People’s Republic of Bangladesh Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY) (P178133) DRAFT ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) May 2023 (Incorporated LEG comments) 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. People’s Republic of Bangladesh (Borrower) will implement the Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY) Project (the Project), through the Department of Women Affairs (DWA) under Ministry of Women and Children Affairs (MoWCA) and the Local Government Division (LGD) under Ministry of Local Government and Rural Development and Cooperatives (MoLGRDC) (the Implementing Agencies or IAs). The International Development Association (World Bank) has agreed to provide financing for the Project, as set out in the referred agreement. 2. The Borrower shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the World Bank. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Borrower shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring, and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted and implemented under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESS, and in form and substance, and in a manner acceptable to the World Bank. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the World Bank. 4. As agreed by the World Bank and the Borrower, this ESCP will be revised from time to time if necessary, during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to Project performance. In such circumstances, the Borrower, through the respective IA, and the World Bank agree to update the ESCP to reflect these changes through an exchange of letters signed between the World Bank and the Borrower, through the designated representative of the respective IA. The Borrower, through the respective IA, shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY ) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit half yearly (every six-month) Project Management Unit Prepare and submit to the World Bank regular monitoring reports as per approved report to the World Bank throughout (PMU) of LGD and Program template on the environmental, social, health and safety (ESHS) performance of the Project implementation (commencing Implementation Unit (PIU) of Project, including but not limited to the implementation of the ESCP, status of after the Effective Date). Submit each DWA. preparation and implementation of E&S instruments required under the ESCP, report to the World Bank no later than stakeholder engagement activities, functioning of the grievance mechanisms with 60 days after the end of each reporting reference to World Bank ESF and international good practices. The format will be agreed period. by 1st Implementation Support Mission B INCIDENTS AND ACCIDENTS Notify the World Bank no later than 48 PMU/PIU Notify the World Bank of any incident or accident related to the Project which has, or is hours after learning of the incident or likely to have, a significant adverse effect on the environment, the affected accident. communities, the public or workers, including, inter alia, cases of sexual exploitation and abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or Provide subsequent report on action multiple injury, serious mismanagement of in handling waste etc. Provide sufficient taken on the same by seven (07) days of detail regarding the scope, severity, and possible causes of the incident or accident, notifying the World Bank indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any District Facilitator (DF), Community Support Network (CSN), Social Protection Assistant (SPA), Social Protection Supervisor (SPS), and/or Union Women and Children Development Assistant (UWCDA) as appropriate. Subsequently, at the World Bank’s request, prepare a report on the incident or accident and propose any measures to address it and prevent its recurrence. C MONTHLY REPORTS Submit consolidated report as annexes PMU District Facilitators shall provide monthly progress report to LGD on ESHS performance in to the six-monthly reports to be accordance with the metrics specified in the respective bidding documents, sub-project submitted under action A above. proposals and contracts, and submit such reports to the PMU of LGD. PMU will send one consolidated report to World Bank every 6 months. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE a) Within three months of project PMU/PIU a) Establish and maintain a PMU at LGD, with qualified staff and resources to support effectiveness. management of ESHS risks and impacts of the Project, including one Environmental and Social Specialist and one Communication Specialist. Until the formation of the b) Within three months of project LGD PMU, the in-house project preparatory team will support project implementation effectiveness. activities. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY ) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY b) Recruitment of Social Specialist with expertise in environmental and social Retain the Environment and Social management at the existing MCBP-PIU under DWA component team of PMU/PIU for the entire period of Project implementation. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS a) For DWA PIU: As part of Project a) POMs to be prepared by a) Prepare Project Operational Manuals (POM) which will set out environmental effectiveness and to be PMU/PIU. and social management arrangements, including on grievance redressal implemented throughout Project mechanism, sexual exploitation and abuse and sexual harassment (SEA/SH), implementation COVID-19 SOP, e-waste management plan, occupational health and safety plan b) PMU/PIU and community health safety plan, as well as negative and positive lists and For LGD PMU: Within six months of screening check list, as relevant, all in accordance with the relevant ESSs. project effectiveness and to be c) PMU/PIU implemented throughout Project implementation d) PMU/PIU b) Carry out E&S Screening for all the activities according to POM of the LGD/DWA. Activities identified in the negative list will be ineligible for support by the project. b) E&S Screening to be carried out prior to implementation of LGI project activities. c) Prepare checklist based on the screening outcomes if required for the minor refurbishment works. Follow and implement the measures in accordance with c) Checklist and mitigation measures the POM and checklist required for the respective Project activities based on the to be developed before screening process, in accordance with the ESSs, and other relevant Good refurbishment works begin and International Industry Practice (GIIP) including relevant WHO Guidelines on implemented throughout Project COVID-19 response implementation d) Within four months of project effectiveness d) Prepare SEA/SH Action plan EXCLUSIONS Screen all proposed activities/subproject against the negative list set out in the POMs. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY ) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Activities that involve the following characteristics will be ineligible for support under the project: a) Activities requiring land acquisition or resettlement activities with significant environmental impacts, including those that significantly increase GHG emissions. b) Any activities affecting mosques, temples, graveyards, cremation grounds, and other places/objects that are of religious and cultural significance Screen activities before determining c) Activities that may significantly restrict access to common property resources whether they are eligible to receive support from the Project, including and livelihood activities of groups and communities Performance-Based-Grants. d) Activities located within any forest area e) Any activity adversely affecting biodiversity, natural habitat and critical habitat f) Activities with high/substantial E&S risks and impacts g) Any adverse impacts on ethnic minority/require FPIC 1.3 MANAGEMENT TOOLS Specifications to be included with PMU/PIU Screen all project activities in accordance with the POM, SEP, LMP and ESCP prepared for procurement documents before floating the Project, and, thereafter, depending on the Screening outcome, prepare, adopt, tender and contract documents before disclose, and implement the project specific plans. signing of the contracts. Supervise the activities throughout Project implementation. 