Kingdom of Tonga Kingdom of Tonga Pathways to Employment and Resilience Project P181000 Draft ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 24 July 2024 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Kingdom of Tonga (the Recipient) will implement the Tonga Pathways to Employment and Resilience Project (the Project), with the involvement of the Ministry of Internal Affairs Tonga (MIA) and the Ministry of Finance (MoF) 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 ESS, 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 through Ministry of Internal Affairs and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient’s Chief Executive Officer for Ministry of Internal Affairs. The Recipient shall promptly disclose the updated ESCP. 2|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit six-monthly reports to the Association Project Management Unit throughout Project implementation, commencing (PMU) with support from the Prepare and submit to the Association regular monitoring reports on the after the Effective Date. Submit each report to the Central Services Unit (CSU) environmental, social, health and safety (ESHS) performance of the Project, Association not later than 30 days after the end of Environmental & Social (E&S) including but not limited to the implementation of the ESCP, status of each reporting period. Team. preparation and implementation of E&S instruments required under the ESCP, stakeholder engagement activities, and functioning of the grievance mechanisms. B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 hours after PMU with technical and learning of the incident or accident. oversight support from the Promptly notify the Association of any incident or accident related to the CSU E&S Team. Project which has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers, including, inter alia, cases of sexual exploitation and abuse (SEA), sexual harassment Provide subsequent report to the Association within (SH), and accidents that result in death, serious or multiple injury. Provide a timeframe acceptable to the Association. 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. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE PMU with technical support from the CSU E&S team 3|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1. Establish and maintain a PMU at MIA as (IA) in accordance with the 1. PMU structure shall be established in accordance 1. MIA Financing Agreement. The PMU shall be led by the Project Manager with the Financing Agreement and maintained reporting to the IA and will be staffed with qualified staff and resources to throughout Project Implementation. 2. PMU with technical support management of ESHS risks and impacts of the Project including an support from the CSU E&S E&S Officer at PMU/ CSU. 2. Engagement of PMU E&S Officer for the duration team of the project works, by no later than 3 months 2. Recruit PMU E&S Officer, with terms of reference, qualifications, and after the Effective Date of the Financing Agreement 3. MoF experience satisfactory to the Association, and who have the necessary skill for the Project. to manage the E&S risks and impacts associated with the Project. 3. CSU E&S staffing arrangement to be maintained 3. Maintain CSU E&S staffing arrangement including a full-time locally-based throughout Project Implementation. E&S Specialist and a full-time locally-based E&S Officer with terms of reference, qualifications, and experience satisfactory to the Association, and who have the necessary skill to provide capacity building on E&S risk management and provide implementation support to manage the E&S risks and impacts associated with the Tonga WB Portfolio. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS POM to be prepared and submitted for Association PMU with technical review and No Objection by the Effective Date. oversight from the CSU E&S Include and then implement the following in the Project Operation Manual Once adopted, implement the POM throughout team (POM): Project implementation. - A checklist to guide the storage, management and disposal of e- waste; - Clear eligibility/social inclusion criteria for participation in project activities; - Due diligence and environmental and social requirements for civil society and businesses participating in work placements activities; - Privacy and data protection requirements in relation to the consolidation of social protection beneficiary databases; - Environmental and social eligibility criteria and requirements for the entrepreneurial grant scheme for small business; 4|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY - environmental and social procedures for the CERC. 1.3 MANAGEMENT OF CONTRACTORS As part of the preparation of procurement PMU with technical and documents and respective contracts and oversight support from the Incorporate the relevant aspects of the ESCP, including, inter alia, the implemented throughout the Project CSU E&S team and relevant E&S instruments, the Labor Management Procedures, and code of implementation. Procurement teams conduct, into the ESHS specifications of the procurement documents and contracts with consultants and contracted workers. hereafter ensure that the consultants and contracted workers comply and staff and students on work placements to comply with the ESHS specifications of their respective contracts and standard agreements. 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. PMU with technical and oversight support from the Ensure that the consultancies, studies, capacity building, training, and any CSU E&S team 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. 1.5 CONTINGENT EMERGENCY RESPONSE COMPONENT 1. The adoption of the CERC Manual in form and MOF substance acceptable to the Association in line with 1. Ensure that the CERC Manual provides a description of the ESHS the conditions of disbursement provided in assessment and management arrangements for the implementation of Financing Agreement for the Project. CERC, Component 4, in accordance with the ESSs. 2. Adopt any required E&S instrument and include 2. Prepare, disclose and adopt any environmental and social (E&S) it as part of the respective bidding process, if instruments which may be required for activities under CERC, Component 4 applicable, and in any case, before the carrying out of the Project, in accordance with the CERC Manual including the E&S of the relevant Project activities for which the E&S procedures to be prepared in accordance with the ESSs, and thereafter instrument is required. Implement the E&S implement the measures and actions required under said E&S instruments, instruments in accordance with their terms, within the timeframes specified in said E&S instruments. throughout Project implementation. 