment methods for SCT activities to reduce face to face contact; ensuring that policies, training, messaging and education in all project related areas are 24 increased to improve awareness of Covid-19 • ensuring that management of people with Covid-19 or their contacts are treated critically e.g. requiring project related staff, workers and participants who are unwell or who develop symptoms to stay at home, self-isolate and contact a medical professional or the local Covid-19 information line for advice on testing and referral Provision of Exclusion of Exclusion of • Implementing the SEP ( see Annex 2) which will SCTSCT PIUs SEP developed - cash transfers vulnerable vulnerable ensure inclusivity of all categories of to poor and groups groups beneficiaries. vulnerable households Provision of bi- Community COVID-19 • Implement ongoing prevention Covid-19 SCTCT PIU monthly cash Health and exposure prevention measures under GEWEL as follows: transfers to Safety • social distancing and enhanced hygiene; SCT reports poor and increased Personal Protective Equipment (PPE) vulnerable such as facemasks, washbasins and soap, etc; households encouraging frequent handwashing or disinfection with an alcohol-based hand sanitizer; physical distance of at least 2 meter; regular environmental cleaning and disinfections of project locations (schools, offices etc.; use of digital payment methods for SCT activities to reduce face to face contact; ensuring that policies, training, messaging and education in all project related areas are increased to improve awareness of Covid-19 • ensuring that management of people with Covid-19 or their contacts are treated critically e.g. requiring project related staff, workers and participants who are unwell or who develop symptoms to stay at home, self-isolate and 25 contact a medical professional or the local Covid-19 information line for advice on testing and referral Provision of bi- Environment PPE waste • To avoid the inappropriate disposal of Covid-19 SCT PIUs Sensitisations, provision monthly cash pollution PPE into the environment (i) all non-infectious of waste bags at SCT transfers to PPE should be disposed of as solid waste distribution sites poor and through the municipalmunicipal solid waste vulnerable collection systems and (ii) at all project related households events PPE should be segregated and placed in strong plastic waste bags, secured and disposed of in the municipal solid waste stream and (iii) all those who are infected with Covid- 19 their PPE should be disposed of in the medical waste stream at the medical facility they will have attended and (v) further advice about Covid-19 related PPE waste should be obtained from local health care providers. Provision of bi- OHS Unfair labour • Implement Labor Management Procedure LMP Developed monthly cash practices (LMP) to include appropriate terms and transfers to conditions of employment, non-discrimination, poor and and equal opportunity (which includes a safe vulnerable work environment free from violence and households sexual harassment), workers’ organizations, restrictions on child and forced labor, and occupational health and safety (OHS), drawing on national laws and regulations and international best practices. • All consultants engaged by the project shall receive training on OHS and GBV/SEA-H risks and be required to sign a code of conduct • Provide a Grievance Redress Mechanism $276,518 (GRM) for all contracted workers to raise workplace concerns. The grievance mechanism (GM) shall also receive, register 26 and address concerns and grievances related to the GBV/SEA-H in a safe and confidential manner, and shall include the referral of survivors to GBV/SEA-H service providers. • Individuals under the age of 18 will be prohibited from working on the Project by national laws and regulations Provision of bi- GBV Intimate • Adopt ongoing preventive measures currently School Staff Mid-Year and Last monthly cash Partner being implemented on the parent project will quarter of the Year transfers to Violence, be extended to this operation see GBV Action Community Reports poor and Plan (Annex 1) including sensitization, volunteer focal vulnerable Sexual awareness and training strategies with clear points $206,471 households harassment referral pathways in collaboration with and communities and local women groups and exploitation; women rights organizations • 27 Table 6-2 Monitoring Plan Impact Performance Indicators Monitoring Requirements Frequency Responsibility o Provide waste disposal receptors on For all cash Environmental o Physical routine inspections during PPE waste site (bins) disbursement technicians payments of SCT o activities o Security trainings and protocols in SCT PIU Team place. o Physical and routine inspections during Training frequency o Availability of Covid-19 PPE for payments of SCTs conducted monthly Occupational Health and workers o Observations on COVID protocols or as needed Safety o Availability of Information, Education adherence Communication on Covid-19 o Documentation of GBV, SEA-H training o Number of Covid-19 cases recorded given to workers o SEA-H policy and code of conducts o Availability of Information, Education Bimonthly SCT PIU Team Community Health and Communication of Covid-19 o Physical inspections Safety o o GBV Trainings Bimonthly SCT PIU Team o GBV/ SEA-H code of conduct Gender Based Violence o Review of cases recorded and resolved o Links established with referral pathways Exclusion of vulnerable Bimonthly SCT PIU Team o Implementation of SEP o Records of meetings groups 28 6.5 Project Implementation Unit The SSRSP project will utilise the already existing implementation arrangements under the GEWEL Project. Strategic oversight will be provided by a PSC comprised of the Permanent Secretaries of the two implementing ministries (MCDSS and MOE) and Cabinet office, Gender Division. The role of the PSC will be to provide policy guidance, approve annual work plans and budgets, oversee project progress, ensure coordination across the implementing ministries, and approve the audited financial reports. Each of the implementing ministries is, however, responsible, and accountable for implementation of their component and activities, with the Permanent Secretary as the controlling officer (see Fig 2). For Component 1, the government’s SCT program will continue to be implemented by the MCDSS and the current SCT PIU will continue to provide day to day management of the Program with strategic direction being provided by the Director of Social Welfare. Any emergency response will be implemented by the MCDSS.This will be through the SCT PIU under the Department of Social WelfareTheT payment of the Education grant will continue to be implemented by the Department of Social Welfare in the MCDSS. 29 6.5.1 Organisational Structure/Organogram Figure 2: Project Implementation Unit 7 STAKEHOLDER ENGAGEMENT AND GRIEVANCE REDRESS 7.1 Stakeholder Engagement A detailed Stakeholder Engagement Plan (SEP)7 has been prepared by the Gender Division, MCDSS and MoE to identify the key stakeholders of the “Scaling up Shock Responsive Social Protection� project establishing stakeholder engagement measures, including public information disclosure and consultation, throughout the entire project cycle. A SEP is essential for the implementation of the ESMP as it provides a better perception of the project context and any possible concerns that various stakeholders might hold. It ensures the effectiveness of the mitigation measures developed under the ESMP. Further the SEP takes into consideration the different types of stakeholders and describes measures adopted to ensure groups that are differently affected are captured, particularly those identified as vulnerable. The SSRSP builds on the Girls Education and Women’s Empowerment and Livelihoods (GEWEL) project (P151451) which commenced implementation in 2015 and has embedded regular consultations with its various stakeholders into its programming. As there are no new activities to be included under SSRSP, the identified stakeholders under the GEWEL Project and their description remains relevant for this SEP. However, the SEP acknowledges that stakeholder engagement is an inclusive process conducted throughout the project life cycle. A summary of the key objectives of the SEP as stated in the ESS-10 are to: • Identify the roles and responsibility of all stakeholders and ensure their participation in all stages of the project cycle. • Establish a systematic approach to stakeholder and citizen engagements that will help to identify stakeholders and build and maintain a constructive relationship with project-affected parties. 7 See Annex 2 for the detailed SEP 30 • Assess the level of stakeholder interest and support for the project and to enable stakeholders’ views to be considered in project design and environmental and social performance. • Promote and provide means for effective and inclusive engagement with project- affected parties throughout the project cycle on issues that could potentially affect them. • Ensure that appropriate project information on environmental and social risks and impacts is disclosed to stakeholders in a timely, understandable, accessible, and appropriate manner and format taking special consideration for the disadvantaged or vulnerable groups. • Provide project-affected parties with accessible and inclusive means to raise issues and grievances and allow the Project Implementing Entity and its Project Management Unit to respond to and manage such grievances. ESS10 classifies stakeholders in two broad categories: “Project-affected parties� (PAPs) and “other interested parties�. Within these categories, persons or groups may be categorized as especially disadvantaged or vulnerable Out of these two levels of stakeholders there are three categories into which they can be identified as follows: a) Project Affected Parties (PAPs) –these are defined as persons, groups, and other entities within the project area of influence that are directly influenced (actually or potentially) by the project and/or have been identified as most susceptible to change associated with the project. PAPs also need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures. For the purposes of this Project, affected stakeholders are poor, vulnerable and labor constrained households across Zambia’s 116 districts, and working age women and adolescent girls within those households. They may include the elderly (above 65 years old), severely disabled, chronically ill, child-headed households, female headed households, adolescent girls from SCT households. Stakeholders also include wider community members or non-beneficiaries of the project living in the target communities. They also include community members engaged as volunteers or assgined to focal point role to help deliver the project. b) Other Interested Parties- are defined as individuals/groups/entities that may not experience direct impacts from the project but who consider or perceive their interests as being affected by the project and/or who could affect the project and its implementation. For the purposes of this Project, other interested parties are described as institutions and organizations that will be directly involved in the delivery of the project from national (or HQ), district to community level. At national level, the Gender Division acts as a coordinating unit while MCDSS, MOE implement the project. At district level, the District Commissioners of the target districts, Members of the council, the executive committee and its sub-committees and nongovernmental organisations working in such districts will be direct interested parties. The traditional leaders, area and village development committees and their subcommittees and community volunteers constitute some of the direct interested parties at community level. Cooperation Partners at national level, representatives of NGOs at district and community level, religious groups and their leaders and communities in areas where the project will be implemented are also some of the other interested parties. c) Disadvantaged or vulnerable groups are persons who may be disproportionately impacted or further disadvantaged by the projects as compared with any other groups due to their vulnerable status, and that may require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the projects. Although the Project is largely expected to have positive impacts among beneficiary members of the target communities, there is still a possibility of individuals, families and communities being negatively affected by activities of the program. These may come from among the beneficiaries or non- beneficiary members of the target communities. The women and children, the youth, elderly, disabled and chronically ill are often the most vulnerable because of their limited access to information due to 31 physical, social, cultural, and structural barriers within the communities. These categories of people will be particularly targeted with adequate information to understand the nature of project activities and anticipated positive and potential negative impacts of the project. They will also be provided with information on how to access the grievance redress mechanism of the project whenever the need arises. For elderly members of the community that might have mobility challenges when it comes to accessing venues for program activities such as meetings, there will be consideration to organize meetings within manageable distances. Another envisaged challenge is high illiteracy levels in some of the target communities that will make it difficult for beneficiaries to read and understand written information pertaining to the project. Appropriate methods such as public meetings, visual media (posters, billboards, community videos), will be employed to reach out to such groups of people. Hearing challenges (due to age or birth) by some beneficiaries might require use of sign language aides in outreach and visibility tools as well as Public Address systems or megaphones, especially where the meetings attract large crowds of people. To date, the project has been guided by the SEP in engaging, sensitisation and public information disclosure through different platforms catering for the various identified stakeholders. The SEP has been prepared according to Environmental and Social Standard 10 (ESS 10) on Stakeholder Engagement and Information Disclosure of the World Bank’s Environmental and Social Framework (ESF) and will cover the whole project life cycle. 7.2 Grievance Mechanism A grievance redress mechanism is an accessible and inclusive system, process, or procedure that receives and acts upon complaints and suggestions for improvement in a timely manner and facilitates resolution of concerns and grievances arising in connection with a project. An effective grievance mechanism provides project-affected parties with redress and helps address issues at an early stage. The objective of the GRM is to satisfactorily address complaints (grievances) from beneficiaries and non-beneficiaries of the GEWEL program. The goals of the GRM are to ensure people use the system, staff understand what is going well or poorly with program design and implementation, and communication messages around the GRM are tested and improved. The GRM is expected to address eight categories of complaints: Exclusion; Inclusion; Payment; Service Standards; Fraud and Corruption; Serious, including Gender Based Violence (GBV); and Other. The project will harness the existing Grievance Redress Mechanism operational manual established under the GEWEL (see Annex 3). The GEWEL GRM provides step-by-step information on how to handle complaints, from intake to response, including standard processes for responding to different categories of complaints. It articulates the types of complaints that can be reported and how they should be responded to as well as outlining the roles and responsibilities at all levels. It also outlines the steps for collecting, logging, and responding to complaints and describes how the GRM will be implemented, including awareness raising and monitoring and evaluation. In summary, the GRM has three channels available to receive complaints including complaint boxes, community grievance focal person as well as a telephone hotline for GBV complaints. The mechanism will also allow for anonymous complaints to be raised and addressed. 