ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project Government of Rwanda Ministry of Environment Volcanoes Community Resilience Project (P178161) Draft ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) July, 2023 1 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Rwanda through the Ministry of Environment (MoE) (the Recipient) will implement the Volcanoes Community Resilience Project (the Project), with the involvement of the Rwanda Water Resources Board (RWB), Rwanda Meteorology Agency (Meteo Rwanda), Rwanda Environment Management Authority (REMA), and the Rwanda Development Board (RDB), as set out in the Financing Agreement. The International Development Association (hereinafter the Bank or the World Bank)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 Bank. 4. As agreed by the Bank 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 the MoE and the Bank agree to update the ESCP to reflect these changes through an exchange of letters signed between the Bank and the Recipient, Ministry of Finance and Economic Planning (MINECOFIN). The Recipient shall promptly disclose the updated ESCP. 2 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING The Government through MoE will prepare and submit to the Bank, regular monitoring Submit consolidated quarterly reports Single Project reports on the development and implementation of the environmental, social, health and to the Bank throughout Project Implementation Units safety (ESHS) performance of the Project, including but not limited to the implementation implementation, [commencing after the (SPIUs: RWB, REMA, of the ESCP, status of preparation and implementation of E&S instruments required under Effective Date]. Submit each report to RDB, Meteo Rwanda) the ESCP, stakeholder engagement activities, and functioning of the grievance the Bank no later than 15 days after the through MoE which will mechanism(s), Incidents and accidents, Capacity building programs conducted, Activities end of each reporting period. compile one report & planned for the next reporting period. submit to the Bank. B INCIDENTS AND ACCIDENTS Environmental and Promptly notify the Bank of any incident or accident related to the Project which has, or is Immediately, and no later than 48 hours Social Risk likely to have, a significant adverse effect on the environment, the affected communities, after learning of the incident or Management staff of the public or workers, including, inter alia, cases of sexual exploitation and abuse (SEA), accident. SPIUs (REMA, RWB, sexual harassment (SH), and accidents that result in death, serious or multiple injury. RDB, Meteo Rwanda) Provide sufficient detail regarding the scope, severity, and possible causes of the incident Provide a subsequent report to the Bank through MoE or accident, indicating immediate measures taken or that are planned to be taken to within a timeframe acceptable to the address it, and any information provided by any contractor and/or supervising firm, as Bank. appropriate. Subsequently, at the Bank’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 Require contractors and supervising firms to provide progress monthly monitoring Monthly or upon request as annexes to SPIUs (REMA, RWB, reports on ESHS performance in accordance with the metrics specified in the respective the reports to be submitted under RDB, Meteo Rwanda) bidding documents and contracts and submit such reports to the Bank. action A above. through MoE 1 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY D NOTIFICATIONS RELATING TO DAAB COMPLIANCE REVIEW OF CONTRACTOR No later than 7 days after the issuance SPIUs (REMA, RWB, COMPLIANCE WITH SEA/SH PREVENTION AND RESPONSE OBLIGATIONS or receipt, as applicable, of the relevant RDB, Meteo Rwanda) Notify the Bank of any referral submitted to the Dispute Avoidance and Adjudication document (i.e., referral to the DAAB, through MoE Board (DAAB) to initiate a process of compliance review in relation to a contractor’s issuance of DAAB decision, Notice of obligations to prevent and respond to sexual exploitation and abuse (SEA), and/or sexual Dissatisfaction, notice of harassment (SH) specified in the respective works contract with such contractor; and, in commencement of emergency/full the event of any such referral, notify the Bank of: (i) the DAAB’s decision on such arbitration, emergency/full arbitration referral; (ii) the contractor’s Notice of Dissatisfaction, if any, with such DAAB decision; order, as applicable). (iii) any notification received on the commencement of an emergency arbitration proceeding or full arbitration proceeding in relation to the DAAB’s decision; and (iv) the resulting emergency arbitration order and/or full arbitration order, if any. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Expand the Single Project Implementation Unit (SPIU) in MoE as the coordination entity SPIUs of MoE, RWB, REMA and RDB will MoE and SPIUs (RWB, with qualified staff and resources to support the management of ESHS risks and impacts each appoint the specified full time staff RDB, and REMA, Meteo of the Project. Engage an Environmental Risk Management Specialist, Social Risk for the project by project effectiveness. Rwanda). Management Specialist, and Community Engagement, and Development Specialist. In addition, the Single Project Implementation Units (SPIUs: REMA, RWB and Meteo) will have a unit comprising Environmental and Social Risk Management Specialists in each of their respective SPIUs to support the management of ESHS risks and impacts. The Rwanda Water Resources Board (RWB) will appoint a full time one Environmental and Social Risk Management Specialist and one Gender Specialist. Rwanda Environment Management Authority (REMA) will appoint a full time Environmental Risk Management Specialist, a full time Social Risk Management Specialist, a Community Development Specialist, and a fulltime Ecology Specialist. Rwanda Development Board (RDB) will hire a Technical Assistant (TA) to support in environmental and social aspects of component 3. The TA will include Environmental and Social Safeguard Expert and Community Engagement Expert Rwanda Meteorological Agency will appoint an Environmental and Social Risk Management Specialist 2 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY In addition, the district project hubs will be established and will each involve 3 District MoE to make sure hubs staff are in Environmental Officers and 3 Community Development Officers. The project will have place by project effectiveness. three district hubs as follows: Hub1 serving the districts of Burera and Musanze seated in MoE and SPIUs Musanze District, Hub 2 serving the districts of Nyabihu, Rubavu and Rutsiro seated in Rubavu District, and Hub 3 serving the districts of Ngororero, Muhanga and Gakenke seated in Muhanga District. The Environmental and Social Risk Management Staff at the Ministry of Environment will coordinate and support the implementing partners and district project hubs. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS 1. Adopt and implement an Environmental and Social Management Framework (ESMF) 1a. The ESMF, SEP, RPF are under MoE and SPIUs (REMA, and Resettlement Policy Framework (RPF); Labour Management Procedures (LMP); preparation and will be ready before RDB, RWB, Meteo Stakeholder Engagement Plan (SEP), and Gender and Gender Based Violence Action Plan project appraisal. Rwanda) (GAP) for the Project, consistent with the relevant ESSs. 1b. LMP and GAP before project effectiveness and implemented 2. Adopt and implement an Environmental and Social Impact Assessment (ESIA), and throughout project implementation corresponding Environmental and Social Management Plan (ESMP) Resettlement Action Plan (RAP), or other appropriate environment and social risk management instruments (environment and social audit, occupational health and safety, etc) for the park 2. ESIA/ESMP and RAP for park expansion and green village implementation component 3, consistent with the relevant expansion by project appraisal and ESSs. implemented throughout project implementation. 3. Adopt and implement an Environmental and Social Impact Assessment (ESIA), and corresponding Environmental and Social Management Plan (ESMP) Resettlement Action Plan (RAP), or other appropriate environment and social risk management instruments (environment and social audit, occupational health and safety, biodiversity management 3. ESIA/ESMP, RAP: Prior to the plan, etc.,) for the sub Projects of flood management structures in component 1, and procurement of related activities, and ecological restoration plan for park expansion in component 2, consistent with the after adoption, implemented relevant ESSs as specified in the ESMF. throughout the project implementation 3 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 4. The Ministry of Environment as a Coordinating Entity will ensure that RWB, REMA, Meteo Rwanda and RDB adopt and implement the site-specific Environmental and Social Impact Assessment (ESIA) and Environmental and Social Management Plan (ESMP) and Resettlement Action Plan (RAP) or any other relevant plan as set out in the ESMF. The proposed activities described in the exclusion list set out in the ESMF shall be ineligible to receive financing under the Project. 1.3 MANAGEMENT OF CONTRACTORS As part of the preparation of MoE and SPIUs (RWB, Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant projects procurement documents and respective RDB, Meteo Rwanda, and subprojects E&S instruments, the Labor Management Procedures, and code of contracts. and REMA) conduct, into the ESHS specifications of the procurement documents and contracts with Supervise contractors throughout contractors and supervising firms. Thereafter ensure that the contractors and Project implementation. supervising firms comply and cause subcontractors to comply with the ESHS specifications of their respective contracts. 