ORGANISATION OF EASTERN CARIBBEAN STATES (OECS) COMMISSION OECS- Skills and Innovation Project - P179210 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) September 7, 2023 1 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The OECS Commission (the Recipient) will implement its respective part of the the OECS - Skills and Innovation Project (the Project), 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 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 Education Development Management Unit (EDMU) Program Director. The Recipient shall promptly disclose the updated ESCP. 2 | Page MATERIAL MEASURES AND ACTIONS TIMEFRAME MONITORING AND REPORTING A REGULAR REPORTING Submit 6-month annual reports to the throughout Project implementation, co Prepare and submit to the Association regular monitoring reports on the after the Effective Date. Submit each re environmental, social, health and safety (ESHS) performance of the Project, including Association no later than 45 days after but not limited to the implementation of the ESCP, status of preparation and each reporting period. implementation of E&S instruments required under the ESCP, stakeholder engagement activities, and functioning of the grievance mechanism(s). B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 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 affected Provide subsequent report to the Asso communities, the public or workers, including, inter alia, cases of sexual exploitation within 10 days of the initial notice of th and abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or or accident. multiple injury. Provide 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 Establish and maintain a RPIU as set ou Establish and maintain a Regional Project Implementation Unit (RPIU) with qualified Financing Agreement. Hire or appoint t staff and resources to support management of ESHS risks and impacts of the Project specialist for the RPIU no later than 60 including one E&S specialist. the Effective Date and thereafter main position throughout Project implement 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS Submit the E&S provisions for the Asso prior review and no objection prior to t Incorporate E&S provisions to manage Project activities under Component 1 of the finalization of the POM, and incorporat Project as part of the Project Operations Manual (POM), consistent with the relevant Provisions as part of the POM. Thereaf ESSs. The provisions shall include, inter alia, an E&S exclusion list, E&S Codes of implement the E&S provisions through Practice, and simplified labor management procedures (LMP). implementation. 1.3 TECHNICAL ASSISTANCE Throughout Project implementation. Ensure that the consultancies, studies, capacity building, training, and any other technical assistance activities under Component 1 of 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 Same timeframe as for the ado Develop, adopt and implement simplified Labor Management Procedures (LMP) for implementation of the POM. Component 1 of the Project as part of the E&S provisions of the POM to be prepared under action 1.2 above. 1 | Page MATERIAL MEASURES AND ACTIONS TIMEFRAME 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Same timeframe as for the adoption an Establish and operate a grievance mechanism for Component 1 Project workers implementation of the POM. consistent with ESS2 and as described in the simplified LMP . ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the adoption an Incorporate resource efficiency and pollution prevention and management measures, implementation of the POM. including measures to manage electronic waste, in the E&S provisions of the POM to be prepared under action 1.2 above. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY Same timeframe as for the adoption an Assess and manage specific risks and impacts to the community arising from Project implementation of the POM. activities, including, inter alia, behavior of Project workers and response to emergency situations, and include mitigation measures in the E&S provisions of the POM, to be prepared under action 1.2 above. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT Not Currently Relevant ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES Not Currently Relevant ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not Currently Relevant ESS 8: CULTURAL HERITAGE Not Currently Relevant ESS 9: FINANCIAL INTERMEDIARIES Not Currently relevant ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Submit the final SEP for the Association review and no objection, and thereafte Update, consult, adopt and implement a Stakeholder Engagement Plan (SEP) for and disclose the SEP no later than 60 d Component 1 of the Project, consistent with ESS10, which shall include measures to, the Effective Date. 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. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism alo SEP, no later than 60 days after the Effe Establish, publicize, maintain, and operate an accessible grievance mechanism, to and thereafter maintain and operate th receive and facilitate resolution of concerns and grievances in relation to Component 1 mechanism throughout Project implem of 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 Training shall be facilitated and provided as applicable and appropriate to RPIU staff, Training to be delivered throughout Pr Project workers, contractors and supervision firms on: implementation. � environmental and social requirements and implementation � community health and safety. � SEA/SH prevention and response measures 2 | Page MATERIAL MEASURES AND ACTIONS TIMEFRAME � emergency preparedness and response 3 | Page Grenada OECS- Skills and Innovation Project - P179210 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) September 7, 2023 4 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 5. Grenada (the Recipient) will implement its respective parts of the OECS - Skills and Innovation Project (the Project) with the involvement of its Ministry of Education (MoE), 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. 6. 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. 7. 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. 8. 