32 The three Ministries, Ministry of Gender, Ministry of Education, and MCDSS which form part of SSRSP have each designated two Grievance Focal Persons at the Headquarters (HQ) level. Each Province and District have also identified a maximum of two Grievance Focal Persons in the Community Development Department as well as in the District Education Board. All participating communities have also identified a Community Grievance Focal Person who will be the main support for the project at community level. Guidance and Counselling Teachers in schools which have KGS girls will be provided with Complaint Forms and will be responsible for communicating through the district or a nearby GEWEL Complaint Box, complaints to the District Grievance Focal Persons for MOGE. The GRM provides a Complaint Categories and Responses section which outlines the procedures for investigation/resolution, forwarding to HQ, referral based on GBV Referral Pathway, or a standard response. Other complaints that may not be within the jurisdiction of project will be forwarded to the relevant program or related district level office whilst it is acknowledged that some complaints will require no further investigation. All complaints related to GBV/ SEA/H will be fast tracked and referred immediately using the GRM Operational Guideline outlined GBV Referral Pathway. New stakeholders will be informed of the grievance mechanism in place during sensitizations, through community-based stakeholder and other forms of media including posters and fact sheets. The Government of Zambia has a separate Grievance Redress Mechanism (GRM) to deal exclusively with those that involve workers employed by the government public service commission. This will be used to receive concerns, complaints, and grievances from public service members. Other project workers will have a separate GRM as defined in the LMP to address worker concerns. Workers will be informed of the GRM at the time of recruitment. 33 8 Annexes 8.1 Annex 1: GBV ACTION PLAN Action Responsible Party Timeline Frequency Comments Expand deployment of GRM-GBV Focal Points to MCDSS-GBV-GRM February 2023 Selection All 116 districts to have females as GBV- remaining districts and to cover SCT (currently 76 Focal Point happens once GRM focal points districts covered) in a year March 31st 2023 Selected Focal Points will be trained in GBV- GRM. The training activity happens at Implement harmonized training to community level district level Implement Annual Harmonized ToT on GBV and GRM MCDSS-GBV-GRM Mid-March, 2023 This is a harmonized training activity for all Train province and district level Focal Points Focal Point GEWEL implementing components and is undertaken in regions Develop Tools for Community Sensitization MCDSS GBV-GRM December This is aimed at harmonize SCT community Review SCT Community Sensitization session on GRM Focal Point 31st,2022 sensitization session to GEWL GRM and GBV Radio sensitization key message Rights and responsibilities of beneficiaries (service charters) Lifeline child-line to pilot drama shows in at Radio and physical sensitization meetings Lifeline Childline January 31st, 2023 least 4 districts and work closely with GEWEL Focal Point districts level staff in rolling out sensitization activities All IEC materials to be translated into official February 28th, 7 local languages 2023 Undertake regular monitoring of GRM and GBV MCDSS GBV-GRM December, 2022 Midyear and This monitoring activity will be specific to Provisions Focal Point last quarter of GRM and GBV provisions. It will involve the year holding a few meetings with community level FPs in smaller groups 34 Action Responsible Party Timeline Frequency Comments Implement GRM and GBV National Symposium for all MCDSS, MoE GBV- September 9th, Virtual symposium with key stakeholders to components i.e., undertake a GBV-GRM fact finding GRM Focal Points 2022 identify areas of harmonization for all field trip develop an action plan on the findings of GEWEL implementing components. field trip, hold virtual a symposium with key stakeholders and hold a physical symposium to Hold physical symposium to validate Key validate findings, mitigation measures, and proposals take aways of virtual symposium to be used for a harmonized GEWEL GBV-GRM for further strengthening of the GEWEL Hold physical symposium to validate findings October 31st, 2022 GBV-GRM. Key takeaways included; Clarity on how to work with female focal points vs CWACs, placement of complaint boxes, how to manage excess complaint boxes, collection of complaints, holding regular meetings and strengthened harmonization between offices of DSW and DCD use of harmonized operation manual, brochures, budgets, timelines, communication messages and service charters Monitor and document lessons learned from SWL MCDSS GBV-GRM April 15th, 2023 Discussion with men in smaller groups to Engaging Men Activity implemented during Phase 4 Focal Point get feedback on their involvement in LS trainings Finalize roll-out of Referral Pathways MCDSS GBV-GRM August 31st, 2023 Ensure referral pathway directories are Print referral pathway directories Focal Point /Gender delivered to all 116 districts Division Harmonized communications strategy for Lifeline MCDSS MoE GBV- December 31st, Radio jingles to include Lifeline Childline Childline GRM Focal Point 2022 MCDSS and MoE to ensure GBV-GRM Implement radio jingles communication messages are reflective of Revise community sensitization guidelines to include lifeline child line including 116/933 toll free Lifeline Childline number on the stickers Share lifeline communication messages during school KGS schools to provide and distribute key assemblies communication messages on Life Line Child SCT sensitization meetings April 30th, Line to all schools Print fact sheets for schools and distribute them 2023 35 Action Responsible Party Timeline Frequency Comments Place Posters and stickers in dormitories Pilot community sensitization through drama shows Lifeline Childline January, 2023 Lifeline Child Line to lead the process and identify at least 4 districts where the pilot exercise could happen Case Management MCDSS GBV-GRM This could Linkages could be with NGOs and other Identify opportunities for linkages with GRM Focal Point happen government institutions throughout the year Training and awareness raising of MCDSS MCDSS and MoE GBV- Before end of April MCDSS to ensure that GRM implementing Adapt MOE training materials for MCDSS GRM Focal Point 30th, 2023 officers are oriented on the training Updated SRGBV action plan and support materials developed by MoE and develop District preparation of Action Plans based on training an Action Plan based on orientation Orientation of officers Awareness raising/sensitization activities on GBV and MCDSS GBV-GRM November - Once per year Participate in community radio shows and SEA/SH prevention and mitigation to SWL and SCT Focal Point December Gender activism will happen in order to beneficiaries and their communities raise awareness on GBV and SEA/SH to Conduct awareness raising for beneficiaries and their commemorate 16 days of Gender activism households upon registration on potential risks for household violence due to increased income, existence of GRM and how to report any such incidences Men are currently involved during LBS Implement ‘BRAC engaging men’ activity Once per year training under SWL Payments MCDSS GBV-GRM This activity is Regular discussions are always held with Ensure payment sites are as close to beneficiaries as Focal Point currently being respective PSPs possible rolled out Introduce electronic payment where possible Discussions to be held on a regular basis Regular meetings to discuss GBV risk with Payment with GBV focal Points with regards to Service providers available and reliable PSPs in communities Revise the MoU with PSPs to include a provision on May, 30th, 2023 Gender 36 Action Responsible Party Timeline Frequency Comments Referral Pathways MCDSS GBV-GRM April 30th, 2023 MCDSS to ensure districts across the Hold orientation meeting for identified service Focal Point country hold engagement meetings at providers at district-level to reach an understanding district level with identified service on the potential coordination required providers on potential coordination GBV-responsive GRM April 30th, 2023 Most of these activities are budgeted in the Expand GRM to all SWL and SCT districts, including: GEWEL GRM except for training of GBV Complaint Boxes mapping exercise for new districts for new Access to the hotline for serious complaints such as SWL and KGS districts GBV, SEA/SH in collaboration with the NGO Lifeline/Childline Zambia Referral of survivors to GBV services through referral pathways Communications to ensure community members are Once this document is agreed the GEWEL aware of how to access and use the GRM GBV-GRM Timeline would need to be Systematic logging of complaints and data revised management Training on GBV principles (including survivor-centric approach) Selection of Community Focal Points Survivor Fund MCDSS GBV-GRM June 15th, 2023 MCDSS to draw lessons from pilot districts Confirm linkages with Survivor Fund and Shelters, etc. Focal Point on the survivor fund Document lessons learned from piloting of Survivor MCDSS to document lessons learned from Fund survivor fund pilot. Savings Groups MCDSS GBV-GRM This activity is All saving groups being formed will not keep Fast track digitization of Savings Boxes Focal Point ongoing money in the saving box Polygamous households MCDSS GBV-GRM This activity is on- Messages are disseminated during the Need for continued sensitization and follow-up Focal Point going enrollment processes of potential meetings beneficiaries on the programme and also 37 Action Responsible Party Timeline Frequency Comments during awareness raising meetings on the SCT Codes of Conduct MCDSS GBV-GRM This activity is MCDSS to ensure identified GBV related Ensure that assessment of any GBV risks is included Focal Point ongoing risks are included in bidding processes for in bidding process for contractors, including service contracts and include a clause on requirement for Codes of Conduct (need further GBV in the MoU with PSPs guidance here) Explore partnership with HR Child-headed households MCDSS GBV-GRM On going MCDSS to ensure that the appointment of Ensure female deputy appointed for child-headed Focal Point female deputies for CHHs is documented in households participating in SCT the revised SCT guidelines Effective monitoring of child-headed households to ensure SCT benefits are received and used appropriately 38 8.2 Annex 2: STAKEHOLDER ENGAGEMENT PLAN Republic of Zambia Gender Division Ministry of Community Development and Social Services Ministry of Education DRAFT Stakeholder Engagement Plan Scaling up Shock Responsive Social Protection in Zambia (P179095) 39 1. INTRODUCTION ......................................................................................................................... 41 1.1 PROJECT BACKGROUND .................................................................................................................. 42 1.2 ESS 10: STAKEHOLDERS ENGAGEMENT AND INFORMATION DISCLOSURE............................................................ 43 1.3 PURPOSE OF THE STAKEHOLDER ENGAGEMENT PLAN (SEP) .......................................................................... 43 2. BRIEF SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES.............................................................. 44 3. STAKEHOLDER IDENTIFICATION AND ANALYSIS ........................................................................................... 45 3.1 PROJECT-AFFECTED PARTIES (PAPS) ................................................................................................... 46 3.2 OTHER INTERESTED PARTIES ............................................................................................................. 46 3.3 DISADVANTAGED OR VULNERABLE GROUPS ............................................................................................ 48 4. STAKEHOLDER ENGAGEMENT PLAN ............................................................................................. 49 5.IMPLEMENTATION ARRANGEMENTS FOR STAKEHOLDER ENGAGEMENT PLAN .......................................................... 52 5.1ROLES AND RESPONSIBILITIES ............................................................................................................ 52 5.2 STAKEHOLDER ENGAGEMENT METHODS................................................................................................ 52 6.INFORMATION DISCLOSURE FOR PROJECT ...................................................................................... 53 6.1ESTIMATED BUDGET FOR SEP ACTIVITIES................................................................................................ 55 7.GRIEVANCE REDRESS MECHANISM ................................................................................................ 56 8.MONITORING AND REPORTING ..................................................................................................... 58 40 ACRONYMS CDA Community Development Assistants CGP Child Grant Program COVID-19 Coronavirus Disease of 2019 CP Cooperating Partner CWAC Community Welfare Assistance Committee DEBS District Education Boards Secretary DPO District Planning Officer ASO Assistant Statistical Officer DM&C Director Monitoring and Compliance DDCC District Development Coordinating Committees DSW Department of Social Welfare ECT Emergency Cash Transfer GBV Gender Based Violence G&C Guidance and Counseling GEWEL Girls’ Education and Women’s Livelihood Project GRM Grievance Redress Mechanism GRZ Government of the Republic of Zambia HQ Headquarters IA Implementing Agency IDA International Development Association KGS Keeping Girls in School M&E Monitoring and Evaluation MCDSS Ministry of Community Development and Social Services MCP Multiple Category Transfer Program MDTF Multi-Donor Trust Fund MIS Management Information System MOF Ministry of Finance MOG Ministry of Gender MOGE Ministry of General Education NGO Non-Government Organization OHS Occupational Health and Safety PAD Project Appraisal Document PEO Provincial Education Office PEO Provincial Education Officer PDO Project Development Objective PIM Project Implementation Manual PIU Project Implementation Unit PPE Personal Protective Equipment PPM Pay Point Manager PSP Payment Service Provider SCT Social Cash Transfer SDR Special Drawing Rights SEA/ SH Sexual Exploitation and Abuse/ Sexual Harassment SRH Sexual and Reproductive Health SWL Supporting Women’s Livelihood UN United Nations UNICEF United Nations Children’s Fund VAC Violence Against Children WB World Bank ZMK Zambian Kwacha 1. Introduction This Stakeholder Engagement Plan (SEP) has been prepared in compliance with the World Bank Environmental and Social Framework (ESF), in particular ESS 1 Assessment and Management of 41 Environmental and Social Risks and Impacts and ESS 10 Stakeholder Engagement and Information Disclosure. Under ESS 1, risks associated with the project have been identified which are likely to have differential impacts on different groups and subsequently appropriate mitigation. ESS 10 recognizes the need for transparent engagement with project stakeholders to ensure wide participation, increase opportunities for project acceptability and provide for citizen participation in the project life span. To this effect, the SEP has been drafted clearly stipulating the process of consultation and disclosure of key project information that will be availed to relevant stakeholders during preparation and implementation of the project. The SEP further provides guidance on the process of stakeholder analysis, how to engage multiple stakeholders including vulnerable groups such as persons living with disability and how to engage in meaningful consultations as well as the process of providing feedback. The SEP is a living document