1.4 TECHNICAL ASSISTANCE Ensure that the consultancies, studies (e.g., study on ecological restoration, study on Throughout Project implementation. MoE and SPIUs (RWB, livelihood improvement, feasibility studies and designs for flood reduction infrastructure, RDB, Meteo Rwanda, and others that might be needed at latter stage but cannot be predicted now), capacity and REMA) building, training, and any other technical assistance activities under the Project, including, inter alia, that E&S risk management instruments as specified under 1.2 are carried out in accordance with terms of reference acceptable to the 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 and implement the Labor Management Procedures (LMP) for the Project, including, LMP will be finalized prior to the project MoE and SPIUs (RWB, inter alia, provisions on working conditions, management of workers relationships, effectiveness and implemented RDB, Meteo Rwanda, occupational health and safety (including personal protective equipment, and emergency throughout project implementation, its and REMA) through preparedness and response), code of conduct (including relating to SEA and SH), forced provisions will be included in tender their SPIUs labor, child labor, grievance mechanism (GM) for Project workers, and applicable documents. requirements for contractors, subcontractors, and supervising firms. The workers grievance committees will be elected before start of works. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 4 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 3.1 WASTE MANAGEMENT PLAN MoE and SPIUs (RWB, Adopt and implement a Waste Management Plan (WMP), to manage hazardous and The WMP will be prepared by the RDB, and REMA) non-hazardous wastes, consistent with ESS3. As per the ESMF, subproject specific ESS3 Contractor before subproject through their respective related requirements will be established in subproject instruments (e.g., ESIAs, ESMPS) commencement (as part of Contractor’s Environmental and bids and contracts). Environmental and Social Management Social Risk Subprojects will incorporate waste management measures recommended by the ESMF Plan (CESMP) and implemented Management staff. into subproject ESMPs and contractors’ CESMPs. throughout the sub project implementation. Adopt and implement waste management plan at operation phase of the green village Prior to the subproject commencement and observed throughout the project implementation. MoE and SPIUs RDB, and REMA. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT MoE and SPIUs (RWB, Feasible measures (financially and technically) for improving efficiency in consumption of Prior to the subproject commencement RDB, and REMA) energy and water, as well as other resources and material inputs will be identified as part of ESIA/ ESMPs and observed through their respective through the specific ESIAs and ESMPs to be prepared under action 1.2. throughout the project implementation Environmental and Social Risk Management staff ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY MoE and SPIUs (RWB, Appropriate measures will be identified, and plans prepared and implemented to ensure Prior to the commencement of the RDB, and REMA) road safety and minimize traffic accidents. These will be part of the site-specific subprojects as part of subprojects ESMP through their respective ESIAs/ESMPs. Traffic management plans/ measures will cover procedures to undertake and implemented throughout the sub Environmental and pre-construction checks for any roads to be used for transport of construction- and project implementation. Social Risk access materials to ensure roads are suitable and contractors will have to develop their Management Staff own traffic management plans (based on the ESMP), diligent implementation to be supervised and monitored by MoE and IPs. . 4.2 COMMUNITY HEALTH AND SAFETY With reference to the project ESMF, in line with ESS4, adopt appropriate measures to Prior to the appraisal as part of the address the following risks and impacts: ESMF of the project and throughout the - Transmissible diseases (e.g. HIV/AIDS) and communicable diseases (e.g. corona project implementation virus, influenza,..) 5 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY - Hazardous material and other harmful substances MoE and SPIUs (RWB, - Emergency preparedness and response RDB, and REMA) - Labor influx through their respective - Traffic and road safety Environmental and - Community exposure to health issues Social Risk - Gender based violence Management Staff Contractors will develop their own traffic management plan, labour influx management plan, emergency management plan, hazardous material management plan, diseases prevention plan and diligent implementation will be supervised and monitored by the supervising firms, implementing partners and project coordination unit.. MoE and IPs to ensure diligent implementation during project operation, through responsible agencies as appropriate. 