The World Bank Burkina Faso Digital Transformation Project (P177022) Appraisal Environmental and Social Review Summary Appraisal Stage (ESRS Appraisal Stage) Public Disclosure Date Prepared/Updated: 07/08/2023 | Report No: ESRSA02558 Jul 08, 2023 Page 1 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Burkina Faso WESTERN AND CENTRAL P177022 AFRICA Project Name Burkina Faso Digital Transformation Project Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Digital Development Investment Project 7/20/2023 10/30/2023 Financing Borrower(s) Implementing Agency(ies) Burkina Faso Ministry of Digital Transition, Posts and Electronic Communications Public Disclosure Proposed Development Objective The PDO is (i) to expand access to affordable and climate resilient broadband connectivity, (ii) to improve government’s capacity to deliver public services digitally, and (iii) to strengthen the digital skills to foster acceleration of the digital economy. Financing (in USD Million) Amount Total Project Cost 150.00 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] The project is designed to accelerate digital transformation through a series of integrated and mutually reinforcing interventions. Component 1 (Expanding Digital Connectivity for Digital Inclusion) will help improve access to affordable and high-quality internet by unlocking critical investments in the middle- and last-mile. Component 2 (Accelerating the Digital Transformation of Public Services) will establish further technological foundations and capabilities to digitize public service delivery and increase the uptake of digital public services through, inter alia, Jul 08, 2023 Page 2 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) strengthened data hosting and management infrastructure, and deployed shared digital platforms (interoperability, signature and certification, digital payment). Component 3 (Accelerating Digital Skills for Increased Adoption of Digital Services) will focus on both the supply and demand side to boost the adoption of digital services provided by the public and private sector in Burkina Faso. Component 4 (Project Management) will support counterpart’s capacity in citizen engagement, project management, communications, and monitoring and evaluation (M&E). Component 5 (Contingent Emergency Response Component, CERC) would help to respond to eligible crises or emergencies that could arise during implementation. D. Environmental and Social Overview D.1. Detailed project location(s) and salient physical characteristics relevant to the E&S assessment [geographic, environmental, social] While the precise locations of the project interventions are not known and will be determined after project appraisal, the project aims to intervene nationwide and will be implemented in the 13 regions of Burkina Faso in both urban and rural areas. The country is characterized by a tropical climate with a rainy and dry seasons. The physical geography is characterized by a savanna that is grassy in the north gradually giving way to sparse forests in the south. The ecosystem hosts a large biodiversity including various species spread across the regions. The land classification is characterized by forests, agricultural ecosystems, pastoral ecosystems, wetlands, urban areas, mountain ecosystems and conservation areas. In addition, much of Burkina lies in the Sahel, the fringe of the Sahara with the north gradually dries out into scrubs and semi-desert. The growing insecurity in the whole country mainly in the sahel, northern, eastern and south-west regions is making it difficult to implement projects. To date, some regions such as the northern, south-west, sahel and eastern parts of Public Disclosure the country are practically inaccessible for project implementation. According to UNHCR in February 2022, Burkina Faso has 1,814,283 IDPs with more than 50% women and children. A security risk assessment (SRA) has been conducted to determine accessible regions meaning sites where construction can take place or even those accessible to activities proposed under component 3. The Security Management Plan has also been prepared based on the SRA; it will be validated by appraisal. D. 2. Borrower’s Institutional Capacity The implementing agency for project interventions will be put in place before the project effectiveness. The Government of Burkina Faso has implemented the WARCIP 1B Project (BF-WARCIP), funded by the World Bank under the Bank’s old E&S Operational Policies. The Project Implementation Unit (PIU) of the other ongoing Burkina-Faso eGovernment Project (P155645) will be in charge of the implementation of the Project Preparation Advance (PPA) focused on: (a) recruitment of PIU staff; (b) Project Implementation Manual (PIM); (c) Environment and social and procurement assessments; (c) several technical feasibility studies for components 1 and 2. The Borrower's capacity in terms of working within the World Bank’s Environmental and Social Framework (ESF) is limited as the previous project (eGovernment Project (P155645) was implemented under the old E&S safeguards operational policies and did not recruit E&S specialists. The Project implementation Unit (PIU) for this new operation shall