that will be, disclosed prior to project appraisal, periodically updated to highlight changes during project implementation. Its effectiveness will be monitored during project implementation and evaluated towards the close of the project. The project will be monitored by the Project Implementation Unit (PIU) through the Environment and Social focal persons at Provincial and District officials once the project becomes effective. In the interim, the point of contact for the Stakeholder Engagement Program is: Name: Ms. Mainga Kabika Organization: Gender Division, Cabinet Office Email: info@cabinet.gov.zm Telephone: 260211255231 1.1 Project Background The Scaling up Shock Responsive Social Protection in Zambia Project (P179095) will project will build on the existing IDA and multi-donor funded, government flagship social protection project, GEWEL (P151451) and will continue the focus on government’s cash plus social protection approach to support the poorest households in Zambia with cash transfers and layering additional interventions to empower girls from those households to complete their secondary education, and support women in starting their own small businesses. Project Components: The PDO will be achieved through several innovative and systemic interventions through four components. The project comprises the following components and subcomponents: Component 1: Social Cash Transfers (SCT) This component will provide financing to cover cash transfers to the almost 1 million beneficiaries of the government’s SCT program for the period of one year. This component will finance bi-monthly cash transfers to poor and vulnerable households. SCT currently provides a bi-monthly transfer of ZMW 400 (US$24 equivalent, or US$12 monthly) for an average household and double this amount for households with a disabled person. Beneficiaries are selected through categorical as well as poverty targeting to identify people that are poor and also are not able to work for reasons of age, disability, illness, or high dependency ratios. SCT also provides an education grant to households that have one or more KGS girls through the existing SCT payment system. This is to support households cover other costs involved in attending school such as uniforms, books, food, and transport, among others. The value of the grant is currently ZMW 600 (around US$35) per girl per year. This represents 25 percent of the annual cash transfer value for the average household or 12.5 percent of the annual cash transfer for households with a disabled member. Component 2: Contingency Emergency Response Component (CERC) A CERC component will be introduced to respond to current and future shocks. Following an eligible crisis or emergency, the Borrower may request the Bank to re-allocate project funds to support emergency response. This component would draw from the uncommitted credit resources under the project from other project components to cover emergency response. The component will include the design and implementation of a mechanism to scale up the SCT to channel funds to poor and 42 vulnerable households in the case of emergencies, including droughts and food price shocks. MCDSS will be the implementing agency for the CERC and the emergency response will be provided through a vertical and / or horizontal expansion of the SCT, as appropriate29. A CERC manual will be prepared as soon as possible during implementation for readiness to activate if an d when necessary. This manual will form a CERC Annex to the Project Implementation Manual (PIM) and will include the operational, fiduciary and technical details of the CERC. Component 3: Keeping Girls in School (KGS) This component will scale up the government’s KGS initiative to an additional 67 districts and 100,000 beneficiaries to those already supported under GEWEL. Government recently announced the abolishment of tuition, Parent Teacher Association (PTA), and examination fees at the secondary school level in the 2022 budget speech30. While KGS was previously providing bursaries to cover the school fees of secondary school aged girls from the poorest households, it was restructured in February 2022 to focus on the other important barriers to girls’ retention in school. Component 4: Supporting Women’s Livelihoods (SWL) This component will scale up the government’s SWL initiative to an additional 35 districts and 56,000 beneficiaries to those already supported under GEWEL. This will mean countrywide coverage of the KGS and SWL initiatives across Zambia’s 116 districts, in line with the current country wide coverage of the SCT. The project will utilize the existing systems and capacity built by the GEWEL project, including a Grievance Redress Mechanism (GRM) that is functional countrywide, Management Information Systems (MIS) and digital payment systems, among others. 1.2 ESS 10: Stakeholders Engagement and Information Disclosure As per ESS 10: Stakeholders Engagement and Information Disclosure, implementing agencies should 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. To meet best practice approaches, the project will apply the following principles for stakeholder engagement: • Openness and life-cycle approach: public consultations for the project will continue during the whole project lifecycle from preparation through implementation. Stakeholder engagement will be free of manipulation, interface, coercion, and intimidation; • Informed participation and feedback: information will be provided and widely distributed among all stakeholders in an appropriate format; conducted based on timely, relevant, understandable and accessible information related to the project; opportunities provided to raise concerns and assure that stakeholder feedback is taken into consideration during decision making; • Inclusiveness and sensitivity: stakeholder identification is undertaken to support better communications and building effective relationships. The participation process for the project is inclusive and the stakeholders are always encouraged to be involved in the consultation process. Equal access to information is provided to all stakeholders. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods. Special attention is given to vulnerable groups, particularly women headed households, youth, elderly and the cultural sensitivities of diverse ethnic groups. 1.3 Purpose of the Stakeholder Engagement Plan (SEP) 43 Stakeholder engagement is an inclusive process conducted throughout the project life cycle. Where properly designed and implemented, it supports the development of strong, constructive and responsive relationships that are important for successful management of a project environmental and social risks8. Communicating early, often, and clearly with stakeholders helps manage expectations and avoid risks, potential conflict, and project delays.9In addition, the plan assists in managing stakeholder expectations which will have a bearing throughout the lifespan of the project. Further the SEP takes into consideration the different types of stakeholders and describes measures adopted to ensure groups that are differently affected are captured, particularly those identified as vulnerable. Hence, this SEP provides a plan to interact effectively with stakeholders to support project interests. 2. Brief Summary of Previous Stakeholder Engagement Activities The SSRSP, an emergency operation, will build on the Bank’s leading operation in the social protection sector in Zambia, the Girls Education and Women’s Empowerment and Livelihoods (GEWEL) project (P151451). Since commencing implementation in 2015, GEWEL has embedded regular consultations with its various stakeholders into its programming. Stakeholder engagement activities have included Government line ministries; Civil Society Organizations and Non-Governmental Organizations; Political leaders; Civic leaders; Provincial Administration; Districts Administration; Faith Based Organizations; Traditional Leaders; direct beneficiaries and wider community members; and Cooperating Partners. There are a number of regular and needs-based consultation activities that take place, for example, to understand community perception of the project and implementation performance. These usually take the form of a community meeting or Focus Group Discussion during regular Headquarter (HQ) and Provincial monitoring activities. District staff (including DCDO, DSWO and DEBS) are regularly consulted to discuss potential challenges and areas to improve project design. Table 1: List of recent consultations that design takes into account Consultation Description Modality Frequency Impact GEWEL Additional Discussion between Government Workshop September Consolidated decision to Financing and Cooperation Partners to 2019 expand GEWEL to Workshop improve program design GEWEL include support to Social Cash Transfers High level GBV Highlighted the extent of School Workshop December Created the momentum Workshop related gender-based violence as 2021 to begin addressing a problem and the need to begin school related gender- address with Senior based violence in the Management Ministry of Education among senior management Joint Review & Consultation for GEWEL National Bi-Annual Maintained project Implementation government stakeholders as well meetings trajectory to achieve Support Missions as Cooperation Partners to PDO discuss various aspects of program performance SWL Impact Discussed and presented findings Workshop January 2022 Highlighted program Evaluation of SWL Impact Evaluation implementation and Workshop impact gaps in specific areas, including productive grants and training 8 The World Bank (2017), The World Bank Environmental and Social Framework 9 Pollet., T (2014), A Strategic Approach to Early Stakeholder Engagement 44 Brought together governmental Workshop December – Build consensus around SCT Operational representatives to improve PIM January 2022 changing aspects of SCT Guidelines Consultation for frontline implementers so design to facilitate that it is more operational and operational efficiency modular, and provides more clarity on processes and design updates Discussion between Workshop October 2019 Presented preliminary Joint UN government, Cooperation options to improve the Program Consultations Partners and stakeholders on the early warning system to preliminary findings from the better meet information review of the Joint UN Program requirements to enable early and scalable food and cash response. Consultations with all levels of Key December – Resulted in GEWEL MTR Government, Cooperation Information January 2022 identification of areas of Consultations Partners and Districts Interviews, improvement for the Meetings, project and Workshops recommendations for future programming Discussion among working National Monthly Resulted in Technical groups comprised of government Meetings identification of areas of Working Groups and development partner improvement for the experts on specific subject areas project and – education grants, livelihoods, recommendations for payments, shock responsive addressing social protection, gender, GBV, implementation GRM, program management, challenges etc. The highest government Meetings Quarterly Provided policy GEWEL Steering structure in the governance of guidance and high-level Committee the project and discusses policy support to achieve PDO issues affecting the implementation of the GEWEL Project. Engagement on the rollout of the Meetings Quarterly Enhanced the rollout District level GRM and monitoring of GBV and functioning of the GRM and GBV Meetings issues and handling GRM through trouble- shooting and capacity building on GBV referrals 3. Stakeholder Identification and Analysis This stakeholder analysis identifies and determines the likely relationship between the project and its various stakeholders. As there are no new and additional activities to be included under SSRSP, the identified stakeholders under the GEWEL Project and their description remains relevant for this SEP. Stakeholders are those directly or indirectly affected by a project, as well as those who may have interests in a project and/or the ability to influence its outcome, either positively or negatively. Stakeholder analyses help to identify the perceptions, interests, needs, and influence of actors on the project. ESS10 classifies stakeholders in two broad categories: “Project -affected parties� (PAPs) and “other interested parties�. Within these categories, persons or groups may be categorized as especially disadvantaged or vulnerable. 45 3.1 Project-Affected Parties (PAPs) Project-affected Parties (PAPs) are defined as persons, groups and other entities within the project area of influence that are directly influenced (actually or potentially) by the project and/or have been identified as most susceptible to change associated with the project, and who need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures. For the purposes of this Project, affected stakeholders are poor, vulnerable and labor constrained households across Zambia’s 116 districts, and working age women and adolescent girls within those households. They may include the elderly (above 65 years old), severely disabled, chronically ill, child- headed households, female headed households, adolescent girls from SCT households. The SSRSP aims to protect poor and vulnerable households' investment in human capital in response to shocks, increase livelihood diversification for women and secondary school retention for disadvantaged adolescent girls in extremely poor households. Table 2: Affected Stakeholders Stakeholder Description SCT Beneficiaries Members of the ultra-poor and vulnerable households SWL Beneficiaries Female-headed households of ultra-poor and vulnerable households KGS Beneficiaries These are vulnerable girls from extremely poor households (SCT HHs) enrolled on the KGS programme to be supported in secondary school (boarding fees, education grant, and sanitary towels provision) Community members in Members of communities in which the Project is implemented project areas Stakeholders also include wider community members or non-beneficiaries of the project living in the target communities. They also include community members engaged as volunteers or assgined to focal point role to help deliver the Project, for example, see Table 2, below. Table 3: Affected Stakeholders (continued) Stakeholder Description Community Grievance Focal Respected females that receive training and take responsibility for handling Points complaints including serious complaints related to GBV, SEA/SH Community Based Volunteers These are females that provide mentorship support to targeted SWL beneficiaries. They train beneficiaries in Life and Businesses skills and take lead role in supporting SWL beneficiaries with formation of Saving Groups. Community Development These are civil servants that have the responsibility of manning Assistants communities, they supervise CBVs with various tasks Community Welfare Assistant These operate at village level they play critical role of community Committees mobilization SWL Savings Group Treasurers The women keep the savings in their households Social Cash Transfer Pay Point The Pay Point Managers responsible for paying SCT beneficiaries Managers Guidance and Counseling These are female G&C teachers in schools that act as the KGS GRM Focal (G&C) Teachers Point Person FPP in schools and help the girls lodge in complaints. The G&C teachers are the link between the KGS girls in schools and the Community FPP 3.2 Other Interested Parties 46 Other interested parties are defined as individuals/groups/entities that may not experience direct impacts from the project but who consider or perceive their interests as being affected by the project and/or who could affect the project and the process of its implementation. For the purposes of this Project, other interested parties are described as institutions and organizations that will be directly involved in the delivery of the project from national (or HQ), district to community level. At national level, the Gender Division acts at a coordinating institution while MCDSS, MOE implement the Project. At district level, the District