4.3 SEA AND SH RISKS MoE and SPIUs (RWB, According to the provisions of the updated ESMF, develop, adopt and implement Prior to the project effectiveness and RDB, and REMA) measures and actions to assess and manage the risks of gender-based violence (GBV), observed throughout the project through their respective sexual exploitation and abuse (SEA) and sexually transmitted diseases. ESMP to comprise implementation. Environmental and comprehensive and culturally appropriate measures to address risks and impacts and to Social Risk undertake appropriate sensitization, awareness rising and capacity building for local Management Staff communities, including social institutions such as schools. SEP and ESMP will contain provisions for additional community-based monitoring and reporting. SEP and ESMP to incorporate relevant provisions from WB’s Guidance Note on Management of Gender Based Violence (2017). The Project’s Grievance Mechanism to cover special provisions for victims of GBV as appropriate. Workers Code of Conduct to comprehensively cover the areas of GBV, SEA and STD, including relevant disciplinary measures, penalties and provisions for prosecution. Contractors will have to develop their own management- and community liaison plans covering community health and safety (based on the ESMP), diligent implementation to be supervised and monitored by MoE and IPs. 6 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 4.4 SECURITY MANAGEMENT SPIUs (RWB, RDB, and Adopt and implement ESMF guidance on measures to ensure diligent selection, Prior to the sub project implementation REMA) through their operation and supervision of security personnel. as part of the ESMP and observed respective Contractors will have to develop their own security management plans, diligent throughout the project implementation. Environmental and implementation to be supervised and monitored by MoE and IPs. Social Risk Management staff ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT POLICY FRAMEWORK MoE and SPIUs (RWB, Adopt and implement a Resettlement Policy Framework (RPF) for the Project, consistent Adopt and implement RPF throughout RDB, and REMA) with ESS5. Conduct due diligence prior to commencement of any resettlement related project implementation. through their respective activities, and thereafter implement the RPF throughout Project implementation. Environmental and Subproject sites to be screened for resettlement impacts prior to commencement of any Social Risk activities. Management Staff 5.2 RESETTLEMENT PLANS MoE and SPIUs (RWB, Prepare site specific resettlement action plans (RAPs) or proportional resettlement Prior to the implementation of activities RDB, and REMA) action plans consistent with the requirements of the Resettlement Policy Framework on site. through their respective (RPF) that has been prepared for the Project in line with ESS5, in a manner acceptable to Environmental and the MoE, IPs, and the World Bank, and thereafter implement the respective RAPs before Social Risk carrying out any project works that involve involuntary resettlement. Management Staff 5.3 GRIEVANCE MECHANISM MoE and SPIUs (RWB, Develop and implement the arrangements for the grievance mechanism for resettlement Before commencement of project RDB, and REMA) as described in the RPF and SEP in line with ESS10 requirements activities and throughout Project through their respective implementation Environmental and Social Risk Management Staff ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS MoE and SPIUs (RWB, According to the provisions of the ESMF, ESS6 measures will be identified through the Before commencement of sub project RDB, and REMA) specific ESIAs and ESMPs to be prepared under action 1.2. And for the Volcanoes activities and throughout Project through their respective national park expansion area under component 2 and its buffer zone implementation Environmental and ecosystem restoration plan/ biodiversity management plan. Social Risk MoE and IPs will ensure diligent implementation of biodiversity management measures Management Staff during project operation, through responsible agencies as appropriate. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not Applicable Not Applicable 7 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 8: CULTURAL HERITAGE 8.1 CULTURAL HERITAGE RISKS AND IMPACTS MoE and SPIUs (RWB, Baseline survey and impact assessment as appropriate will be undertaken in the course Before commencement of project RDB, and REMA) of the ESIA. Specific attention will be given to cultural heritage linked to natural features activities and throughout Project through their respective such as trees, rocks and shrines. Any impacts on graves from the project will be dealt implementation Environmental and with in the RAP. Social Risk Management Staff in collaboration with Districts, and Ministry of Youth and Culture (MYCULTURE) 8.2 CHANCE FINDS MoE and SPIUs (RWB, The ESIAs/ESMPs to be prepared (action 1.2) will incorporate chance find procedures in Before commencement of project RDB, and REMA) case valuable artifacts or culturally valuable materials are found during Project activities and implemented throughout through their respective implementation. Project implementation. Same Environmental and timeframe as for the ESIA/ESMP Social Risk Management Staff in in collaboration with RDB, REMA, MYCULTURE, and Districts ESS 9: FINANCIAL INTERMEDIARIES Not Applicable Not Applicable ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION MoE and SPIUs (RWB, MoE and all implementing institutions Adopt and implement a Stakeholder Engagement Finalize SEP prior to project appraisal RDB, and REMA) Plan (SEP) for the Project, consistent with ESS10, which shall include measures to, inter and thereafter implement the SEP as through their respective alia, provide stakeholders with timely, relevant, understandable and accessible required throughout the project Environmental and information in a culturally appropriate manner, which is free of manipulation, implementation period. SEP can be Social Risk Management interference, coercion, discrimination and intimidation. updated when required. Staff 10.2 PROJECT GRIEVANCE MECHANISM MoE and SPIUs (RWB, Establish, maintain and operate a grievance mechanism to ensure reception and timely Adopt and implement a grievance RDB, and REMA) response to any complaints made about the Project (including those from members of mechanism prior to commencement of through their respective the communities, local businesses and other stakeholders), as described in the SEP. project activities and throughout Environmental and project implementation. Social Risk Management Staff 8 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY An accessible grievance mechanism shall be established, publicized, maintained and operated to receive and facilitate resolution of concerns and grievances in 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 also receive, register and address concerns and grievances related to sexual exploitation and abuse, sexual harassment in a safe and confidential manner, including through the referral of survivors to gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. CAPACITY SUPPORT CS1 Training to be provided for MoE and PIU staff and other stakeholders like Districts, Planning for capacity building training at MoE, SPIUs (RWB, RDB, Contractors and Consultants include: the start (during the first year) of the Meteo Rwanda, and � Training plan will be prepared referring to the provisions of ESMF on Capacity Building project. This plan will be updated REMA) of project staff & stakeholders at different levels (national, District, and community). annually based on the need assessment The trainings will focus on the following topics: Overview of EHS subproject findings and annual plan collected from contract EHS requirements (plans, staffing, mitigation, monitoring, and the project implementing institutions reporting, etc.) and Districts. Throughout project preparation and implementation � Environmental and Social monitoring and reporting on EHS performance of the project. � Health, Safety and Environment Awareness raising sessions for the community shall be conducted and strengthened, including training to strengthen stakeholder capacity in coordinating, planning, implementing and monitoring environmental and social issues in catchment treatment works. � Stakeholder mapping and engagement � Supervision of ESMP implementation, monitoring and reporting � Grievance management/ use of e-GRM � Assessment of environmental and social risks � GBV, SEA, SH, � Community health and safety � RAP/LRP implementation monitoring � Community awareness training on mitigation and management of ES in subprojects, esp. in livelihood enhancement schemes. � Further topics to be defined 9 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Volcano Community Resilience Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY CS2 PIUs will develop and implement training and awareness for Project workers and the Prior to the project commencement and SPIUs (RWB, RDB, community on occupational health and safety including on emergency prevention and through the Project’s Implementation Meteo Rwanda and preparedness, as well as on consultation and capacity building of local communities phase REMA) through their regarding GBV, SEA/SH and STD. respective Environmental and Social Risk Management Staff 10 | Page