1.4 TECHNICAL ASSISTANCE During preparation of the bidding PMU/PIU Ensure that the consultancies, capacity building, training and any other technical documents and contracts and assistance activities under the Project (including those by firms) are carried out in throughout the Project implementation. accordance with terms of reference acceptable to the World Bank that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Adopt the LMP before engaging PMU/PIU workers and preparation of bidding documents and contacts, and thereafter implement the LMP throughout Project implementation. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY ) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Adopt and implement the Labor Management Procedures (LMP) of the Project, including, inter alia, provisions on working conditions, management of workers relationships, occupational health and safety (including personal protective equipment, and emergency preparedness and response), code of conduct (including relating to SEA and SH), forced labor, child labor, grievance arrangements, appropriate working condition amidst a public health emergency (including measures against outbreak of COVID-19); provision of training on handling emergency situation especially health related issues and incorporating labor requirements in the procurement documents and contracts for Project workers, and applicable requirements as required. Ensure that necessary conditions are included in the bidding documents and contracts comply with the provisions set out in the LMP 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS • Adopt and implement the PMU/PIU • Use existing GRM of MCBP program of the DWA for component 1. Use existing DWA existing GRM MoWCA GRM and hotline (109) for the SEA/SH related grievances throughout Project implementation. • Use existing LGD GRM for the Project and formulate local GRC at upazila level. Nominate and train E&S focal to deal with the SEA/SH related grievances • The GRC at the local level will be established before commencement of activities at field level and will operate throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Prepare E-Waste Management plan PMU/PIU Prepare an e-waste management plan for the procurement of IT equipment if required. within six months of the procurement of the computers. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY To be implemented throughout Project PMU/PIU/Contractors Assess and manage specific risks and impacts to the community and beneficiaries arising implementation. from Project activities, including COVID 19. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY ) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Include SOPs in the POM in line with WHO standards and national guidelines. Measures for COVID-19 to be undertaken to be implemented throughout Project implementation as applicable. 4.2 SEA AND SH RISKS Adopt the GVB/SEA/SH measures and Measures to be Ensure the avoidance of all forms of Gender Based Violence (GBV)/Sexual Exploitation implement throughout Project implemented by PMU/PIU as and Abuse (SEA), Sexual Harassment (SH) by establishing written Codes of Conduct for all implementation. required and training to be project personnel, including workers in the project area, and train and sensitize them on conducted with the supports this issue. SEA/SH action plan will be adopted of PMU/PIU. within four months of Project effectiveness. SEA/SH action plan to be Update and finalize the SEA/SH action plan. prepared by PMU/PIU ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK Not relevant for this Project. Not relevant for this Project. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS Not relevant for this Project. This ESS6 is currently not relevant. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 TRIBAL PEOPLES PLANNING FRAMEWORK Consultations will be carried out with all PMU/PIU Relevant aspects of ESS7 shall be considered since Component 2 of the Project will be tribal areas (if identified) throughout implemented in selected, yet undetermined, locations and some of the targeted the project cycle beneficiaries and services may be in areas that may have tribal/ethnic minorities women and children. Some of the services may be in areas with tribal/ethnic minorities. If beneficiaries belonging to tribal/ethnic are identified in the project intervention areas, they will be consulted, and all project related information will be made accessible to them, so that they can benefit from the project. Any situation that may require obtaining FPIC should not be considered for financing and will be included as part of the exclusion criteria. 7.2 GRIEVANCE MECHANISM Before start of project activities (if PMU/PIU The project will use the same GRM for all beneficiaries including tribal/ethnic people. required) ESS 8: CULTURAL HERITAGE 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY ) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 8.1 CULTURAL HERITAGE RISKS AND IMPACTS The ESS is not application as the project will not finance any civil work. ESS 9: FINANCIAL INTERMEDIARIES 9.1 This is not applicable for this project. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Implement it over the Project period. PMU/PIU Adopt and implement Stakeholder Engagement Plan (SEP) for the Project, consistent with ESS10, which includes measures to, inter alia, 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. The SEP may be amended/ updated (and re-disclosed) as needed. 10.2 PROJECT GRIEVANCE MECHANISM PMU/PIU Establish the local grievance mechanism • Use existing GRM of MCBP program of the DWA for component 1. Use existing before commencement of Project MCBP GRM and hotline (109) for the SEA/SH related grievances activities at field level , and thereafter maintain and operate the mechanism • Use existing LGD GRM for component 2 and formulate the local GRM at upazila throughout Project implementation. level. Nominate and train E&S focal points to deal with the SEA/SH related grievances • The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 All staff of the PMU and PIU under component 1 and 2 will be given capacity building Within six months after Project PMU/PIU training and orientation on environmental, social, health and safety (ESHS) management Effective Date. following the national legal and policy requirements, international treaties, WHO guidelines and the World Bank ESF. PMU/ PIU will design and implement training for 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Bangladesh Enhancing Investments and Benefits for Early Years (BEIBEY ) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY targeted groups involved in the project to improve their awareness of risks and mitigate the impacts. ESF. Training on ESF and the 10 ESSs—including preparation of the specific instruments applicable for the project. • Training on issues related to COVID-19 • Training on Labor and Working Conditions and ESIRT • Training on Grievance Redress Mechanism • Training on GBV/SEA/SH CS2 Occupational Health and Safety Within six months after Project PMU/PIU Effectiveness and once in every six Workplace risk management months thereafter. Prevention of accidents at work sites Health and safety rules Preparedness and response to emergency situations 9|Page