Commissioners of the target districts, Members of the council, the executive committee and its sub-committees and nongovernmental organisations working in such districts will be direct interested parties. The traditional leaders, area and village development committees and their subcommittees and community volunteers constitute some of the direct interested parties at community level. Cooperation Partners at national level, representatives of NGOs at district and community level, religious groups and their leaders and communities in areas where the project will be implemented are some of other interested parties. Table 4: Other Interested Parties Stakeholder Description District Local Leadership These may be traditional, religious or political leaders (including ward councilors and Members of parliament) who have influence in the communities where the project is being implemented District Development Coordinating This is a political arm of government at district level and is constituted Committees by elected Councilors, Council Secretary, District Commissioner and Heads of respective government departments District Community Development These civil servants stationed at district level whose main task is to Officers attend to all issues within the district Assistant District Community These civil servants stationed at within communities or in sub-centers Development Officers District Education Boards Secretary These civil servants stationed at district level whose main task is to (DEBs) attend to all issues within the district concerning the KGS girls. The DEBs is the controlling officer of KGS at district level under the Ministry of Education District Planning Officer (DPO) These civil servants stationed at district level whose main task is to attend to all issues within the district concerning the KGS girls. The DPO is the KGS focal; point person at district level under the ministry of education and is in charge of all the enrollments, payments and all KGS activities at district level. Assistant Statistical Officer (ASO) These civil servants stationed at district level whose main task is to attend to all issues within the district concerning the KGS girls. Provide technical support to the implementation of the project The ASO is in charge of entering all the KGS data onto the KGS MIS at district level Provincial Ministry of Education Coordinate implementation of KGS in the province, monitor KGS (Provincial Education Office -PEO) activities in the province, Community sensitization, technical support Provincial Education Officer These civil servants stationed at provincial level whose main task is to attend to all issues within the province concerning the KGS girls Senior Planning Officer These civil servants stationed at provincial level whose main task is to attend to all issues within the province concerning the KGS girls 47 National/HQ level GEWEL Coordinating Committee Direction, guidance on implementation Ministry of Community Houses project implementation unit Development and Social Services -Third Project Component-ISSB housed at the Ministry Gender Division Coordinate implementation of all component of GEWEL including; SWL, KGS and SCT Ministry of Community Coordinate implementation of grant payments with PSPs, Manage MIS Development and Social Welfare for SWL, develop implementation materials and Oversee implementation Community sensitization, technical support and mobilization for project implementation of community development projects. Donors Cooperation partners who co-finance the GEWEL Media May report on impacts of GEWEL to the general public. 3.3 Disadvantaged or Vulnerable Groups Disadvantaged or vulnerable groups are persons who may be disproportionately impacted or further disadvantaged by the projects as compared with any other groups due to their vulnerable status, and that may require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the projects. Although the Project is largely expected to have positive impacts among beneficiary members of the target communities, there is still a possibility of individuals, families and communities being negatively affected by activities of the program. These may come from among the beneficiaries or non- beneficiary members of the target communities. The women and children, the youth, elderly, disabled and chronically ill are often times the most vulnerable because of their limited access to information due to physical, social, cultural and structural barriers within the communities. These categories of people will be particularly targeted with adequate information to understand the nature of project activities and anticipated positive and potential negative impacts of the project. They will also be provided with information on how to access the grievance redress mechanism of the project whenever the need arises. For elderly members of the community that might have mobility challenges when it comes to accessing venues for program activities such as meetings, there will be consideration to organize meetings within manageable distances. Another envisaged challenge is high illiteracy levels in some of the target communities that will make it difficult for beneficiaries to read and understand written information pertaining to the project. Appropriate methods such as public meetings, visual media (posters, billboards, community videos), will be employed to reach out to such groups of people. Hearing challenges (due to age or birth) by some beneficiaries might require use of sign language aides in outreach and visibility tools as well as Public Address systems or megaphones, especially where the meetings attract large crowds of people. Extra effort will be undertaken to reach out to non-beneficiary members of the target communities to make them understand the project targeting processes and capacity limits so that they do not feel disadvantaged. For the purposes of this Project, disadvantaged or vulnerable groups are described below. Table 5: Disadvantage or Vulnerable Groups 48 Stakeholder Description Women in male-headed and May experience GBV/SEAH at home, or in transit to collect payments or female-headed beneficiary attend trainings or meetings. households The elderly May have accessibility challenges Disabled/persons affected by May have accessibility challenges chronic diseases/bedridden Stakeholder Engagement Plan Stakeholder engagement activities need to provide specific stakeholder groups with relevant information and opportunities to voice their views on topics that matter to them. GEWEL and the proposed SSRSP, is a highly interactive program, and beneficiaries have frequent opportunities to interact face to face with program implementers (for example, during transfer pickups, livelihoods training, etc.). Stakeholders are to be kept informed at all stages of the project cycle as the project develops and evolves, including reporting on project environmental and social performance and implementation of the SEP and grievance redress mechanism (GRM). This is important for the wider public, but equally and even more so for targeted women beneficiaries and school going girls. Taking into account the large-scale directly affected population of this national program, the SEP will capture the views of sample communities in: - Existing SCT supported districts - New SWL districts where new caseloads will be targeted - New KGS districts where new caseloads will be targeted The SEP will pay particular attention to especially vulnerable and disadvantaged groups, including the elderly, persons with disabilities, female-headed households, orphans and vulnerable children. Table 6 outlines the consultations scheduled. The Gender Division together with MCDSS and MOE will jointly lead the implementation of the SEP. The purpose of the engagement program for this project is to: • Consult stakeholders on the proposed project design, anticipated environmental and social risks and impacts, mitigation measures, the draft engagement plan and the draft environmental and social risk management instruments; and • Provide regular information and feedback to stakeholders related to project implementation progress and any other emerging issues throughout the project cycle. 49 Table 6: Planned Stakeholder Engagement Activities No. Project Phase Engagement Activity Objective Targeted Stakeholders Time Frame 1 Project National level Collect views on the design of the project, Representatives of Government Ministries, June, 2022 Preparation Stakeholder environmental and social risks, mitigation Departments and Agencies, Development Phase Consultations measures, grievance redress mechanisms Partners, NGOs, CSOs and Stakeholder engagement plan Provincial level Collect views on the design of the project, PDCC members, NGO representatives, June 2022 Consultations environmental and social risks, mitigation representatives for Faith-Based Organization measures, grievance redress mechanisms and Stakeholder Engagement Plan District level Collect views on the design of the project, DDCC members, civic leaders, July 2022 Stakeholder environmental and social risks, mitigation representatives for local NGOs, Consultations measures, grievance redress mechanisms representatives for local FBOs, traditional and Stakeholder Engagement Plan leaders Community level Collect views on the design of the project, Members of target communities, July 2022 Stakeholder environmental and social risks, mitigation local/traditional, religious, and political Consultations measures, grievance redress mechanisms leaders, development sub-committees such and Stakeholder Engagement Plan as CWACs and disadvantaged and vulnerable groups 2 Project Project Inception Provide feedback on approved project design Members of the District Executive July 2022 Implementation meetings with District and orient district level stakeholders on their Committees Phase Councils roles Community Mobilize and prepare target communities for Selected beneficiaries and non-beneficiaries July 2022 mobilization project implementation of project Project Provide and obtain on-going information and National, district, and community level Bi-Annually Implementation support on project performance, to monitor implementers Monitoring and progress on results Supervision Missions Project review Provide and get periodic feedback on project Selected National, District and Community Quarterly meetings with selected implementation progress and any emerging level stakeholders stakeholders from issues National, District and Community level Impact Evaluation To assess program impacts on beneficiaries. Beneficiaries and Implementers at district Every 2 years and community level 50 No. Project Phase Engagement Activity Objective Targeted Stakeholders Time Frame Spot Checks To ensure program operational compliance Beneficiaries and Implementers at district Annual and community level Process Review To assess program compliance and results Beneficiaries and Implementers at district Annual and community level Beneficiary Surveys Obtain feedback on project implementation Selected beneficiaries of project Annual (impacts, experiences, expectations) CSO Platform Obtain feedback on project implementation Zambian civil society Quarterly Social Accountability Obtain feedback on project implementation Selected beneficiaries and implementers Pilot basis with (impacts, experiences, expectations) potential for scale up GRM Review To assess functionality and performance of Beneficiaries and Implementers at district Annual the program’s GRM. and community level 3 Project Close Out Project close out Engage stakeholders on project exit strategy Beneficiary communities and groups, 2025 Phase meetings national and district stakeholders, CSOs 51 4. Implementation Arrangements for Stakeholder Engagement Plan 4.1 Roles and Responsibilities The Stakeholder Engagement activities will form part of the Environmental and Social Commitment Plan (ESCP). This is a tool which will commit Management to ensuring that planned activities are implemented and form part of project approval documents which will be monitored by the World Bank. The monitoring and evaluation framework for the project will also have indicators on the ESCP whose implementation progress will be tracked and reported accordingly. ESCP Implementation progress report will be periodically produced and shared with stakeholders for review, deliberation and action. With the Gender Division playing a coordinating role, the MCDSS and MOE are responsible for SSRSP’s day-to-day program management, including environmental and social management and addressing potential environmental and social risks. Gender Division together with MCDSS and MOE will be responsible for engaging with stakeholders and managing the program’s GRM and implementation of SEP. To implement the various activities envisaged in the SEP, the roles of the GRM and GBV Focal Points in Gender Division, MCDSS and MOE for GEWEL will be expanded to include Stakeholder Engagement under the SSRSP. Focal Points will need to closely coordinate with other key stakeholders, including other government agencies, CSOs and PAPs. Focal Points will make use of the Project’s decentralized government structures at District and Community level to implement the SEP. Specifically, they will be responsible for: planning and implementation of SEP in coordination with other relevant agencies, manage and implement the GRM, coordinate and supervise activities, monitor and report on social performance to GoZ and World Bank, monitor management, resolution, and reporting of grievances. 5.2 Stakeholder Engagement Methods Public/community meetings Project launch meetings for national stakeholders will take place followed by similar meetings at provincial and district level. At the community level, districts will organize community gatherings to disclose relevant project information including information on targeting, environment and social impacts and the GRM. These events are scheduled to commence in June-July. Communication materials Written information will be disclosed to the public through a variety of communications materials, including brochures, flyers, posters, and on Government websites. They will be updated regularly with key project updates and reports on the project’s performance. The website will also provide information about the grievance mechanism for the project’s GRM. Surveys Relevant implementing agencies with support of GRM/Stakeholder Engagement Focal Points will organize a number of surveys to assess the quality of program implementation. These will include: Impact Assessments, Process Reviews, Beneficiary Surveys, etc. Grievance Redress Mechanism In compliance with the World Bank’s ESS10, the project- specific grievance mechanism that was established for GEWEL will be extended to cover SSRSP to handle complaints and issues, including GBV referrals. Detailed communications materials (specifically a GRM brochure or pamphlet) have been 52 developed to help PAPs become familiar with the grievance redress channels and procedures. A GRM module has already been established and is functional in across the country for GRM to enable accurate capture and tracking of grievances from submission to resolution and communication with complainants. Training, workshops Trainings on a variety of topics and issues will be provided to relevant government service providers. Issues covered will include sensitization to targeting, PIM, environment and social risk management, livelihoods, FM, labor issues, gender, case management, GRM, etc. Reviews Program biannual review meetings will be organized to provide and collect periodic feedback on project implementation progress and identify and discuss new and emerging issues. A focus on incorporating the views of Vulnerable Groups Appropriate and clear methods of communication will be used to inform in a timely manner, all participants about the meetings. This will include invitation letters where possible, stipulating the type and number of community stakeholder groups expected to come to the meetings. Where possible and necessary, separate consultations will be done with select interest groups during community meetings. The community meetings will be properly facilitated using a pre-designed discussion guide which will carry specific questions targeting vulnerable groups. Well experienced moderators will be used to conduct community meetings to ensure equitable participation and contribution of marginalized groups. The facilitating teams will have skilled note takers who will record the deliberations verbatim with the aid of voice recorders. Consent (verbal) or and otherwise, will be sought from meeting participants before recorders are used in recording of proceedings. After completion of consultations, the field notes and transcriptions will be consolidated, analyzed and key issues incorporated into the relevant project documents. Information Disclosure for Project Disclosing project information is essential for meaningful consultation on project design and for stakeholders to understand the potential opportunities of the project as well as its risks and impacts. Appropriate information will be provided to stakeholders depending on the stage of the project and the identified stakeholder information needs. This will include information on the nature of the project design, the anticipated environmental and social risks and impacts, the proposed mitigation measures, the stakeholder engagement plan, grievance redress mechanisms and how stakeholder views were incorporated in the project design and management of environmental and social risks. The Project will use a combination of methods to disclose information pertaining to the project in a manner that is commensurate with the nature of the identified stakeholders and environmental and social sensitivity of the project. For community level stakeholders, information will mostly be disclosed through public meetings organized within the communities. Deliberate efforts will be made to ensure that vulnerable groups of people such as women and school going children, the elderly and disabled are adequately represented and heard in such meetings. At national and district level, disclosure of information will be done through meetings with the representatives and heads of government departments. DDCC meetings, through printed and electronic copies of relevant project documents will be made available to stakeholders through appropriately designated places within reach of stakeholders, including government websites. 