recruit environmental and social development specialists, including those with EAS/HS and security profiles. The Bank will ensure that they the recruited specialists have the capacity to implement Bank’s procedures and manage identified E&S risks and impacts. The World Bank team will enhance their capacity at the implementation stage, as necessary, to ensure project compliance with the ESF requirements. : the client has prepared the following environmental and social instruments: the Stakeholder Engagement Plan (SEP), Environmental and Social Commitment Plan (ESCP), Labor Management Procedures (LMP), Environmental and Social Management Framework (ESMF), Resettlement Framework (RF).The dedicated E&S specialists for the new PIU will be recruited, before the Jul 08, 2023 Page 3 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) project effectiveness date with terms of reference (TOR) acceptable to the Bank to implement environmental and social commitments. The evaluation report along with the CVs of the best candidates will also be reviewed by the Bank, to ensure conformity with the TOR and the final selection will also be cleared by the Bank. II. SUMMARY OF ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Substantial Environmental Risk Rating Substantial The environmental risk is rated “Substantial” due to the potential risks during the civil works planned under Components 1 and 2, which will consist of: (i) the expansion of the National Fiber Optic backbone, (ii) the expansion of last mile connectivity in rural area and (iii) the installation of a modular data center in a built in container. The proposed civil works for the installation of the fiber optic may generate adverse environmental risks and impacts that will need to be assessed and managed in order to comply with the ESF. The key potential risks and impacts associated with the project’s activities identified in the ESMF are related to: (i) Resource efficiency and pollution prevention and management (to excavation along side streets and households’ doors, installation of piping and communication infrastructures, water and energy use, dust, noise, and the potential contamination of water sources, mainly due to construction waste management; (ii) Occupational and community health and safety, as well as human security; (iii) the extension of the national fiber optic backbone to reach more 2nd layer and 3rd layer administrative capitals which may have the potential to affect habitats or protected areas. However, the potential risks and impacts associated with these civil works activities are expected to be limited and reversible with appropriate mitigation measures, which will Public Disclosure be put in place to avoid, minimize or compensate identified E&S risks and impacts. Social Risk Rating Substantial Project social risk is rated as substantial at this stage. This rating is related to carrying out civil works in rural areas that could lead to impacts and risks on private and/or community assets. For example, activities related to excavation along side streets and next to houses and the installation of piping and communication infrastructures could lead to the disruption of economic activities and damage to private property. Digital economy development and legislative and regulatory framework strengthening can be sensitive and critical in terms of inclusion. With high national levels of illiteracy and the low level of instruction, and most people living in rural areas with limited access to markets and services, digital infrastructure and services deployment there is a risk of social exclusion from project benefits. In particular disadvantaged women and youth, who are active actors in all economic sectors, risk being excluded. The growing insecurity in the Sahel, northern, eastern and southern-ouest regions is making it difficult to implement projects. Indeed, the country is facing to terrorism attacks, individual and group abdications mainly on women, girls and young men, targeted killings of men. Several regions that continue to be emptied of their population with more women and children in “forced displacement” situation. B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: Jul 08, 2023 Page 4 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) This standard is relevant. The civil work activities related to the expansion of the National Fiber Optic backbone, the expansion of last mile connectivity in rural areas and the installation of two data centers (Components 1 and 2) could cause adverse environmental and social risks and impacts. These are identified and analyzed in the ESMF and include the risk of exclusion of certain vulnerable groups including women, youth, internally displaced persons (IDP), persons with disabilities, etc., from consultation processes and full access to project benefits, resource efficiency and pollution prevention and management (sourcing of raw materials for civil works, water and energy use, dust, noise, potential contamination of water sources due to construction) and electronic waste management mainly and Occupational and community health and safety as well as human security. A screening process will be put in place to ensure that E&S risks