ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) Common Market for Eastern and Southern Africa (COMESA) Inclusive Digitalization in Eastern & Southern Africa - Multi-Phase Programmatic Approach (MPA) (P502532) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) May 30, 2024 1|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Common Market for Eastern and Southern Africa (COMESA) (the Recipient) will implement the Inclusive Digitalization in Eastern & Southern Africa Multi-Phase Programmatic Approach (P502532) (the Project), as set out in the Financing Agreement. The International Development Association (the Association) has agreed to provide financing for the Project, as set out in the referred agreement. 2. The Recipient shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Association. The ESCP is a part of the Financing Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Recipient shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring, and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted and implemented under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESSs, and in form and substance, and in a manner acceptable to the Association. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the Association. 4. As agreed by the Association and the Recipient, this ESCP will be revised from time to time if necessary, during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to Project performance. In such circumstances, the Recipient and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient through the COMESA Secretary General. The Recipient shall promptly disclose the updated ESCP. 2|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit quarterly reports to the COMESA Association throughout Project Prepare and submit to the Association regular monitoring reports on the environmental, implementation, commencing 90 days social, health and safety (ESHS) performance of the Project, including but not limited to after the Effective Date. Submit each the implementation of the ESCP, status of preparation and implementation of E&S report to the Association no later than instruments required under the ESCP, stakeholder engagement activities, and 30 days after the end of each reporting functioning of the grievance mechanisms, including those related to Sexual Exploitation period. and Abuse and Sexual Harassment (SEA/SH). B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 COMESA hours after learning of the incident or Promptly notify the Association of any incident or accident related to the Project which accident, and no later than 24 hours has, or is likely to have, a significant adverse effect on the environment, the affected after learning of any fatality or SEA/SH communities, the public or workers, including, inter alia, cases of SEA/SH, and accidents incident. that result in death, serious or multiple injury, alleged violations of labor laws (forced and child labor) and working conditions, cases of gender-based and other discrimination Provide subsequent report within a such as exclusion of vulnerable people (women, youth, people with disabilities, minority timeframe acceptable to the and disadvantaged groups). Association. Provide sufficient detail regarding the scope, severity, and possible causes of the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and/or supervising firm, as appropriate Subsequently, at the Association’s request, prepare a report on the incident or accident and propose any measures to address it and prevent its recurrence. C CONSULTING FIRMS MONTHLY REPORTS Submit the monthly reports to the COMESA Association as annexes to the reports to Require Consultants to provide monthly monitoring reports on environmental, social, be submitted under action A above. health and safety (ESHS) performance in accordance with the metrics specified in the respective bidding documents and contracts and submit such reports to the Association. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 3|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.1 ORGANIZATIONAL STRUCTURE a) Establish and maintain the Project’s regional Program Coordination Unit (PCU) at a) Establish PCU prior to the Project COMESA the COMESA Secretariat. Effective Date and maintain throughout Project b) To support the management of ESHS risks and impacts of the Project, the PCU shall implementation. recruit and maintain an environmental expert with OHS expertise, a social expert, and a stakeholder engagement/communication expert and train and sensitize them b) Recruit the qualified on the World Bank’s ESF/ESSs requirements to enable them to review consultancy environmental, social, and ToRs and reports to ensure they are in line with the ESF/ESSs stakeholder engagement/ communication experts no later c) Mobilize additional staff or consultants including interns as needed on short-term than 90 days after the Project and long-term engagements in accordance with capacity building and institutional Effective Date and thereafter needs assessment; maintain these positions throughout Project implementation. c) Throughout Project implementation. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS Draft SEP was adopted and disclosed by COMESA the Association and COMESA on May 6, Update and implement the Stakeholder Engagement Plan (SEP) in form and substance 2024, and shall be updated no later acceptable to the Association. than 90 days after the Effective Date, and thereafter implement it throughout Project implementation. 1.3 MANAGEMENT OF CONTRACTORS As part of the preparation of COMESA procurement documents and respective Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S consultancy contracts. instruments, labor and other relevant provisions in the Project Operations Manual (POM), and SEA/SH code of conduct, into the ESHS specifications of the procurement documents and contracts with consultants and other service providers. Thereafter ensure that consultants and service providers comply with the ESHS specifications of their respective contracts, including SEA/SH aspects. 4|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. COMESA Ensure that the consultancies, studies (including feasibility studies, if applicable), capacity building, training, and any other technical assistance activities under the Project are carried out in accordance with terms of reference acceptable to the Association, that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Adopt the labor management COMESA procedures contained in the POM prior Adopt and implement key relevant provisions of the Labor Management Procedures (LMP) to Project Effective Date and thereafter developed for the ASCENT Project’s (P180547) COMESA operations in the IDEA COMESA implement those procedures POM including, inter alia, provisions on working conditions, management of workers throughout Project implementation. relationships, occupational health and safety plans (including personal protective equipment, and emergency preparedness and response if applicable), code of conduct (including relating to SEA/SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for consultant firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Operationalize the worker GM prior to COMESA Adopt, adhere to and operate the IDEA COMESA Project Worker Grievance Mechanism engaging Project workers and (GM) established under the ASCENT (P180547) COMESA operations LMP, and consistent thereafter maintain and operate it with ESS2. throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT NOT RELEVANT ESS 4: COMMUNITY HEALTH AND SAFETY NOT RELEVANT ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY NOT RELEVANT ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES NOT RELEVANT ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES NOT RELEVANT ESS 8: CULTURAL HERITAGE NOT RELEVANT ESS 9: FINANCIAL INTERMEDIARIES NOT RELEVANT ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Timeframe indicated in 1.2. COMESA Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent with ESS10. 10.2 PROJECT GRIEVANCE MECHANISM Draft Project GM was adopted and COMESA disclosed (as part of SEP) on May 6, Adapt, adopt and operate the grievance mechanism implemented by COMESA under 2024, and shall be updated and the ASCENT project (P180547), in coordination with ASCENT, to receive and facilitate operationalized no later than 90 days resolution of concerns and grievances in relation to the IDEA Project COMESA after the Project Effective Date. operations, promptly and effectively, in a transparent and non-discriminatory manner that is culturally appropriate and readily accessible to all Project-affected parties, at no Thereafter maintain and operate the cost and without retribution, including concerns and grievances filed anonymously, in a mechanism throughout Project manner consistent with ESS10. implementation. 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 6|P a g e ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Inclusive Digitalization in Eastern & Southern Africa (P502532) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY CS1 PCU staff and consultant training on: Within 12 months of the Project COMESA with World Bank Effective Date. support a) Stakeholder Engagement Plan (SEP) – stakeholder mapping and engagement, and the functioning of the project’s grievance mechanisms b) Specific relevant aspects of environmental and social assessment, gender considerations c) Emergency preparedness and response d) Labor Management Procedures (LMP) including a Code of Conduct for project workers in relevant languages and Labor Specific GRM e) World Bank ESHS requirements for ESF and WB EHS Guidelines (including those for Telecommunications and (where relevant) Electric Power Transmission and Distribution), f) SEA/SH Action Plan including GBV issues g) Project wide GRM h) Occupational Health and Safety (OHS) Plan 7|P a g e