53 Communication to stakeholders on information disclosure programmes will be conveyed through relevant means depending on targeted audiences. Mostly, the project will use written forms of communication such as letters and electronic mails, community radio stations where available, and mobile public address system (ZANIS). Where possible social media platforms and groups will be created to assist in information dissemination to targeted stakeholders. All these processes, platforms, and channels will be linked to the GD. MCDSS and MoE Websites. Table 7 summarizes the key methods that will be used for disclosure of Project information at different stages of the Project. Table 7 provides information on other means of project disclosure. Table 7: Information Disclosure When With Frequency and Channels of Engagement Purpose Current Status whom timing Engagement methods Project National- After approval In-person Stakeholder Share information Approx. 90% of preparation Gender by the World consultation meetings, on project Design GEWEL stage Division, Bank meetings, round virtual summary, implementing MCDSS, table stakeholder meetings, Stakeholder communities MOE and meetings, virtual emails and Engagement Plan, reached other meetings letters Environmental and relevant Social Commitment government Plan, Grievance Ministries, Redress Department Mechanism setup s and After approval Community and Community and Share information Agencies by the World National Radio National Radio on project Design and NGOs. Bank station brochures station summary, and leaflets, brochures and Stakeholder leaflets Engagement Plan, Environmental and Social Commitment Plan, Grievance Redress Mechanism setup Through printed Electronic Make available and electronic media, DDCC printed and copies at National, meetings electronic copies at and District level National, and focal offices as well District level focal as online portals offices as well as online portals Project Districts- Review Community Members of Share project implementa Local Meetings meetings, public target activity and tion Councils; Community address systems, communities in progress updates radios, national radio phone-in target districts Management Community- radios, banners, programmes, Grievance Redress Project newspaper Information Mechanism affected placements, leaflets, posters persons; etc., and brochures; vulnerable audio-visual groups and materials, MCDSS local Websites; Press populations releases in the local media; and meetings 54 When With Frequency and Channels of Engagement Purpose Current Status whom timing Engagement methods Project National- In-person Project Completion Closure Gender consultation and evaluation Division, meetings, round Report MCDSS, table stakeholder Exit Strategy MOE and meetings, virtual other meetings relevant Community government meetings, Ministries, Information Department leaflets, MCDSS s and Websites; Press Agencies releases in the and NGOs. local media 4.2 Estimated Budget for SEP activities The GRM/Stakeholder Engagement Focal Points in Gender Division, MCDSS and MOE will be responsible for planning and implementation of stakeholder engagement activities, as well as other relevant outreach and disclosure activities. In order to ensure successful SEP implementation, a series of activities are necessary for which the project has to provide adequate funding. The Stakeholder Engagement activities so far mentioned may be part of other project documents, so it is possible that they have also been budgeted for in other plans. As such a tentative budget for the project’s activities is reflected in Table 8. This table will be updated to include all stakeholder activities, including workshops, trainings, and program review and monitoring activities. Table 8: SEP Activities – Estimated Budget (5 years) No. Project Engagement Objective Targeted Stakeholders Budget USD Phase Activity 1 Project Project Provide feedback on Members of the District 50,000 Implementat inception approved project design Executive Committees ion Phase meetings with and orient district level District stakeholders on their Councils roles Community Mobilize and prepare Members of target 80,000 mobilization target communities for communities, CWACs, project implementation traditional, religious and political leaders, beneficiaries, etc. Manage the Provide a systematic way Project Affected People at 500,000 Grievance of receiving, recording community, District and Redress and resolving grievances National levels Mechanism from Project Affected Persons (PAPs) Project Provide and obtain on National, district, and 200,000 implementatio going information and community level n monitoring support on project stakeholders performance 55 No. Project Engagement Objective Targeted Stakeholders Budget USD Phase Activity and supervision missions Project review Provide and get periodic Selected National, District 100,000 meetings with feedback on project and Community level selected implementation progress stakeholders stakeholders and any emerging issues from National, District and Community level 2 Project Close Project close Engage stakeholders on Beneficiary communities 25,000 Out Phase out meetings project exit strategy and groups, national and district stakeholders 3 Project Communicatio Engage beneficiaries and Communities, district and 300,000 Implementat n and implementers and national level stakeholders ion Phase Information – document progress. visibility and Disseminate to achieve documentation visibility through systematic outreach activities TOTAL 1,255,000 5. Grievance Redress Mechanism The Girls Education and Women’s Empowerment and Livelihood project (GEWEL) is a flagship intervention which aims to support the Government of the Republic of Zambia (GRZ) to increase access to livelihood support for women and access to secondary education for disadvantaged adolescent girls in extremely poor households in selected districts. The original (‘parent’) GEWEL project was funded by International Development Assistance (IDA) in the amount of US$ 65 million. The project was approved in May 2015, became effective in April 2016 and closed on September 30, 2020. An Additional Financing (AF) agreement for the GEWEL project was negotiated and effected on 1st August 2020. The GEWEL AF aimed to deepen the human capital impacts of GEWEL by expanding coverage and providing more complementary support to poor women through provision of one-off grants, meeting school needs for school going girls in secondary education and paying cash transfers to extremely vulnerable households. While considerable effort and forethought has been made to include safeguards in the design and implementation of the project in order to minimize and prevent potential adverse impacts from the project, there is always a possibility that interests of some individuals and groups may still be negatively affected by activities of the project. It is therefore expected that such instances may generate complaints from some community members and school going children. As such, provision of a mechanism for receiving, recording and resolving potential concerns and complaints that may arise from Project affected persons is necessary. Such a mechanism would assist to provide early remedies to grievances so as to avoid unnecessary project implementation delays and obstructions. A Grievance Redress Mechanism is a system through which queries or clarifications about the GEWEL project are responded to, problems that arise out of implementation are resolved, and grievances are addressed efficiently and effectively. The objective of the GRM is to satisfactorily address complaints (grievances) from beneficiaries and non-beneficiaries of the GEWEL program. The goals of the GRM are to ensure people use the system, staff understand what is going well or poorly with program design and implementation, and communication messages around the GRM are tested and improved. 56 A GRM is an accessible and inclusive system, process, or procedure that receives and acts upon complaints and suggestions for improvement in a timely fashion and facilitates resolution of concerns and grievances arising in connection with a project. An effective GRM provides project-affected parties with redress and helps address issues at an early stage. The three Ministries which form part of GEWEL have each designated one Grievance Focal Person at the HQ level. Each District has also identified two Grievance Focal Persons in the Community/Social Welfare Developments and two in the District Education Board. MOG Grievance Focal Persons are responsible for monthly high-level monitoring and production of a Monthly Monitoring Report. At the HQ level, Grievance Focal Persons are responsible for weekly monitoring of the Grievance MIS Module, providing responses to complex or serious complaints which cannot be resolved at the district-level. At District level, Grievance Focal Persons are responsible for collecting forms, logging them in the Grievance MIS Modules, determining the appropriate responses (per guidelines), and delivering the responses to complainants. At community level, selected female Community Grievance Focal Points takes charge of the box and ensuring forms are always available. The FPs also supports the District Grievance Focal Persons in delivery of response letters. Channels through which complaint forms are lodged Channel 1: Complaint Box Complaint Forms are available near locked Complaint Boxes in a location chosen by the GEWEL beneficiaries during the first sensitization meeting about the GRM. Complainant fills out the Complaint Form, tears off the bottom portion (so the complainant keeps a record of their Complaint Number) and puts the rest of the form in the Complaint Box. Complaint Forms are also available with Community Grievance Focal Persons or through Guidance and Counseling Teachers in schools. Forms are collected by District Grievance Focal Person every month (delivering responses to complaints collected previously). If Community Grievance Focal Person receives a serious complaint, they immediately call it into District Grievance Focal Person. Channel 2: Community Grievance Focal Person The female focal point will be GEWEL beneficiaries and endorsed by community. These will always be women. They will be rresponsible for the Complaint Boxes and ensuring complaint forms are available. They will work closely with district staff on complaints related to GBV, SEA/SH, they will also ccontact district if forms are running low and assist beneficiaries to fill out Complaint Forms or receive complaints verbally. One requirement on which these women shall be selected is owning a phone. Channel 3: Telephone Hotline for Serious Complaints A telephone hotline for serious complaints, such as GBV has been set up in collaboration with an NGO (Childline Zambia). Childline is an existing national hotline for GBV + HIV + other child protection related issues. Any child can call the toll-free hotline (#933 or #116) to: Receive counselling over the phone or Referral to appropriate services in their District. GEWEL will collaborate with Childline to ensure awareness of their service in KGS districts and to receive reporting from Childline on cases reported in all 116 districts in the country. Steps to Register Complaints • Step 1: Lodging complaints complaints can be received in writing via Complaint Forms. They can also be made verbally to GEWEL FPs, Staff or Guidance and Counselling Teachers. FPs can fill out a Complaint Form on behalf of the complainant • Step 2: Recording Complaints in Grievance MIS Module Once back at District headquarters, the Grievance Focal Persons review the forms and divide them according to which program they relate to. Complaints for SWL will be given to the SWL GRM Focal Person, for KGS they will go the KGS, SCT complaints will go to SCT Focal Person GRM Focal Person, 57 and complaints for any other program are referred to the appropriate District-level authority Each Grievance Focal Person processes their respective complaints into the GRM MIS Module and generate response which they take back to the community. • Step 3. For each complaint, the District Grievance Focal Person should consult the Complaint Categories and Responses section. The majority of complaints will require no further investigation. For complaints which can be addressed at District level (e.g., CBV showing up late), the district-level staff should take appropriate action according to Ministry or GEWEL program rules and standards. For complaints requiring HQ action (e.g., payments), the District Grievance Focal Person should contact HQ to request investigation and resolution. It is the responsibility of the district to regularly follow up with HQ on any pending responses required to resolve a complaint. District to send notification to HQ-level Grievance Focal Persons on all serious complaints (serious complaints will be resolved jointly with HQ). • Step 4: Resolving Complaints & Issuing Responses to Complaints Once a response has been determined for a complaint, the District Grievance Focal Person should process the complaint in the MIS Module and issue a response. Response letters should be delivered back to complainants in CWACs at least once per month when the District Grievance Focal Person goes to collect the Complaint Forms from the boxes. When complaints are referred to other programs (e.g., Health), the GEWEL team should refer the complaint to the respective government institution for further processing. For complaints where there is a contact phone number, a phone call may be used to deliver the initial response on the complaint. However, the letter must always follow the phone call at a later date as well. Gender Based Violence Cases Since Gender Based Violence (GBV) and Sexual Exploitation and Abuse cases are substantively different from other complaints that are typically handled through the grievance redress mechanisms, their information will be handled in a special way within the GRM to ensure that the information is confidential. The GRM committees will be oriented on how to approach survivors and make referrals. Serious complaints raised through the GRM, including GBV cases are addressed immediately by referring GBV survivors to support services within the national GBV Referral Pathway. Additionally, FPs help link GBV survivors to services and support. When services are not available in the community, the Community and District Grievance Focal Person Persons work together with HQ to ensure that GBV survivors receive the support needed and follow up on cases. Information collected is kept to a minimum so as to avoid the potential for the survivor to be identified. Only the following elements related to a GBV allegation should be recorded: Age and sex of the survivor. Type of alleged incident (as reported, in the survivors’ own words) Whether alleged perpetrator is, to the best of the survivor’s knowledge, part of GEWEL Whether survivor was referred to service provision. Additional information is normally gathered by the service providers using their existing survivor support protocols. Service providers will have their own internal reporting and case management system, where the detailed information on the case will be stored. This information shall be confidential and not part of the GEWEL GRM process. GRM monitoring and evaluation is undertaken alongside any other evaluation exercises for the project. This is possible using the GRM Monitoring Tool which is populated every quarter by district level staff. Monitoring is also done in the GEWEL MIS Module where all complaints are processed, resolved and copies stored. 