5|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES PMU is responsible for the implementation of the LMP, ESS2 applies to all project workers under P2ER. Tongan public service Draft LMP has been prepared by Appraisal. LMP to with technical support by the legislation and regulations apply to PMU staff and national consultants be finalized and disclosed finalized no later than 3 CSU E&S team directly contracted by the PMU including the Public Service Act 2002 and the months after the Effective Date. Implement the LMP Tonga Public Service Policy Manual 2020. and all measures specified under action 2.1 through Project implementation. Prepare and implement Labor Management Procedures (LMP) for the Project for contracted workers and which responsibilities and requirements in relation to apprenticeship recipients. The LMP includes provisions, including, inter alia, on working conditions, management of workers relationships, occupational health and safety (including personal protective equipment, and emergency preparedness and response), measures to manage risks of sexual exploitation and abuse and sexual harassment (including through behavioral standards or code of conduct, and access to the project GRM which includes referral pathways for SEA/SH related grievances), forced labor, child labor, grievance arrangements for project workers, and applicable requirements for contractors, subcontractors, and supervising firms. Ensure that employment agreements created between the apprenticeship provider and the apprenticeship recipient, and contracts between the IA and the provider, include these provisions to ensure compliance with E&S requirements in line with ESS2 including details on roles and responsibilities of each party. 6|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish a Grievance Mechanism to be adopted PMU is responsible for the and operational within three months of the Project implementation of the Establish and operate a grievance mechanism for Project workers, as Effective Date. Maintain throughout Project Worker Grievance described in the LMP and consistent with ESS2. Implementation. Mechanism, with technical oversight by the CSU E&S team ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Timeline as noted in 1.2 above for the PMU with technical support implementation of measures in the POM. and oversight from the CSU Adopt and implement the waste management measures specified in the Thereafter implement throughout Project E&S team POM. For electronic/electric waste (ICT equipment), end of life waste implementation at the time of procurement of ICT management should be considered at the time of procurement and equipment. documented using the waste management checklist in the POM. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY Throughout Project Implementation. PMU with technical support and oversight from the CSU Assess, manage and monitor community health and safety risks associated E&S team with project activities and address any risks as they arise. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Draft SEP has been prepared and disclosed. SEP to PMU with technical support be finalized no later than 3 months after the and oversight from the CSU Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project, Effective Date. Thereafter implement the SEP E&S team consistent with ESS10, in a manner acceptable to the Association, which shall through Project implementation include 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. 7|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 10.2 PROJECT GRIEVANCE MECHANISM Grievance Mechanism to be established and PMU with technical support operational no later than 3 months after the and oversight from the CSU Establish, publicize, maintain, and operate an accessible grievance Effective Date. Maintain throughout Project E&S team mechanism, to receive and facilitate resolution of concerns and grievances in Implementation. relation to the Project, promptly and effectively, in a transparent manner that is culturally appropriate and readily accessible to all project-affected parties, at no cost and without retribution, including concerns and grievances filed anonymously, in a manner consistent with ESS10. 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 CAPACITY BUILDING PLAN No later than 3 months after the Effective Date. PMU to arrange training and PMU staff to receive training on project E&S instruments, the roles and keep records. responsibilities of different key agencies in E&S risk management. CSU E&S Team to prepare and deliver training. CS2 Project workers and other stakeholders to receive training on: On inception of all new workers to the project and PMU to arrange training and • Project’s E&S instruments and compliance requirements with the on regular intervals throughout Project keep records. WB ESSs. Implementation CSU E&S Team to prepare • Stakeholder engagement and Grievance mechanism and deliver training. implementation • Roles and Responsibilities for ES management • GBV and SEA/SH prevention and awareness raising. • Community and worker health and safety. CS3 CSU to develop an environmental and social capacity building and training No later than 3 months after the Effective Date. CSU E&S Team to prepare plan for PMU E&S Officers and contractors. plan and deliver training. 8|Page MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY CS4 CSU and PMU E&S Specialists and other project workers as relevant to receive Throughout project implementation. PMU training, as offered by external training providers, on areas of environmental and social risk management to support their capacity building. 9|Page