Ministry of Basic and Secondary School Education (MBSSE) SIERRA LEONE FREE EDUCATION PROJECT ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) June 20, 2023 1|Page ENVIRONMENTAL & SOCIAL COMMITMENT PLAN - ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Sierra Leone (the Recipient) is implementing FREE Education Project (the Project), with the involvement of the Ministry of Basic and Secondary School Education (MBSSE), as set out in the Financing Agreement. The International Development Association (the Association) has agreed to provide the Original Financing (P167897) and Additional Financing (P178704) for the Project, as set out in the referred agreement. This ESCP supersedes previous versions of the ESCP for the Project and shall apply both to the Original Financing and the Additional Financing for the Project referred to above. 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 support, 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 as 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 the Minister of MBSSE, 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 authorized representative. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL & SOCIAL COMMITMENT PLAN - ENHANCING SIERRA LEONE ENERGY ACCESS PROJECT ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – SIERRA LEONE FREE EDUCAITON PROJECT MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING FEPs/MBSSE Prepare and submit to the Association regular monitoring reports on the environmental, Quarterly reporting to the Association is social, health and safety (ESHS) performance of the Project, including but not limited to ongoing for the parent project and will the implementation of the ESCP, the status of preparation and implementation of E&S be extended to cover the Additional instruments required under the ESCP (including, inter alia, the Environmental and Social Financing throughout project Management Plan (ESMP), Labor Management Procedures (LMP), Sexual Exploitation implementation. Each report shall be and Abuse and Sexual Harassment (SEA/SH) Action Plan), stakeholder engagement submitted to the Association no later activities, functioning of the grievance mechanisms. than five (5) days after the end of each reporting period. An Environmental and Social Management and Reporting System (ESMRS)using digital tools shall be established to coordinate E&S reporting for all sub-project Maintain ES reporting system throughout project implementation. B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 FEPs/MBSSE hours after learning of the incident or Promptly notify the Association of any incident or accident related to the Project which accident. 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 Provide subsequent report to the abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or Association within a timeframe multiple injuries. Provide sufficient detail regarding the scope, severity, and possible acceptable to the Association 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 CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports to the FEPs/Clark of works/ Association upon request as annexes to Contractor Require contractors and Clerk of works to provide monthly monitoring reports on ESHS the reports to be submitted under performance in accordance with the metrics specified in the respective bidding action A above. documents and contracts, and submit such reports to the Association. Conduct annual E&S audit of civil works by a third party. Annually throughout project FEPs/MBSSE implementation 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – SIERRA LEONE FREE EDUCAITON PROJECT MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE FEPs/MBSSE Maintain the existing Free Education Secretariat (FEPs) at MBSSE with the qualified a. The Project has staffed the Environmental Specialist and Social and Gender Specialist to support the management required E&S specialists. These of E&S risks for both the parent project and AF. positions shall be maintained throughout Project The FEPs have recruited and shall maintain the 18 Clerks of Works positions to support implementation. construction supervision. b. The Clerks of Works have been Additionally, the E&S Specialists at the national level in FEPs shall be supported by recruited and these positions Environment and Social Officers (ESOs) at the Local Councils to implement the project. will be maintained throughout the constructions. c. MOU with Local councils on the terms of engagement with the project will be approved by June 15, 2023. Thereafter, ESOs will be supporting E&S supervision throughout project implementation. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – SIERRA LEONE FREE EDUCAITON PROJECT MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS a. The ESMF of the Original FEPs/MBSSE Financing project was prepared a. Update the existing ESMF to include risk assessment and management and disclosed on June 7, 2019. measures supported under the additional financing. Thereafter, disclose, This ESMF shall be updated consult upon, and implement the updated ESMF, consistent with the relevant and redisclosed within 1 month ESSs. after the Effective Date of the Additional Financing. The b. Prepare and update as relevant, disclose, consult upon, adopt and implement Recipient shall implement the an Environmental and Social Impact Assessment (ESIA), and/or Environmental updated ESMF throughout and Social Management Plan (ESMP) for infrastructure/works under Project implementation. Component 3 of the Project for