6. Monitoring and Reporting The Stakeholder Engagement Plan will be periodically revised and updated as necessary in the course of SSRSP Project implementation to ensure that the information presented herein is consistent, and that the identified methods of engagement remain appropriate and effective in relation to the project 58 context. Any major changes to the project related activities and to its schedule will be duly reflected in the SEP. Biannual summaries and internal reports on public grievances, enquiries, and related incidents, together with the status of implementation of associated corrective/preventative actions will be collated by responsible staff and referred SSRSP’s senior management. The summaries will provide a mechanism for assessing both the number and the nature of complaints and requests for information, along with the Project’s ability to address those in a timely and effective manner. Information on public engagement activities undertaken by the project during the year may be conveyed to stakeholders in two possible ways: • Publication of a standalone annual report on project’s interaction with the stakeholders GRM and Stakeholder Engagement Focal Points will maintain a Stakeholder Engagement Log that chronicles all stakeholder engagement undertaken or planned. The Engagement Log includes location and dates of meetings, workshops, and discussions, and a description of the project-affected parties and other stakeholders consulted. The Project will also develop an evaluation form to assess the effectiveness of formal engagement process. The questions will be designed as appropriate for the relevant audience. • Quarterly Narrative Reports will include reporting on Stakeholder Engagement including inclusion of new section on engagement and how feedback is being processed. • A number of Key Performance Indicators (KPIs) will also be monitored by the project on a regular basis, including the following parameters: o Number of public consultations held by districts o Number of communications materials on beneficiary rights developed and disseminated to beneficiaries o Number of press materials published/broadcasted in the local, regional, and national media Stakeholder Engagement progress will become a standing Agenda on Steering Committee and monthly Technical Committee meetings Standing Agenda of GEWEL Steering Committee and monthly Technical Committee Meetings 59 8.3 Annex 3: GRIEVANCE REDRESS MECHANISM GEWEL GRM Manual - FINAL.pdf 60 8.4 Annex 4: SECURITY MANAGEMENT PLAN SECURITY MANAGEMENT PLAN Table of Contents ANNEX 4: SECURITY MANAGEMENT PLAN .................................................................... 61 ABBREVIATIONS ............................................................................................................................. 62 1.OBJECTIVE OF THE SECURITY MANAGEMENT PLAN (SMP) .................................................................... 63 1A) SECURITY APPROACH ......................................................................................................... 63 2. OVERVIEW OF THE SECURITY SITUATION........................................................................................... 63 3. SECURITY MANAGEMENT PLAN...................................................................................................... 65 4. SECURITY MANAGEMENT ............................................................................................................. 70 5. INCIDENCE REPORTING................................................................................................................. 70 61 Abbreviations SSRSP Scaling Up Shock Responsive Social Protection in Zambia SCT Social Cash Transfer SMP Security Management Plan GEWEL Girls Education and Women’s Empowerment and Livelihoods ZISPIS Zambia Integrated Social Protection Information System PPMs Paypoint Managers OHS Occupational Health and Safety DSWO Department of Social Welfare Offic CWAC Community Welfare Assistance Committe 62 1.Objective of the Security Management Plan (SMP) To provide and maintain a safe physical environment and manage staff activities to reduce the risk of personal injury and property loss during the implementation of the Scaling Up Shock Responsive Social Protection in Zambia (SSRSP) Social Cash Transfer (SCT) component. The plan describes how security will be organized to face identified threats and how to be continuously reassessed and reorganized in correlation with security situations and operations being undertaken. The SMP covers sub-project activities relating social cash transfers in the Social Cash Transfer (SCT), Keeping Girls in School (KGS), Supporting Women’s Livelihoods (SWL) and the Contingency Emergency Response (CERC) components. 1a) Security Approach The SSRSP SCT PIU will ensure that security procedures and criteria are fully designed and updated, and the means fully available to ensure the security for project operations. It will also leverage in using the existing national and local security infrastructure to access and share security related information. In addition, and working with the National Police Service, the DSWO will specifically identify and address security risks in the community engagement activities that can pose a threat to Project staff, mainly Paypoint Managers (PPMs) engaged in cash disbursement activities. The PPMs will inform the nearest police officers for support in case of any emerging security threats they cannot handle. 2. Overview of the Security Situation There is potential Occupational Health and Safety (OHS) risks associated with the Social Cash Transfer (SCTs) method of payment, mainly PPMs carrying substantial amounts of cash being vulnerable to theft and physical harm. This security risk has been rated as moderate in terms of likelihood and consequences. The table below shows a risk assessment matrix which works by selecting the appropriate consequences from across the bottom, and then cross referencing against the row containing the likelihood, to read off the estimated risk rating. 63 Table 3: Risk Matrix Impact Negligible Minor Moderate Significant Severe Very likely Low med Medium Medium High high High Likelihood Likely Low Low med Medium Med High High Possible Low Low med Medium Med High Med High Unlikely Low Low med Low Medium Medium Med High 64 3. Security Management Plan Table 4: Risk Identification and Management Risk Issue Specific Risk Description Mitigation Responsibility Banking PPMs being observed making a large SCT ✓ Keep information/knowledge about cash withdraws PPM funds withdrawal when using main ahead of payment days limited to a minimum number District Social banking hall of people. Welfare Officer ✓ All banking transactions should take place away from (DSWO) the main banking hall (i.e. branch managers office or other) ✓ PPMs should vary the time of day of bank withdrawals so movements and cash transfer patterns cannot be predicted. ✓ In an event that PPM suspects they are being followed, immediately report to the nearest police station. ✓ DSWOs expected to establish a collaborative working relationship with the bank manager to ensure he/she understands the nature of the withdrawals and importance of providing discreet service. 65 ✓ PPMs to use secure security bags or unmarked bags/containers to carry cash and do not draw attention to them. Bags should be opaque. ✓ The PPM should not be carrying funds that exceed the maximum unless necessary, and in this case a second PPM should be mobilized ✓ Banks having insufficient SCT funds for PPM PPMs to make a withdrawal in one day ✓ If PPM finds that the standards are not met or feels DSWO unsafe, they should communicate with their manager/DSWO immediately. Travel PPM staying overnight in a lodge with large ✓ PPM should withdraw a maximum of K60.000.00 at any sum of SCT funds one time and never travel with more than this amount. ✓ Lodges should be considered to be “safe� in line with minimum security standards: • Night guard, • Availability of a safe • Secure locks on rooms Long distances to be travelled with SCT If a PPM feels vulnerable during travel with funds, a DSW funds, by own means. vehicle should be made available. Should a DSW vehicle not 66 be available, consider hiring a vehicle or taxi, with an approved driver based on Driver Approval Guidelines. In the case that more than the maximum amount is required, a deputy PPM may be employed, or staggered payment system introduced to that area. Where possible, the PPM should vary the route being taken to and from the bank. Lack of security when travelling with SCT Avoid public transport and/or travel on foot or bicycle. funds. Where practical and the security situation dictates, the DSW vehicle should be made available for the PPM. Vehicle assignment should be prioritized for communities which: • PPMs are female • Substantial physical threats • Remote or hard-to-reach. Poor infrastructure making travel difficult, SCT payments should be planned to take this into particularly in the rainy season. consideration, by making more frequent payments ahead of the rainy season. Avoid allowing payments to accumulate in the case that communities become inaccessible during rainy season. 67 Safe storage Lack of a secure location within community All SCT funds shall be kept in a secure location (i.e. safe or DSWO to store money (No safe) strong room) immediately upon arrival at community level and should never be kept in private residences. Should a “secure� lodge not be identified, an alternative safe storage location shall be identified, such as a police post or other Government facility. A Serviceability Audit shall be conducted on all strong rooms and safes to ensure that they are in good working order and/or identify where upgrades or maintenance work is needed. Should beneficiaries not be available to collect their transfer after 3 days of being notified; funds should be returned to the bank. Safe location storage, key management Lodges should be considered to be “safe� in line with the following minimum-security standards: ✓ Night guard, ✓ Availability of a safe ✓ Secure locks on rooms Communication Notifying Community Welfare Assistance Liaise with CWAC members only when it is time to PPMs Committees (CWAC) and beneficiaries of commence payments. DSWO pending distribution 68 PPMs should not talk publicly about their role or movements to community members. Response to an incident PPMs shall be issued with a list of numbers for key security personnel for them to contact in the event of an incident, or if they feel at risk when carrying SCT funds. Guidelines on Incident Reporting Protocols shall be put in place. 69 4. Security Management This shall entail some of the key operating procedures which will comprise of: • Discreet Services: District Social Welfare Officers are expected to establish a working relationship with the bank manager to ensure he/she understands the nature of the withdrawals and importance of providing discreet service. • Maximum withdrawal: PPM should withdraw a maximum of K60.000.00 at any one time and never travel with more than this amount. In the case that more than the maximum amount is required, a deputy PPM may be employed. • Accommodation: DSWOs to implement certification protocol for lodges. • Safe storage: Should a “secure� lodge not be identified, an alternative safe storage location shall be identified through a Serviceability audit, such as a police post or other Government facility. • Travel: PPMs to avoid public transport and/or travel on foot or bicycle. DSWO to approve drivers in line with Drivers’ Approval Guidelines. PPMs to vary route to and from the bank and time of the day for banking withdrawals. • PPMs to use security bags or unmarked bags/ containers to carry cash. • Distribution Point: 1-2 CWAC members to accompany PPMs and be present during cash distribution. • Communication: PPM to always alert the bank of expected arrival time. PPM to inform another staff member of expected return time or expected time to deposit the cash in the secure location (i.e. school/clinic safe or strong room) to avoid closure of the school or clinic before PPM arrives. 5. Incidence Reporting • PPMs shall be issued with a list of numbers for key security personnel to contact in the event of an incident, or if they feel at risk when carrying SCT funds. 1. Immediately raise any security concerns that you have to the Police or your manager. 2. If you are attacked/ robbed immediately report the crime to the nearest police. All incidents including robberies, attempted thefts, attempted break-ins, must be reported to the police and DSWO and should be recorded in an occurrence book. The Police with support of the DSWO, will initiate an investigation to determine sequence of events, what may have contributed to the incident, probable cause (s) and contributing factors),and recommendations, corrective actions, and 70 mitigation measures (based on investigative findings). An incident report will be issued to the Project Coordinator with details of the above actions. 71 Annex 5: LABOUR MANAGEMENT PROCEDURES 72 LABOUR MANAGEMENT PROCEDURES Abbreviations ACC Area Coordinating Committees COVID-19 Corona Virus Disease 2019 CWAC Community Welfare Assistance Committees DSW Department of Social Welfare DSWO District Social Welfare Office DWAC District Welfare Assistance Committee ESF Environmental and Social Framework ESS Environmental and Social Standard GBV Gender Based Violence GEWEL Girls Education and Women’s Empowerment and Livelihoods KGS Keeping Girls in School LMP Labour Management Procedures MCDSS Ministry of Community Development and Social Services MoE Ministry of Education OHS Occupational Health and Safety PIU Project Implementation Unit PPM Pay Point Managers PSWO Provincial Social Welfare Office SCT Social Cash Transfer SEA-H Sexual Exploitation, Abuse and Harassment SWL Supporting Women’s Livelihoods 73 Table of Contents ANNEX : LABOUR MANAGEMENT PROCEDURES .......................................................................... 73 1.0 INTRODUCTION .................................................................................................................... 75 1.1 OVERVIEW OF LABOUR USE ON THE PROJECT ................................................................................ 75 2.0 ASSESSMENT OF KEY POTENTIAL LABOR RISKS ....................................................................... 