Federal Republic of Nigeria Ministry of Health and Social Welfare Nigeria: Primary Healthcare Provision Strengthening Program (P504693) (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 Primary Healthcare Provision Strengthening Program – HOPE PHC (the Operation), with the involvement of the Federal Ministry of Health and Social Welfare (FMOHSW) [and] [cause the Operation to be carried out by the following implementing entities (together the “Operation Implementing Entities�): (a) at the federal level, the National Primary Healthcare Development Association (NPHCDA), National Health Insurance Agency (NHIA), and Nigeria Center for Disease Control (NCDC), and, (b) in Participating States, the respective State Ministry of Health (SMoH), State Primary Healthcare Development Board (SPHCDB), State Supported Health Insurance Agency (SSHIA), Hospitals Management Board (HMB), and Drug Management Agency (DMA)] as set out in the Financing Agreement and the Grant Agreement (the “Agreements�). The International Development Association (the Association) and the International Bank for Reconstruction and Development, acting jointly as administrator of the Global Financing Facility, has agreed to provide financing for the Operation as set out in the referred Agreements. The Operation consists of a Program-for-Results Financing component described in Part 1 of Schedule 1 to the Agreements (the “Program�) and an IPF Component described in Part 2 of Schedule 1 to the Agreements (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 Agreements. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreements. 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 a manner acceptable to the Association. Once adopted, the 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 Health & Social Welfare 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 Coordinating Minister of Health & Social Welfare. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Nigeria: Primary Healthcare Provision Strengthening Program (P504693) Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit Six-monthly reports to the National Program Prepare and submit to the Association regular monitoring reports on the environmental, Association throughout Project Coordination Unit (NPCU) social, health, and safety (ESHS) performance of the Project, including but not limited to implementation, commencing after the within the SWAp the implementation of the ESCP, status of preparation and implementation of E&S Effective Date. Submit each report to the Coordination Office (SCO) instruments required under the ESCP, stakeholder engagement activities, and functioning Association no later than 14 days after the at the Federal Ministry of of the grievance mechanisms. end of each reporting period. Health and Social Welfare (FMOHSW) B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 NPCU hours after learning of the incident or Promptly notify the Association of any incident or accident related to the Project that has, accident. 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 Notify the Association of fatality or SEA/SH abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or multiple incidents within 24 hours of learning of the injury [Provide sufficient detail regarding the scope, severity, and possible causes of the incident. 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 Provide subsequent report to the appropriate. Association within a timeframe acceptable to the Association. 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 Hire one Environmental specialist and one NPCU and BHCPF State Establish and maintain a qualified one Environmental and one Social staff and resources to Social specialist no later than one month Oversight Committees support the management of ESHS risks and impacts of the Project at the [NPCU] and after the Effective Date and maintain the (BCPPF-SOCs) Participating states position throughout Project implementation. 1.2 MANAGEMENT TOOLS AND INSTRUMENTS Prepare, disclose, consult upon, and adopt NPCU Prepare, consult upon, adopt, disclose, and implement the following instruments in the SEP by August 19, 2024. accordance with the ESSs and in a manner acceptable to the Association: Implement requirements of the SEP throughout Project implementation. i. Stakeholder Engagement Plan (SEP) ii. Labour Management Plan LMP shall be prepared, disclosed, iii. Environmental and Social (E&S) Screening Checklist consulted, and adopted no later than three iv. Environmental and Social Assessment months after the Effective Date and 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Nigeria: Primary Healthcare Provision Strengthening Program (P504693) Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY implemented throughout the Project lifecycle. E&S Screening Checklist shall be developed no later than three months after the Effective Date and implemented by the SPIUs during Project implementation to screen activities for E&S impacts. Environmental and Social Assessment report shall be prepared by the NPCU and submitted to the Association at the end of each calendar year, no later than 15th December of each year. 1.3 TECHNICAL ASSISTANCE Throughout Project implementation. NPCU Ensure that the consultancies, studies (including feasibility studies), capacity building, training, and any other technical assistance activities under the Project are carried out by 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 Adopt the LMP no later than three months NPCU/BHCPF-SOC Adopt, and implement the Labor Management Procedures (LMP) including, inter alia, after the Effective Date, but before provisions on working conditions, management of workers’ relationships, occupational engaging Project workers, and thereafter health and safety (OHS) (including personal protective equipment, and emergency implement the LMP throughout Project preparedness and response), code of conduct (including relating to SEA and SH), forced implementation. labor, child labor, grievance arrangements for Project workers, and applicable requirements for contracted workers such as Independent Verification Agencies (IVAs) or Monitoring and Evaluation (M&E) consultants, consistent with ESS2. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish the grievance mechanism before NPCU/BHCPF-SOC Establish and operate a grievance mechanism for Project workers, as described in the LMP engaging Project workers and thereafter and consistent with ESS2. maintain and operate it throughout Project implementation 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Same timeframe as action 2.1 NPCU/ BHCPF-SOC 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Nigeria: Primary Healthcare Provision Strengthening Program (P504693) Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Adopt and implement OHS as an annex to the LMP to mitigate risks to the human population and the environment because of transportation of goods and project personnel, e-wastes from procurement of electronic and solar equipment, and minor labor-related risks. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT: This standard is not relevant to the Project. ESS 4: COMMUNITY HEALTH AND SAFETY: This standard is not relevant to the Project. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT This standard is not relevant to the Project. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES: This standard is not relevant to the Project. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES: This standard is not relevant to the Project. ESS 8: CULTURAL HERITAGE: This standard is not relevant to the Project. ESS 9: FINANCIAL INTERMEDIARIES: This standard is not relevant to the Project. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Prepare, disclose, consult upon, and adopt NPCU Prepare, disclose, consult upon, adopt and implement a Stakeholder Engagement Plan the SEP by August 19, 2024. Implement the (SEP) for the Project, consistent with ESS10, which shall include measures to, inter alia, SEP throughout the Project provide stakeholders with timely, relevant, understandable, and accessible information, implementation. and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination, and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM NPCU Establish, publicize, maintain, and operate an accessible grievance mechanism, to receive Establish the grievance mechanism no and facilitate the resolution of concerns and grievances in relation to the Project, promptly later than three (3) months after the and effectively, in a transparent manner that is culturally appropriate and readily accessible Effective date and thereafter maintain to all Project-affected parties, at no cost and without retribution, including concerns and and operate the mechanism throughout grievances filed anonymously, in a manner consistent with ESS10. Project implementation. While the operationalization of the Project The grievance mechanism shall be equipped to receive, register, and facilitate the level GRM is pending, complaints will be resolution of SEA/SH complaints, including through the referral of survivors to relevant submitted through the FMOHSW existing gender-based violence service providers, all in a safe, confidential, and survivor-centered complaints channels such as SERVICOM. manner. CAPACITY SUPPORT CS1 Capacity support to NPCU staff, stakeholders, and Project workers on: Throughout Project implementation. NPCU/ BHCPF-SOC • The E&S implementation and management in a PforR operation, results verification, consultation, communication, etc. . • ESF Fundamentals • GRM Training • Gender-based Violence prevention and response plan • Stakeholder mapping and engagement 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Nigeria: Primary Healthcare Provision Strengthening Program (P504693) Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY • E-waste and Healthcare Waste Management • OHS measures including on emergency prevention and preparedness. • Traffic management and Incident prevention 6|Page