Federal Republic of Nigeria Ministry of Budget and Economic Planning, Ministry of Education, and Ministry of Health and Social Welfare Nigeria: Human Capital Opportunities for Prosperity and Equality - Governance (HOPE - GOV) Program (P181476) (Part 2 -Investment Project Financing Component) Negotiated ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) August 27, 2024 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Federal Republic of Nigeria (the Recipient) will implement the Nigeria Human Capital Opportunities for Prosperity and Equality -Governance (HOPE-GOV) Program (P181476) (the Operation), with the involvement of the Federal Ministry of Finance (FMoF); the Federal Ministry of Budget Economic Planning (FMBEP), the Federal Ministry of Education (FME) and the Federal Ministry of Health and Social Welfare (FMOHSW)] and cause the Operation to be carried out by the Participating States and the Universal Basic Education Commission (“UBEC� or the “Operation Implementing Entity�), as set out in the Financing Agreement. The International Development Association (the Association) has agreed to provide financing for the Operation as set out in the referred agreement. The Operation consists of a Program-for-Results Financing component described in Part 1 of Schedule 1 to the Financing Agreement (the “Program�) and an IPF Component described in Part 2 of Schedule 1 to the Financing Agreement (the “Project�). 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 the Ministry of Budget and Economic Planning and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient through the Minister of Budget and Economic Planning. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Nigeria: Human Capital Opportunities for Prosperity and Equality (HOPE) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit six-monthly reports to the Association National Program Prepare and submit to the Association regular monitoring reports on the throughout Project implementation, Coordination Unit environmental, social, health and safety (ESHS) performance of the Project, including commencing after the Effective Date. Submit (NPCU) at the Federal but not limited to the implementation of the ESCP, status of preparation and each report to the Association no later than 14 Ministry of Budget and implementation of E&S instruments required under the ESCP, stakeholder days after the end of each reporting period. Economic Planning engagement activities, and functioning of the grievance mechanisms B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 hours NPCU after learning of the incident or accident. Promptly notify the Association of any incident or accident related to the Project which has, or is likely to have, a significant adverse effect on the environment, the Notify the Association of fatality or SEA/SH affected communities, the public or workers, including, inter alia, cases of sexual incidents within 24 hours of learning of the exploitation and abuse (SEA), sexual harassment (SH), and accidents that result in incident. death, serious or multiple injury. Provide sufficient detail regarding the scope, severity, and possible causes of the incident or accident, indicating immediate Provide subsequent report to the Association measures taken or that are planned to be taken to address it, and any information within a timeframe acceptable to the provided by any contractor and/or supervising firm, as appropriate. Association as requested. 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 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.1 ORGANIZATIONAL STRUCTURE Establish and maintain an NPCU as set out in the NPCU and Participating Establish and maintain one qualified E&S staff and resources to support Financing Agreement. States management of ESHS risks and impacts of the Project at the NPCU and Participating States Assign an E&S officer (1 person) responsible for E&S no later than one month after the Effective Date and thereafter maintain the position throughout Project implementation. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS 1. Prepare, disclose, consult upon, and adopt NPCU Prepare, consult upon, adopt, disclose, and implement the following instruments in the SEP by August 20th 2024. accordance with the ESSs and in a manner acceptable to the Association: Implement requirements of the SEP throughout Project implementation. 1. Stakeholder Engagement Plan (SEP) 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Nigeria: Human Capital Opportunities for Prosperity and Equality (HOPE) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 2. Labour Management Procedure 2. Prepare, disclose, consult upon, and adopt the LMP no later than three months after the Effective Date and prior to engaging Project workers and implement it throughout the Project implementation. 1.3 TECHNICAL ASSISTANCE Throughout Project implementation. NPCU Ensure that the consultancies, studies (including feasibility studies, if applicable), capacity building, training, and any other technical assistance activities under the Project are carried out in accordance with terms of reference acceptable to the Association that are consistent with the ESSs. Thereafter ensure that the outputs of such activities comply with the terms of reference. 1.4 ACTIVITIES SUBJECT TO RETROACTIVE FINANCING From Project Concept to the Effective Date. NPCU Retroactive financing on the IPF will only cover consultancies and other operating expenses. No works will be financed. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOUR MANAGEMENT PROCEDURES Adopt the LMP no later than three months after NPCU and Participating Adopt and implement the Labour Management Procedure (LMP) including, inter alia, the Effective Date, but before engaging Project States provisions on working conditions, management of workers ’ relationships, workers, and thereafter implement the LMP occupational health and safety (OHS) (including personal protective equipment, and throughout Project implementation. emergency preparedness and response), code of conduct (including relating to SEA and SH), forced labour, child labour, grievance arrangements for Project workers, and applicable requirements for contracted workers such as consultants for Independent Verification Agencies (IVAs) or Monitoring and Evaluation (M&E), consistent with ESS2 and the Public Service Rules 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish the grievance mechanism before NPCU and Participating Establish and operate a grievance mechanism for Project workers, as described in the engaging Project workers and thereafter States LMP and consistent with ESS2 and the Recipient’s ES Framework. maintain and operate throughout Project Implementation 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Same timeframe as action 2.1 NPCU and Participating Adopt and implement OHS measures as an annex to the LMP to mitigate risks to the States human population, traffic related risks and the environment. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT: This standard is not relevant for the Project. ESS 4: COMMUNITY HEALTH AND SAFETY: This standard is not relevant for the Project. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT: This standard is not relevant for the Project. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES: This standard is not relevant for the Project. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES: This standard is not relevant for the Project. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Nigeria: Human Capital Opportunities for Prosperity and Equality (HOPE) MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 8: CULTURAL HERITAGE: This standard is not relevant for the Project. ESS 9: FINANCIAL INTERMEDIARIES: This standard is not relevant for the Project. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Prepare, disclose, consult upon and adopt the NPCU Prepare, disclose, consult upon, adopt and implement a Stakeholder Engagement Plan SEP by August 20th 2024 and thereafter (SEP) for the Project, consistent with ESS10, which shall include measures to, inter alia, implement the SEP throughout Project provide stakeholders with timely, relevant, understandable and accessible implementation. information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism no later NPCU Establish, publicize, maintain, and operate an accessible grievance mechanism, to than three months after Project Effective Date, receive and facilitate resolution of concerns and grievances in relation to the Project, and thereafter maintain and operate the promptly and effectively, in a transparent manner that is culturally appropriate and mechanism throughout Project readily accessible to all Project-affected parties, at no cost and without retribution, implementation. 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 support to NPCU staff, stakeholders and, Project workers on: Throughout Project implementation. NPCU and Participating • The E&S implementation and management in a PforR operation, results states verification, consultation, communication, etc. Other specific training such as ESF/ESHS • ESF Fundamentals (including ESHS Guidelines) implementation will be conducted within 4 • Labour Management Procedures months of the Project Effective Date. • GRM Training • Stakeholder mapping and engagement • E-Waste Management • Importance of Resource Efficiency and Sustainable Procurement • OHS measures including on emergency prevention and preparedness. 5|Page