76 3.0 BRIEF OVERVIEW OF LABOR LEGISLATION: TERMS AND CONDITIONS...................................... 77 4.0 BRIEF OVERVIEW OF LABOR LEGISLATION: OCCUPATIONAL HEALTH AND SAFETY (OHS) .......... 79 5.0 RESPONSIBLE STAFF .............................................................................................................. 79 6.0 POLICIES AND PROCEDURES .................................................................................................. 81 SECTION 7: AGE OF EMPLOYMENT .............................................................................................. 82 SECTION 8: TERMS AND CONDITIONS .......................................................................................... 82 9.0 GRIEVANCE MECHANISM ...................................................................................................... 82 10.0 CONTRACTOR MANAGEMENT ............................................................................................. 83 11.0 COMMUNITY WORKERS/ VOLUNTEERS ............................................................................... 83 74 1.0 INTRODUCTION The Scaling Up Shock Responsive Social Protection (SSRSP) (P179095) is being prepared under the World Bank’s Environmental and Social Framework (ESF). The project aims to alleviate the negative impacts of the multiple crises Zambia has faced on household income and food security. The project builds on the Girls Education and Women’s Empowerment and Livelihoods (GEWEL) project (P151451), one of the main social protection programmes in Zambia. Under the Environmental and Social Standard 2 (ESS2) on Labour and Working Conditions, the project is required to develop Labour Management Procedures (LMP) to identify the main labour requirements and risks associated with the project and help the borrower to determine the resources necessary to address project labour issues and in doing so, promote sound worker-management relationships and enhance the development benefits of a project by treating workers fairly and providing safe and healthy working conditions. LMP is a living document and may be adjusted as the project advances and as new categories of workers become involved in the various activities. 1.1 OVERVIEW OF LABOUR USE ON THE PROJECT ESS2 categorizes project workers into direct workers; contracted workers; and community workers. The labour category of direct workers will be government civil servants, from the Ministry of Community Development and Social Services (MCDSS), Ministry of Education (MoE) and the Gender Division at the national, provincial and district levels. All civil servants are Zambian nationals and will remain governed by the Employment Code Act no. 3 of 2019, the Industrial and Labour Relations Act, Chapter 269 of the Laws of Zambia, Public Service Regulations and Human Resources Manuals. ESS2 will therefore not apply to government civil servants, except for the provisions of paragraphs 17 to 20 (Protecting the Work Force) and paragraphs 24 to 30 (Occupational Health and Safety), which fall under the provisions for workers' safety, as provided for in ESS 2. 1. Direct Workers: The project will engage the following key categories of workers as “direct workers�: Civil Servants: Project Implementation Units (PIUs) have been set up and will be maintained throughout the project implementation. These are in the MCDSS, under the Department of Community Development and the Directorate of Social Welfare where there are 11 project staff and 25 project staff respectively, and in the Ministry of Education under the Department of Planning and Information where there are 10 project staff. The project staff have been directly contracted for various positions at least for a period of two years and the contracts are renewable upon job satisfaction. The job skills and experiences among the workers in the PIUs ranges from: programme coordination; programme management and implementation; financial management; data and information management; systems development; planning, monitoring and evaluation; grievances/PSEA/GBV management; gender and communication; case management; procurement and logistics; social cash transfer payments; and environmental and social safeguards among other relevant skills. Each of the implementing ministries is responsible and accountable for implementation of their component and activities, with the Permanent Secretary as the controlling officer. Each PIU shall be responsible for overall coordination and strategic guidance as well as oversight in all functions. The PIUs will be supported by the Provincial offices responsible for planning, quality control, training, budgeting and budget review; financial and progress reporting as well as oversight on district reporting and sensitization and capacity building activities at provincial level. District offices will oversee the day-to-day implementation, administration, financial management, procurement, monitoring and evaluation of Project with the assistance of Area Coordinating Committees (ACC) with responsibilities 75 of monitoring and coordinating Community Welfare Assistance Committees (CWAC) and as further detailed in the Project implementation Manual. 2. Community Workers: these will be community volunteers through community structures including CWACs working in communities where the Social Cash Transfer (SCT) is implemented. Some direct workers working as civil servants have volunteered their time to serve the community as Pay Point Managers (PPMs) who pay beneficiaries on behalf of MCDSS. CWACs are community- level structures with members elected by the communities. Their labour will be provided on a voluntary basis with records of the election process, and the specific project activities in which the community volunteers will be engaged. There are 87,776 community volunteers and 4,400 individual public service workers serving as PPMs at national level that are supporting MCDSS on the project. 2.0 ASSESSMENT OF KEY POTENTIAL LABOR RISKS Key Labour Risks Potential risks related to labour and working conditions include: Occupational Health and Safety (OHS) risks, Gender-based violence and/or sexual exploitation, abuse, and harassment (GBV/SEA-H) and risk of transmission of HIV/AIDS. The PIU will assess and address these risks by developing recruitment guidelines, procedures and appropriate OHS measures and applying relevant provisions of the Employment Act No. 3 of 2019, public service regulations and HR manual. In addition, the PIU will coordinate the training of all workers engaged in project activities, on the guidelines and protocols on how to protect themselves and the communities from the spread of COVID-19. The following are key labour risks anticipated during the implementation of the project: a) Occupational Health and Safety (OHS) risks: There are risks related to transmission of the COVID- 19 for all project direct workers, including community worker volunteers, engaged in project activities. The COVID-19-specific risks associated with the SCT relate to the possibility of both beneficiaries, project staff and volunteers contracting the disease through face-to-face interaction that would emanate from activities such as community engagement, targeting and payment, if the necessary preventive and mitigation strategies are not implemented. Covid-19 related risk will be managed through: Continuation and strengthening of the GEWEL Covid- 19 mitigation measures for project activities which include, (i) promoting social distancing and enhanced hygiene; and (ii) increased Personal Protective Equipment (PPE) such as facemasks, washbasins and soap, etc (iii) encouraging frequent handwashing or disinfection with an alcohol-based hand sanitizer (iv) physical distance of at least 2 meter (v) regular environmental cleaning and disinfections of project locations (schools, offices etc) (vi) use of digital payment methods for SCT activities to reduce face to face contact (vii) ensuring that policies, training, messaging and education in all project related areas are increased to improve awareness of Covid-19 and (viii) management of people with Covid-19 or their contacts e.g. through requiring project related staff, workers and participants who are unwell or who develop symptoms to stay at home, self-isolate and contact a medical professional or the local Covid-19 information line for advice on testing and referral. The project will also identify and provide resources necessary for online platforms that can be used instead of face-to-face meetings (i.e., Zoom, WhatsApp, SMS, and Skype) as well as retain the names and contact details of all meetings’ participants for at least one month. This will help public health authorities trace people who may have been exposed to Covid-19 if one or more participants become ill shortly after the event. 76 b) Child labour: Although the risk of child labour is minimal (given the recruitment criteria for all government jobs are persons above 18 years), the risk may emerge through the community labour. c) Forced labour: Forced labour risk is unlikely as the project will work mainly with MoE staff. However, there may be risks related to use of community worker volunteers. d) Labour disputes over terms and conditions of employment. Likely cause for labour disputes includes demand for limited employment opportunities; labour wages/rates and delays of payment; disagreement over working conditions (particularly overtime payments and adequate rest breaks); and health and safety concerns in the work environment. Further, there is a risk that employers may retaliate against workers for demanding legitimate working conditions, or raising concerns regarding unsafe or unhealthy work situations, or any grievances raised, and such situations could lead to labour unrest and work stoppage. e) Discrimination and exclusion of vulnerable groups. If unmitigated, vulnerable groups of people may be subject to increased risk of exclusion from employment opportunities under the project. Such groups include women and persons, the elderly, and persons with disabilities (PWDs). Sexual harassment and other forms of abusive behavior by workers or managers will also have the potential to compromise the safety and wellbeing of the vulnerable groups of workers and the local communities, while adversely affecting project performance. g) Sexual harassment, exploitation and abuse: there are several concerns on the potential for GBV, increased risk of abuse and exploitation, especially for vulnerable women workers, among project workers and between project workers and local communities. h) Transmission of HIV/AIDS: there are risks related to transmission of HIV/AIDS among project direct workers, community volunteers and the communities in which they will be implementing project activities. The PIU will ensure that sensitisation on HIV/AIDS transmission and continuation of established relevant OHS measures on HIV/AIDS. i) Pay Point Managers are also at risk associated with carrying substantial amounts of cash, being vulnerable to theft and physical harm. Mitigation measures for PPMs will be followed as articulated in the Security Management Plan ( see Annex 4). 3.0 BRIEF OVERVIEW OF LABOR LEGISLATION: TERMS AND CONDITIONS This section sets out the key aspects of national labor legislation with regards to term and conditions of work, and how national legislation applies to different categories of workers, with particular focus on legislation relating to terms and conditions of employment: The Employment Code Act No. 3 of 2019 (Employment Code) and the Industrial and Labour Relations Act, Chapter 269 of the Laws of Zambia are the two main pieces of legislation that govern the employment relationship and articulates on equal employment, non-discrimination and child labour. Including the Public Health Act Chapter 265 of the Laws of Zambia, the Public Health Act Cap. 295 of the Laws of Zambia and Occupational Health and Safety Act No 36 of 2010. Zambia has also ratified ILOs ten fundamental Conventions including: • C029 Forced Labour • C087 Freedom of Association and Protection of the Right to Organise • C098 Right to Organise and Collective Bargaining 77 • C100 Equal Renumeration • C105 Abolition of Forced Labour • C111 Discrimination (Employment and Occupation) • C138 Minimum Age • C155 Occupational Safety and Health • C182 Worst Forms of Child Labour • C187 Promotional Framework for Occupational Safety and Health a) The Employment Code Act, 2019 regulates the employment of persons; prohibit discrimination at an undertaking; constitute the Skills and Labour Advisory Committees and provide for their functions; provide for the engagement of persons on contracts of employment and provide for the form and enforcement of the contracts of employment; provide for employment entitlements and other benefits; provide for the protection of wages of employees; provide for the registration of employment agencies; regulate the employment of children and young persons; provide for the welfare of employees at an undertaking; provide for employment policies, procedures and codes in an undertaking; repeal and replace the Employment Act,1965, the Employment (Special Provisions) Act,1966, the Employment of Young Persons and Children Act, 1933 and the Minimum Wages and Conditions of Employment Act, 1982; and provide for matters connected with, or incidental to, the foregoing. b) The Industrial and Labour Relations Act, Chapter 269, provides for the formation of workers and employers representative organizations and the constitution of the Tripartite Consultative Labour Council (TCLC). The TCLC provides a national forum for employers, workers and government to discuss and resolve labour issues, including OHS, which may be affecting the labour market. The Act also provides for the formulation of recognition and collective agreements, settlement of disputes, strikes and lockouts. In the collective agreements, employers and workers reach consensus on various issues including those to do with OHS. The Constitution of Zambia Article 24 which states that “A person below 18 years shall not be employed and shall in no case be caused or permitted to engage in any occupation or employment which would prejudice his health or education or interfere with his physical, mental or moral development…� c) The Public Health Act Cap. 295 of the Laws of Zambia, and guided by the two Statutory Instruments, SI 21 of 2020 which designates Covid-19 as a notifiable disease and SI 22 of 2020 which provides additional regulations to facilitate management and control of Covid-19, mandatory screening and quarantine of international travelers including air travel passengers, truckers, bus operators, and passengers at points of entry, bus stations and other check points from high-risk areas for a minimum period of 14 days shall be issued. d) The Public Health Act Chapter 265 of the Laws of Zambia, Provides for the prevention and suppression of diseases and generally regulates all matters connected with public health in Zambia. The Act ensures that the workers are safe and protected at their work place through the provision of First Aid, washing facilities (sanitation) and providing compensation to the workers in case of any accidents. 