and impacts associated with these activities including those to be implemented through the private sector for example companies that will be involved in expanding national fiber optic backbone will be addressed appropriately. The Bank team will review and validated the Borrower’s E&S instruments to ensure consistency with ESF requirements. Given that the sites of the expected investments are not known at this stage, an Environmental and Social Management Framework (ESMF) has been prepared and will be finalized and disclosed by the appraisal to provide guidance on conducting environmental and social risk assessment and measures to address all identified environmental and social risks and impacts. The main environmental and social risks and impacts identified in the ESMF are: (i) the risk of air pollution by construction site activities; (ii) the risk of pollution of soil and water by waste from poorly managed work sites;(iii) the risk of soil degradation and loss of vegetation due to land clearing on construction sites; (iv) the risks related to community health and safety during construction activities; (v) risk of potential SEA/SH due to temporary labor influx and contracting of security personnel; (vi) risk of exclusion of some Public Disclosure groups to the project beneficiaries especially those categorized as vulnerable groups (like women, internally displaced persons, female headed households, persons with disabilities and so on); (vii) land tenure challenges in the event of presence of squatters. The ESMF provides guidance on screening, scoping, and managing unavoidable environmental and social impacts, and on the level of environmental and social assessment and types of instruments needed, such as Environmental and Social Impact Assessment (ESIAs) and Environmental Social Management Plan (ESMPs). From a social perspective, the ESMF includes mitigation measures related to social inclusion, participatory approaches during consultation processes, grievances redress mechanisms both for project’s stakeholders and involved workers. A SEP that identifies the key stakeholders of the project and the actions to be taken to ensure their inclusion through consultation and participation during the project implementation has been developed and will be validated and disclosed both in-country and on the World Bank's website prior to project appraisal. SEA/SH risks are integrated into prepared E&S instruments. A specific SEA/SH Prevention and Response Action Plan will be set up and clearly outlined mitigation measures, with an estimated budget allocation, response protocol, and accountability mechanisms to prevent and respond to any SEA/SH incident. This includes but not be limited to the mapping of GBV services in the areas of intervention, as well as the drafting and signature of codes of conduct forbidding SEA/SH, with sanctions for non-compliance; training for workers and awareness raising on SEA/H risks and measures for communities; separate consultations with women, girls and a project Grievance Mechanism (GM) sensitive to the management of SEA/H complaints informed by a survivor-centered approach, with distinct entry points, as well as referral pathways to GBV services, and procedures that are confidential and survivor-centered. Jul 08, 2023 Page 5 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) Activities of existing facilities subject to retroactive financing under the project will be identified during project preparation and due diligence will be carried out to determine the actions required to ensure that these activities meet the requirements of the E&S standards. If necessary, an environmental and social audit will be carried out during project preparation. The ESMF and subsequent ESIAs will make use of the general and sector-specific Environmental Health and Safety Guidelines (EHSG) for the activities identified in relation to occupational and community health and safety. Relevant procedures relating to cultural heritage for “chance finds” are included in the ESMF. The Borrower will monitor the environmental and social performances in accordance with the ESCP. The site-specific ESIAs, including their ESMPs and subsequent contractor’s ESMPs, will be developed during project implementation. The preparation and implementation of the Contractor’s ESMPs will be the responsibility of the selected contractor. The contractors’ ESMPs will include clearly defined mitigation measures during the construction phase. Contractors will be required, as a condition of their contract, to prepare, implement, and comply with their ESMP, project Labor Management Procedures (LMP), including the signing of codes of conduct, and Occupational Health and Safety (OHS), measures outlined in the relevant ESIA/ESMP. The timeline for these commitments is outlined in the ESCP and will be monitored and updated if needed throughout the life of the project. Public Disclosure ESS10 Stakeholder Engagement and Information Disclosure This standard is relevant. The project has prepared a SEP in consultation with the following key stakeholders: i) those who are interested by the project, inlcuding ministries in charge of Finances, Communication, Territorial