which the ESIA/ESMP is required, consistent with the relevant ESSs. b. Prepare and update as relevant, disclose, consult c. Cause other implementing entities such as the ministry of health and the NGO upon, adopt the ESIA and or consortium to adopt and implement requirements of the ESCP including, inter ESMP prior to initiation of alia, the relevant E&S instruments, the Labor Management Procedures, and the construction activities, and SEA/SH Action Plan into their contracts. Thereafter ensure that the these thereafter implement the ESIA entities comply with the ES requirement of their respective contracts. and or ESMP throughout Project implementation. d. Secure environmental permits for all new construction and rehabilitation under the Project. c. As part of respective entities constract thereafter supervise implementation throughout project implementation. d. Secure environmental permits prior to initiation of construction. Thereafter, abide by the terms of permits throughout project implementation 1.3 MANAGEMENT OF CONTRACTORS FEPs/MBSSE/ contractors As part of the preparation of procurement documents and respective contracts. Supervise contractors throughout Project implementation. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – SIERRA LEONE FREE EDUCAITON PROJECT MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S instruments, the Labor Management Procedures, and the code of conduct, into the ESHS specifications of the procurement documents and contracts with contractors and supervising firms. Thereafter ensure that the contractors and supervising firms comply Before the commencement of the and cause subcontractors to comply with the ESHS specifications of their respective construction activities. contracts. Contractors will submit C-ESMPs prior to the start of the construction works for the approval of FPEs 1.4 TECHNICAL ASSISTANCE FEPs/MBSSE Ensure that the consultancies, studies (including feasibility studies), capacity building, Throughout Project implementation. 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 An LMP prepared and disclosed as part FEPs/MBSSE/ Contractors of the ESMF of the Original Financing on Update the existing Labor Management Procedures (LMP) annexed to the ESMF of the (June 7, 2019) shall be updated and parent project and implement the LMP, including, inter alia, provisions on working redisclosed within 1 month after the conditions, management of workers relationships, occupational health and safety Effective Date of the Additional (including personal protective equipment, and emergency preparedness and response), Financing and implemented throughout code of conduct (including relating to SEA and SH), forced labor, child labor, grievance Project implementation. arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Maintain worker's grievance FEPs/MBSSE mechanism and operate it throughout Establish and operate a grievance mechanism for Project workers, as described in the Project implementation. LMP and consistent with ESS2. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN FEPs/MBSSE a. Prepare, adopt and implement a Waste Management Plan (WMP) as part of a. same timeframe for the contractor ESMP, to manage hazardous and non-hazardous wastes, consistent adoption and implementation with ESS3. of the C-ESMP. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – SIERRA LEONE FREE EDUCAITON PROJECT MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY b. The ESMF shall be updated to reflect risk management of activities specifically b. Same timeframe as for the supported under the AF, in particular, those related to use and disposal of first adoption and implementation aid kits in schools. of the updated ESMF under action 1.2 above. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT FEPs/MBSSE Incorporate resource efficiency and pollution prevention and management measures in Same timeframe as for the adoption the ESMP to be prepared under action 1.2 above. and implementation of the ESMP. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY FEPs/MBSSE Incorporate measures to manage traffic and road safety risks as required in the ESMP to Same timeframe as for the adoption be prepared under action 1.2 above. and implementation of the ESMP. 4.2 COMMUNITY HEALTH AND SAFETY FEPs/MBSSE Assess and manage specific risks and impacts to the community arising from Project Same timeframe as for the adoption activities including, inter alia, behavior of Project workers, risks of labor influx, response and implementation of the ESMPs. to emergency situations, accidents and pollution, sexual exploitation and abuse, sexual harassment, and include mitigation measures in the ESMPs to be prepared in accordance with the ESMF. 4.3 SEA AND SH RISKS a. The SEA/SH Action Plan has been FEPs/MBSSE prepared and shall be updated and a. Adopt and implement a SEA/SH Action Plan to assess and manage the risks of disclosed one month after effectiveness SEA and SH. of the Additional Financing, and thereafter implemented throughout b. A service provider has been hired to support the SEA/SH prevention and Project implementation. response efforts and shall be maintained for the AF. b. Service provider has been recruited c. Train Project workers and conduct stakeholder sensitization activities on Project and will be maintained for the AF. activities and relevant SEA/SH mitigation processes. c. Throughout Project implementation d. Undertake regular monitoring and evaluation of progress on SEA/SH measures, including reassessment of risks as appropriate. d. Throughout Project implementation 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – SIERRA LEONE FREE EDUCAITON PROJECT MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY e. Contractors shall adopt the Project SEA/SH Action Plan as part of Contractor e. Contractors shall adopt the Project ESMP and shall implement these provisions. The Recipient shall supervise SEA/SH as part of the C-ESMP prior to contractors throughout Project implementation. the recruitment of contractor workers. Supervision of contractors throughout Project implementation. 