78 4.0 BRIEF OVERVIEW OF LABOR LEGISLATION: OCCUPATIONAL HEALTH AND SAFETY (OHS) This section sets out the key aspects of the national labour legislation with regards to occupational health and safety, and how national legislation applies to the different categories of workers identified in this Section. The Occupational Health and Safety Act No. 36 of 2010 provides for the following: establishment of the Occupational Health and Safety Institute and its functions; establishment of health and safety committees at workplaces and for the health, safety and welfare of persons at work; the duties of manufacturers, importers and suppliers of articles, devices, items and substances for use at work; the protection of persons, other than persons at work, against risks to health or safety arising from, or in connection with, the activities of persons at work; and related matters. This law is broadly concerned with potential hazards to persons in the workplace. The Occupational Health and Safety (OHS) articulates duties of employers, employees and other persons in occupational safety and health in Parts III and IV of the Act. In accordance with the OHS Act, it is a duty of the employer to ensure the health, safety and welfare of the employees at the workplace; and place and maintain an employee in an occupational environment adapted to the employee's physical, physiological and psychological ability. The employer must provide the work environment that is safe and without any risk to the health and safety of the employees at their workplace. The employer must also take preventive measures including adequate first-aid arrangements to deal with emergencies and accidents; provide and maintain adequate supply of drinking water; and separate eating & resting areas free from poisonous or injurious substances. According to the Occupational Health and Safety Act, the employer is responsible for providing all appropriate protective clothing or equipment to be used in the workplace by employees, who in the course of employment, are likely to be exposed to the risk of bodily injuries, and adequate instructions in the use of such protective clothing or equipment. All the protective equipment is provided free of cost. Employers are obliged to ensure that workers have been provided such information, instructions, training and supervision, especially on a machine or process likely to cause bodily injury, to protect the health and safety of employees at workplace. The Act also states that a worker must also take reasonable care for his/her own health and safety and that of other persons who may be affected by his/her acts or omissions at the workplace. The PIU will ensure that the project is undertaken in a manner that complies with applicable international conventions, and national directives, as well as the provisions of ESS2 and related World Bank standards, for addressing occupational health and safety issues relevant to Covid-19, such as: ILO Occupational Safety and Health Convention, 1981 (No. 155) and Promotional Framework for Occupational Safety and Health, 2013 (No. 187) 5.0 RESPONSIBLE STAFF The project has a four-tier implementation structure, and these include Ministry Head office, Provincial Social Welfare office and Department of Planning and Information, District Social Welfare Office and Community structures which include CWACs and PPMs. These are in the MCDSS, under the Department of Community Development and the Directorate of Social Welfare where there are 11 project staff and 25 project staff respectively, and in the Ministry of Education under the Department of Planning and Information, there are 10 project staff. The following are the roles and responsibilities associated with each level of the structure: 79 Project Implementation Units have been set up and will be maintained throughout the project implementation, at Ministries Head offices in the MCDSS under the Department of Community development and the Directorate of Social Welfare, and in the Ministry of Education under the Department of Planning and Information. Each of the implementing ministries is responsible and accountable for implementation of their component and activities, with the Permanent Secretary as the controlling officer. Each PIU is responsible for overall coordination and strategic guidance as well as oversight in all functions. The PIUs will be supported by the Provincial offices responsible for planning, quality control, training, budgeting and budget review; financial and progress reporting as well as oversight on district reporting and sensitization and capacity building activities at provincial level. District offices will oversee the day-to-day implementation, administration, financial management, procurement, monitoring and evaluation of the project with the assistance of Area Coordinating Committees ( ACCs) and Community Welfare Assistance Committees ( CWACs) and as further detailed in the Project Implementation Manual. Role Area of Responsibility Reporting to: CWACs 1.Targeting (awareness raising about the programme and ACC accompanying enumerators to the households during enumeration) 2. Witnessing Payments 3. Monitoring ACC Participates in targeting and enumeration, District Welfare District Welfare Assistance Committee (DWAC) community validation, monitoring Assistance and coordinating. Ensures there is no child labour and Committee (DWAC) DSWO Custodian of the programme at district level, Secretariat of the Provincial DWAC, accounts management, overseeing planning, quality Social Welfare control, training, budgeting and budget review, financial and Office progress reporting, oversight on district reporting, sensitization (PSWO) activities and capacity building at provincial level DWAC Oversight function to community welfare assistance committees PSWO and Area Coordinating Committees in relation to ensuring there is no child labour in CWACs and ACCs, and grievances are handled properly. Pay Point Payments to beneficiaries DSWO Managers Retirement of undisbursed funds (PPMs) Reporting on previous payment PSWO Planning, quality control, training of DSWOs, budgeting and budget Department of review, financial and progress reporting, oversight on district Social Welfare reporting, sensitization activities and capacity building at provincial (DSW) level Headquarters Department of Overall coordination and strategic guidance and oversight in all Permanent Social functions. Secretary, Welfare - Cluster Headquarters Advisory Working Group 80 on Social Assistance 6.0 POLICIES AND PROCEDURES This section sets out information on OHS, reporting and monitoring and other general project policies. Where relevant, it identifies applicable national legislation: a) Occupational Health and Safety (OHS): Pursuant to the relevant provisions of the National OHS Act 2010, Employment Act 2019, ESS2 (including WBG Environmental, Health and Safety Guidelines (EHSGs), the MCDSS, the MoE and Gender Division PIUs will manage the project in such a way that project workers are properly protected against possible OHS risks.. Covid-19: these measures will be implemented to ensure the risk of transmission and exposure to the virus is kept low during interactions with local communities. Guidance is based on the provisions developed by Zambia’s Ministry of Health10 and World Health Organization (WHO) for the prevention and mitigation of COVID-19. Community consultation and awareness creation, which require gathering people, will be carefully managed, with a focus on measures that are being implemented to safeguard the community and implementers alike. The project will follow the good practices articulated under Section 4 to prevent the spread of COVID-19. ✓ As under GEWEL and to avoid the inappropriate disposal of Covid-19 PPE into the environment (i) all non-infectious PPE should be disposed of as solid waste through the normal solid waste collection systems and (ii) at all project related events PPE should be segregated and placed in strong plastic waste bags, secured and disposed of in the municipal solid waste stream and (iii) project related participants infected with Covid-19 should have already visited a medical facility for assessment (if possible) and (iv) all those who are infected with Covid-19 their PPE should be disposed of in the medical waste stream at that medical facility and (v) further advice about Covid-19 related PPE waste should be obtained from local health care providers. Safety: PPMs are vulnerable to theft and physical harm as they will be carrying substantial amounts of cash for the SCT. A Security Management Plan has been put in place, which articulates the potential risks and mitigations as well as procedures to avoid and respond to risks. Key mitigations include (i)trainings that include risk awareness and safe mode of travel, ii) introducing the digital method of payment, (iii) using two PPMs per cash transfer (principle and deputy PPM) to increase personal security, (iv)reduce the number of bank visits and the amount stored at any one time, (v) maintaining a low profile during beneficiary payments by irregular payment patterns; (vii) maintaining privacy between PPM and beneficiary during payments and (vii) limiting the amount of cash carried by any one PPM . Monitoring and reporting: The PIU shall be responsible for reporting on the status of implementation of the above policies and procedures. The PIU will closely monitor OHS performance of the project and report to the World Bank. a. Fatality and serious incidents: In the event of an occupational fatality or serious injury, the PIU shall report to the World Bank as soon as it becomes aware of such incidents. Corrective actions shall be implemented in response to project-related incidents or accidents. The PIU or, where relevant a consultant, may conduct a root cause analysis for designing and implementing further corrective actions. 10 Public Health Act Cap. 295 of the Laws of Zambia have been amended to include two Statutory Instruments, SI 21 of 2020 which designate COVID-19 as a notifiable disease and SI 22 of 2020 which provides additional regulations to facilitate management and control of COVID-19 both issued on 14 March 2020. 81 b. GBV/SEA-H incidents: To avoid the risk of stigmatization, exacerbation of the mental/psychological harm and potential reprisal, the grievance mechanism shall have a confidential, secure, victim-centered, sensitive channel designated to handle GBV-related cases and will be dealt with according to the complainant’s informed consent as articulated in the GEWEL GRM, in a timely manner. Including, all workers will sign the code of conduct (CoC) outlining expected standards of behavior as a measure to this risk. SECTION 7: AGE OF EMPLOYMENT This project will abide by the Employment Code Act No. 3 of 2019 (Employment Code), the Public Service Regulation and Human Resources manual which uphold the minimum age of employment as not less than 18 years of age. The process of age verification will be undertaken prior to engagement of labor and documented using the national registration card (NRC) or passport or other acceptable identification as means of indicative age verification. For community workers who may not have such documents, a verification by a recognized local leader will suffice to engage him/her. All project direct workers will be civil servants and will be recruited through Public Service procedures and regulations and, whether full-time or part-time, they will remain subject to the terms and conditions of their existing public sector employment agreement or arrangement, unless there has been an effective legal transfer of their employment or engagement to the project. Community volunteers will be recruited through existing community volunteering structures. DWACs will be responsible for sensitizing and ensuring that CWACs and ACCs do not allow children under the age of 18 to be community volunteers and will check national registrations or volunteers identity documents to confirm their ages. SECTION 8: TERMS AND CONDITIONS For this project, the following provisions will inform management of all workers: a) Direct workers: Civil servants will remain governed by the Employment Code Act no. 3 of 2019, the Industrial and Labour Relations Act, Chapter 269 of the Laws of Zambia, Public Service Regulations and Human Resources Manuals. The MCDSS and MoE as well as the Gender Division shall therefore follow the public service provisions related to labour engagements and management. b) Community Workers: Minutes of meetings where volunteers where selected including their terms of labour explained and that their labour will be provided on a voluntary basis, will be recorded, and kept through the DSWO. This includes details of what has been agreed, the way in which such agreement was reached, and how the community workers are represented showing that there was consent which must exist throughout the employment relationship and the community worker must have the possibility to revoke freely given consent. DSWOs will assess the authenticity of the free and informed consent, ensuring that no external constraint or indirect coercion was carried out, by any act of the authorities 9.0 GRIEVANCE MECHANISM Worker Grievance Management 82 This section sets out details of the grievance mechanism that will be provided for direct and community workers and describes the way in which these workers will be made aware of the mechanism. All direct workers (civil servants) will continue to use the Public Service Regulations and Human Resources Manuals and will also be informed of the worker grievance mechanism at the time of recruitment and the measures put in place to protect them against reprisal for its use. The project will establish a grievance redress mechanism (GRM) for community workers, in line with the provisions of ESS2, to raise workplace concerns and ensure that all workplace related complaints, including related to workplace sexual harassment, are effectively managed. The GRM will make use of the principles of responsiveness and confidentiality, objectivity and independence, simplicity, fairness, timeliness, participation. The GRM will be proportionate to the nature and scale and the potential risks and impacts of the project. It will be designed to address concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned in a language they understand, without any retribution, and will operate in an independent and objective manner. The grievance mechanism may utilize existing grievance mechanisms, provided, they are properly designed and implemented, address concerns promptly, and are readily accessible to the community workers. Community workers are also free to utilize the already existing GEWEL Grievance Redress Mechanism provided for in the community. The community workers will be informed and oriented in the project worker grievance management once they are engaged for their support on the project. The GRM Specialists in the PIUs and the GRM Master Trainers will support the orientation meetings, and it is expected that approximately 87,776 community worker volunteers and 4,400 individual public service workers will be oriented in grievance management. The orientation meetings will last for a period of three days and are planned to be conducted at least once every year at national level. community workers have a right to express a grievance in relation to their services without prejudice to their voluntary position or fear of discrimination or victimisation and seek redress for the grievance. The grievance mechanism will not impede access to other judicial or administrative remedies that might be available under the law or through existing arbitration procedures, or substitute for GRMs provided through collective agreements. 10.0 CONTRACTOR MANAGEMENT There will be no contractors engaged in this project 11.0 COMMUNITY WORKERS Community volunteers including Community Welfare Assistant Committees (CWACs) and Area Coordinating Committees (ACCs) will be involved mainly in community mobilization and sensitization about the project as described in the table below. The PIU through District Social Welfare Officers (DSWO) will ensure that no one under the age will be allowed to work as a community volunteer on the project through checking all project volunteer’s national registration documents. DSWOs will agree on the terms of engagement with community volunteers and will prepare and share minutes with the community and community volunteers. 83 The table below shows the community volunteers roles and responsibilities as applicable to this project: Role Area of Responsibility CWACs 1.Targeting (awareness raising about the programme and accompanying enumerators to the households during enumeration) 2. Witnessing Payments ACC Participates in targeting and enumeration, District Welfare Assistance Committee (DWAC) community validation, monitoring and coordinating. District offices will be responsible for monitoring the Area Coordinating Committees (ACCs) and Community Welfare Assistance Committees (CWACs) as further detailed in the Project Implementation Manual. 12.0 PRIMARY SUPPLY WORKERS The project will not engage primary suppliers. 84