Administration, Infrastructure, Small and Medium Enterprises, and National Entrepreneurship Associations and NGOs; and ii) those who could be affected directly by the project, includinglocal communities and authorities, farmers, pastoralists, IDPs, women’s groups, and youth). At this stage, the Borrower has consulted and started sensitization with officials and authorities at central, regional, and local levels, followed by consultation with some local leaders, field TIC users local communities. The SEP identifes some vulnerable groups, outline the characteristics and interests of stakeholder groups, and include timing and methods of engagement throughout the project lifecycle. Consultation and participation activities including sensitization will be continued throughout the project implementation life cycle to ensure that key stakeholders fully understand the objectives of the project, the processes, and the benefits, and how they can participate effectively. The SEP includes also a project-level, SEA/SH- sensitive Grievance Mechanism (GM) that assures safe and confidential documentation, the response and management of SEA/SH complaints, and includes the targeted, regular involvement of women and other SEP groups at-risk. Awareness-raising activities on project-related risks of SEA/SH, and related mitigation strategies, is included in the SEP, and will target communities and project workers. The SEP includes a mapping of project key stakeholders that shall be updated at the implementation phase if necessary and a description of the Grievance Mechanism (GM) to guide the development and set up of a functional GRM. The GM shall be transparent and accessible to key stakeholders, including referrals to locally available medical, Jul 08, 2023 Page 6 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) psychosocial and/or legal aid services for any SEA/SH survivor signaling abuse. The GM will be used to receive and resolve project-related complaints; it establishes a systematic approach for consultation and engagement and helps promote an inclusive and participatory approach for stakeholder engagement in addressing any potential risks and negative impact, including a distinct channel for SEA/SH issues; promotes and provides means for effective and inclusive engagement of the project's affected parties throughout the project life-cycle; and ensures that appropriate program information is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner. All stakeholder consultations during this project preparation phase were carried out in accordance with the national COVID-19 prevention strategy, and the technical note on stakeholder engagement in World Bank-supported operations when there are constraints on conducting public meetings (March 20, 2020). The same attention will be observed during the project implementation phase. The SEP has been subject to consultation, and will be cleared and disclosed publicly both in-country and on the World Bank’s website by project appraisal. B.2. Specific Risks and Impacts A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions This standard is relevant. The project will involve direct workers and contracted workers. The direct workers include the civil servants assigned to the project and consultants hired for technical assistance. The project will also include Public Disclosure contractors and sub-contractors who will be hired predominantly under Component 1 and 2 to implement civil works undertaken associated with new building construction or rehabilitation, the installation of the National Fiber Optic backbone, expansion of last mile connectivity in rural area and (iii) the construction of two data centers. The terms and conditions of the contracts for any worker involved in the project will be consistent with national labor law, particularly the provisions of the relevant national law (Decree No 2018-0092/PRES/PM/MINIFID) and the requirements of ESS2. Civil servants working in connection with the project will remain subject to the terms and conditions of their existing public sector employment unless there is an effective legal transfer of employment or engagement to the project that is not expected. During the construction works, contractors will be required to provide laborers with necessary Personal Protective Equipment (PPE), such as boots, hardhats, and other equipment, depending on the areas in which they are deployed. The Borrower prepared a Labor Management Procedures (LMP) consistent with Burkinabe laws and regulations. The LMP aligns with ESS2 requirements on OHS requirements including COVID-19 risk management, terms and conditions of employment, non-discrimination, prevention/exclusion of child and forced labor from project activities, prevention of SEA/SH related risks, and labor specific GM to guide the development and establishment of functional grievance manuals on field. The Ministry and contractors will be required to sign and abide by a code of conduct for workers that would address community health and safety risks, including risks of SEA/SH and child labor. Jul 08, 2023 Page 7 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) The project will organize training for members of the technical preparation