4.4 SECURITY MANAGEMENT FEPs/MBSSE Prior to engaging security personnel Assess and implement measures to manage the security risks of the Project, including and thereafter implemented the risks of engaging security personnel to safeguard project workers, sites, assets, and throughout Project implementation. activities. Such measures are reflected in the ESMP and shall be guided by the principles of proportionality and Good International Industry Practice (GIIP), and by applicable law, in relation to hiring, rules of conduct, training, equipping, and monitoring of such personnel. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK The RPF of the Original Financing was FEPs/MBSSE prepared and disclosed June 7, 2019) The project has prepared and disclosed a Resettlement Policy Framework (RPF) for the and shall be implemented throughout Project, consistent with ESS5. Project implementation. 5.2 RESETTLEMENT PLANS Prepare, disclose, consult upon, and FEPs/MBSSE adopt and implement the respective Prepare, disclose, consult upon, adopt and implement a resettlement action plan (RAP) RAP, including ensuring that before for each activity under the Project for which the RPF requires such RAP, as set out in the taking possession of the land and RPF, and consistent with ESS5. related assets, full compensation has been provided and, as applicable, displaced people have been resettled and moving allowances have been provided. 5.3 GRIEVANCE MECHANISM Operationalize the GM prior to initiating FEPs/MBSSE the RAP process. The grievance mechanism (GM) to address the Project including resettlement-related complaints shall be described in the RPF, RAPs and SEP. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS Screen for Biodiversity risk prior to FEPs/MBSSE initiation of any sub-project. 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – SIERRA LEONE FREE EDUCAITON PROJECT MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY The ESMF includes a procedure for screening biodiversity risks and impacts. In the unlikely event, that significant biodiversity risk is observed from the screening, the site shall be declared ineligible for construction. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 Not relevant. ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS The chance find procedures are already FEPs/MBSSE described in the ESMF for the original Describe and implement the chance finds procedures as part of the ESMF of the Project. financing. Implement these procedures throughout Project implementation. ESS 9: FINANCIAL INTERMEDIARIES 9.1 Not relevant. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION FEPs/MBSSE Adopt and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent The SEP of the Original Financing was with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, prepared and disclosed (June7, 2019). It relevant, understandable and accessible information, and consult with them in a was updated and redisclosed for the culturally appropriate manner that is free of manipulation, interference, coercion, first additional financing on September discrimination and intimidation. 11, 2020. The SEP shall further be updated for the second additional financing prior to project appraisal and be implemented throughout Project implementation. 10.2 PROJECT GRIEVANCE MECHANISM Project GRM has been established for FEPs/MBSSE the original financing. This shall be Establish, publicize, maintain, and operate an accessible grievance mechanism to receive maintained for the AF and operated and facilitate the resolution of concerns and grievances in relation to the Project, throughout Project implementation. 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 GRM will incorporate digital platforms for grievance recording, tracking and reporting. 9|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – SIERRA LEONE FREE EDUCAITON PROJECT MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 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 The following types of training will be provided to the relevant target groups, such as Quarterly and as needed throughout FEPs/MBSSE project staff, stakeholder community, project workers, consultants, contractors, and Project implementation sub-contractors: • E&S screening • Preparatin and implementation of ESMPs • E&S management of construction impacts • stakeholder mapping and engagement • emergency preparedness and response • community health and safety. • GBV/SEA/SH awareness, prevention, reporting and management protocols • Social inclusion • Labor and Management Procedure • Occupational Health and Safety • Waste management (domestic solid wastes and sewage) • School Health Management Training • Contractor management • Additional training that will be identified during implementation. CS2 Conduct training for Project workers on Labor and working conditions, health and safety, Quarterly and as needed throughout FEPs/MBSSE incident and accident report Project implementation 10 | P a g e