team and project workers before the beginning of relevant activities in order to make them aware of the labor risks and to mitigate the effects of the project on local populations. In all cases, for all identified project workers the following rules apply: the minimum age applicable for project workers is 18 - any workers under the age of 18 will not be employed or engaged in connection with the project. Forced labor - including involuntary or compulsory labor, such as contract work, bonded labor or any other similar contract - cannot be used within the framework of the project. These labor requirements will be reflected in the Project Implementation Manual. The LMP will be publicly disclosed both in country and on the Bank's website by project appraisal. ESS3 Resource Efficiency and Pollution Prevention and Management This standard is relevant. The fiber optic extension and deployment of last-mile broadband infrastructure will generate environment and social impacts. There are risks that air and water pollution could result from civil works, electronic waste, and hydrocarbon production. These risks are screened in the ESMF and appropriate mitigation measures are recommended including improving the efficient use of energy, water, and raw materials. It is anticipated that dust and noise will be generated by digging and construction/rehabilitation activities during project implementation. Those most likely to be affected are workers and people living within proximity of work sites. The implementation of mitigation measures such as dust suppression and vehicle maintenance will be incorporated into the contractor's ESMP (C-ESMP). The construction works will present short-term nuisance to the neighbors to some of the project sites. The Environmental and Social Management instruments to be prepared will include mitigation Public Disclosure measures to minimize and manage the noise levels such by applying standard restrictions to hours of site work where appropriate. Construction/ rehabilitation activities will generate solid waste which will primarily include excavated soil and solid wastes. The waste generated by the construction works will be disposed of at approved sites according with national laws and regulations. An electronic waste management plan which will be at project level will be prepared before the beginning of activities and also guide the project for managing waste to avoid or limit any pollution concerned; however, specific mitigation measures will be incorporated into subprojects ESIA/ESMPs. ESS4 Community Health and Safety This standard is relevant. There are substantial health and safety concerns, particularly during the civil works, as the project intervention sites will be located in urban and rural areas. Works in urban areas are likely to take place alongside roads with heavy traffic. To address this, the ESMF includes a chapter on community health and safety, security risk assessment and management provisions, incident reporting procedures generallabor management provisions/measures and SEA/SH mitigation measures. ESMPs for site-specific subprojects will include measures to address road security and SEA/SH risks, and all employees will sign Codes of Conduct that include SEA/SH provisions to prevent and protect local communities and women. Given the difficult security situation in Burkina Faso at the moment mainly with multiple homemade explosives attacks along of roads in rural areas, and potential risks to the project beneficiaries and/or project assets, the Borrower conducted a Security Risk Assessment (SRA) that will be validated prior to appraisal. On the basis of the Jul 08, 2023 Page 8 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) SRA, a Security Risk Management plan (SMP) has also been prepared and will be validated by appraisal. This has been done in accordance with ESS1 (Assessment and Management of Environmental and Social Risk and Impacts) and ESS4 (Community Health and Safety). Each site-specific ESMP for the works planned will take into account security provisions from SMP and require contractors to secure the site by installing fences and engaging security guards to safeguard property and protect local communities from risks associated with construction. The Borrower will be required to assess the risks posed by such security arrangements and incorporate the relevant measures, outlined in the good practice note (GPN), on the use of security personnel. It has not yet been determined what the scale of the labor influx associated with the project activities will be. However, a preliminary SEA/SH assessment showed a substancial risk rating and the Borrower shall develop a mitigation action plan which will be implemented throughout the project life-cycle. Mitigation measures within the ESMPs will provide safe and confidential venues to report SEA/SH-related complaints. A code of conduct, including measures against SEA/SH for ensuring community health and safety, will be prepared and included in all bidding documents. Contractors will be responsible for ensuring their workers’ compliance with codes of conduct. The project GM will be designed to safely and ethically register complaints and address and properly document complaints and allegations (including SEA/SH) during project implementation. The mapping of GBV service providers will be carried out and serve to set up a referencing protocol in accordance with survivors requirements management. Necessary preventive measures and awareness raising to direct workers and contracted workers against COVID19 contagion will also be implemented and monitored throughout the project implementation. Public Disclosure The ESMPs will make use of the General and Industry-specific Environmental Health and Safety Guidelines, defining specific measures to protect communities. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement This standard is relevant at this stage. Under Components 1 and 2, the project will finance civil works. Such activities could impact private property and lead to restriction on land use and involuntary resettlement. As the exact sites of these investments are unknown to date, a Resettlement Framework (RF) has been prepared to guide the preparation of subsquent Resettlement Action Plans (RAP) when project sites are known or delimited in accordance with the agreed schedule defined in the ESCP. The RF includes guidance for screening potential impacts and risks linked with ESS5 requirements before selecting the subproject investment site and measures to avoid, minimize and/or mitigate and properly address impacts and risks related to land used issues in accordance with ESS5 requirements. The RF will be finalized and disclosed both in the country and on World Bank's web site prior to board approval. When required, RAPs will be prepared, disclosed, and implemented in a manner satisfactory to the Bank and prior to the commencement of civil works during the implementation phase. ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources The proposed project is not expected to involve protected areas and biodiversity sites. The extension of the national fiber optic backbone to reach secondary administrative capitals may have the potential to affect habitats and the Jul 08, 2023 Page 9 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) biodiversity that they support. As the specific locations of project activities are not yet known, the ESMF contains checklists to help screen and manage biodiversity issues . Any impact on habitats will be assessed during the preparation of the site-specific ESMPs through the application of a mitigation hierarchy. The ESMPs will provide mitigation measures to ensure that project activities do not alter or cause the destruction of any critical or sensitive natural habitats. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities There are no known Indigenous Peoples/Sub-Saharan Historically Underserved Traditional Local Communities in the project area ESS8 Cultural Heritage It is not anticipated that the project will have a potential impact on known cultural heritage; however, since the project will be financing some civil works, some excavation of earth and earth movement are to be expected. These types of activities pose the possibility of encountering both known and unknown cultural heritage. As a first step, and in line with the mitigation hierarchy, known cultural heritage will be avoided. The ESMF includes provisions and procedures to follow in case of “Chance Finds”. Site-specific ESIAs/ESMPs environmental and social assessment process will confirm the existence of cultural heritage and provisions to manage any “chance finds”. The chance finds procedures will be included in the bidding documents. Therefore, all C-ESMPs and construction and rehabilitation contracts will include a “Chance Finds” clause which will require contractors to stop construction/rehabilitation in the Public Disclosure event that cultural heritage is encountered during civil works. The Ministry of Culture will be consulted and contacted in the event of any disturbance of cultural heritage. ESS9 Financial Intermediaries This standard does not apply to the project C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No OP 7.60 Projects in Disputed Areas No B.3. Reliance on Borrower’s policy, legal and institutional framework, relevant to the Project risks and impacts Is this project being prepared for use of Borrower Framework? No Areas where “Use of Borrower Framework” is being considered: The Borrower Framework will not be used Jul 08, 2023 Page 10 of 11 The World Bank Burkina Faso Digital Transformation Project (P177022) IV. CONTACT POINTS World Bank Contact: Tounwende Alain Sawadogo Title: Senior Digital Development Specialist Telephone No: 5350+2228 / 223-223-20702228 Email: tsawadogo@worldbank.org Contact: Amina Debissa Denboba Title: Senior Education Specialist Telephone No: 5353+88455 / -202-4588455 Email: adenboba@worldbank.org Borrower/Client/Recipient Borrower: Burkina Faso Implementing Agency(ies) Implementing Agency: Ministry of Digital Transition, Posts and Electronic Communications V. FOR MORE INFORMATION CONTACT The World Bank Public Disclosure 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Leader(s): Tounwende Alain Sawadogo, Amina Debissa Denboba Practice Manager (ENR/Social) Abdelaziz Lagnaoui Cleared on 06-Mar-2023 at 09:46:39 EST Jul 08, 2023 Page 11 of 11