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 and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the National Project Coordinator of Grenada’s Project Implementation Unit. The Recipient shall promptly disclose the updated ESCP. 5 | Page MATERIAL MEASURES AND ACTIONS TIMEFRAME MONITORING AND REPORTING A REGULAR REPORTING Submit 6-month annual reports to the throughout Project implementation, co Prepare and submit to the Association regular monitoring reports on the after the Effective Date. Submit each re environmental, social, health and safety (ESHS) performance of the Project, including Association no later than 45 days after but not limited to the implementation of the ESCP, status of preparation and each reporting period. implementation of E&S instruments required under the ESCP, stakeholder engagement activities, and functioning of the grievance mechanism(s). B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 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 affected Provide subsequent report to the Asso communities, the public or workers, including, inter alia, cases of sexual exploitation within 10 days of the initial notice of th and abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or or accident. multiple injury. Provide 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. C CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports to the Asso annexes to the reports to be submitted Require contractors and supervising firms to provide monthly monitoring reports on action A above. ESHS performance in accordance with the metrics specified in the respective bidding documents and contracts and submit such reports to the Association. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Establish and maintain a PIU as set out Financing agreement. Hire or appoint t Establish and maintain a Project Implementation Unit (PIU) with qualified staff and specialist for the PIU no later than 60 d resources to support management of ESHS risks and impacts of the Project including the Effective Date and thereafter main one E&S specialist. positions throughout Project implemen 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS Submit the E&S provisions for the Asso prior review and no objection prior to t Incorporate E&S provisions for the Project as part of the Project Operations Manual finalization of the POM, and incorporat (POM), consistent with the relevant ESSs. The provisions shall include, inter alia, an E&S Provisions as part of the POM. Thereaf exclusion list, E&S screening form, E&S Codes of Practice, an E&S Management Plan implement the E&S provisions through template and simplified labor management procedures (LMP). implementation. 1.3 MANAGEMENT OF CONTRACTORS Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S As part of the preparation of procurem provisions of the POM, and code of conduct, into the ESHS specifications of the documents and respective contracts. procurement documents and contracts with contractors and supervising firms. Supervise contractors throughout Proje Thereafter ensure that the contractors and supervising firms comply and cause implementation. subcontractors to comply with the ESHS specifications of their respective contracts. 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. 1 | Page MATERIAL MEASURES AND ACTIONS TIMEFRAME Ensure that the consultancies, studies, 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. 1.5 CONTINGENT EMERGENCY RESPONSE COMPONENT (CERC) FINANCING a) The adoption of the CERC Manual in a) Ensure that the CERC Manual, as specified in the Financing Agreement, includes a substance acceptable to the Associatio description of the ESHS assessment and management arrangements, including the withdrawal condition under Section III. CERC ESMF, for the implementation of the CERC, in accordance with the ESSs. Schedule 2 of the Financing Agreement Project. b) Adopt the CERC ESMF for activities under the CERC component of the Project, in accordance with the CERC Manual and the ESSs, and thereafter implement the b) Implement the CERC ESMF in accord measures and actions required under said E&S instruments, within the timeframes the terms, throughout Project impleme specified in said E&S instruments. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Same timeframe as for the ado Develop, adopt and implement the simplified LMP for the Project as part of the E&S implementation of the POM. Provisions of the POM, to be prepared under action 1.2 above, including, inter alia, provisions on working conditions, management of workers relationships, occupational health and safety (including personal protective equipment, and emergency preparedness and response), code of conduct (including relating to SEA and SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Same timeframe as for the adoption an Establish and operate a grievance mechanism for Project workers, consistent with ESS2 implementation of the POM. and as described in the simplified LMP. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the adoption an Incorporate resource efficiency and pollution prevention and management measures, implementation of the POM. including, inter alia, waste management measures to manage hazardous and non- hazardous waste, including electronic waste (e-waste), in the E&S Provisions of the POM to be prepared under action 1.2 above, consistent with ESS3. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY Same timeframe as for the adoption an Assess and manage specific risks and impacts to the community arising from Project implementation of the POM. activities, including, inter alia, behavior of Project workers and response to emergency situations, and include mitigation measures in the E&S provisions of the POM, to be prepared under action 1.2 above. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT Not Currently Relevant ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES Not Currently Relevant ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not Currently Relevant ESS 8: CULTURAL HERITAGE Not Currently Relevant ESS 9: FINANCIAL INTERMEDIARIES Not Currently relevant ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 2 | Page MATERIAL MEASURES AND ACTIONS TIMEFRAME 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Submit the final SEP for the Association review and no objection, and thereafte Update, consult, adopt and implement a Stakeholder Engagement Plan (SEP) for the and disclose the SEP no later than 60 d Project, consistent with ESS10, which shall include measures to, inter alia, provide the Effective Date. 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. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism alo SEP, no later than 60 days after the Effe Establish, publicize, maintain, and operate an accessible grievance mechanism, to and thereafter maintain and operate th receive and facilitate resolution of concerns and grievances in relation to the Project, mechanism throughout Project implem 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 Training shall be facilitated and provided as applicable and appropriate to PIU staff, Training to be delivered throughout Pr Project workers, contractors and supervision firms on: implementation. � environmental and social requirements and implementation � community health and safety. � SEA/SH prevention and response measures � emergency preparedness and response 3 | Page Saint Lucia OECS- Skills and Innovation Project - P179210 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) September 7, 2023 4 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 9. Saint Lucia (the Recipient) will implement its respective parts of the OECS - Skills and Innovation Project (the Project) with the involvement of its Ministry of Education (MoE), 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. 10. 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. 11. 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. 12. 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 and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the t Project Manager of Saint Lucia’s Project Implementation Unit (PIU). The Recipient shall promptly disclose the updated ESCP. 5 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – OECS- Skills and Innovation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit 6-month annual reports to the Association PIU/MoE throughout Project implementation, commencing Prepare and submit to the Association regular monitoring reports on the after the Effective Date. Submit each report to the environmental, social, health and safety (ESHS) performance of the Project, including Association no later than 45 days after the end of but not limited to the implementation of the ESCP, status of preparation and each reporting period. implementation of E&S instruments required under the ESCP, stakeholder engagement activities, and functioning of the grievance mechanism(s). B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 hours after PIU/MoE 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 affected Provide subsequent report to the Association communities, the public or workers, including, inter alia, cases of sexual exploitation within 10 days of the initial notice of the incident and abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or or accident. multiple injury. Provide 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. C CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports to the Association as PIU/MoE annexes to the reports to be submitted under Require contractors and supervising firms to provide monthly monitoring reports on action A above. ESHS performance in accordance with the metrics specified in the respective bidding documents and contracts and submit such reports to the Association. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Establish and maintain a PIU as set out in the PIU/MoE Financing agreement. Hire or appoint the E&S Establish and maintain a Project Implementation Unit (PIU) with qualified staff and specialist for the PIU no later than 60 days after resources to support management of ESHS risks and impacts of the Project including the Effective Date and thereafter maintain these one E&S specialist. positions throughout Project implementation. 6 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – OECS- Skills and Innovation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS Submit the E&S provisions for the Association’s PIU/MoE prior review and no objection prior to the Incorporate E&S Provisions for the Project as part of the Project Operations Manual finalization of the POM, and incorporate the E&S (POM), consistent with the relevant ESSs. The provisions shall include, inter alia, an E&S Provisions as part of the POM. Thereafter exclusion list, E&S screening form, E&S Codes of Practice, an E&S Management Plan implement the E&S provisions throughout Project template, and simplified labor management procedures (LMP). implementation. 1.3 MANAGEMENT OF CONTRACTORS PIU/MoE As part of the preparation of procurement Incorporate the relevant aspects of the ESCP, including, inter alia, the relevant E&S documents and respective contracts. provisions of the POM, and code of conduct, into the ESHS specifications of the procurement documents and contracts with contractors and supervising firms. Supervise contractors throughout Project implementation. Thereafter ensure that the contractors and supervising firms comply and cause subcontractors to comply with the ESHS specifications of their respective contracts. 1.4 TECHNICAL ASSISTANCE Throughout Project implementation. PIU/MoE Ensure that the consultancies, studies, 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. 1.5 CONTINGENT EMERGENCY RESPONSE COMPONENT (CERC) FINANCING a) The adoption of the CERC Manual in form and PIU/MoE a) Ensure that the CERC Manual, as specified in the Financing Agreement, includes a substance acceptable to the Association is a description of the ESHS assessment and management arrangements, including the withdrawal condition under Section III.B.1(b) of CERC ESMF, for the implementation of the CERC, in accordance with the ESSs. Schedule 2 of the Financing Agreement for the Project. b) Adopt the CERC ESMF for activities under the CERC component of the Project, in accordance with the CERC Manual and the ESSs, and thereafter implement the b) Implement the CERC ESMF in accordance with measures and actions required under said E&S instruments, within the timeframes the terms, throughout Project implementation. specified in said E&S instruments. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Same timeframe as for the adoption and PIU/MoE implementation of the POM. 7 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – OECS- Skills and Innovation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Develop, adopt and implement the simplified LMP for the Project as part of the E&S Provisions of the POM, to be prepared under action 1.2 above, including, inter alia, provisions on working conditions, management of workers relationships, occupational health and safety (including personal protective equipment, and emergency preparedness and response), code of conduct (including relating to SEA and SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Same timeframe as for the adoption and PIU/MoE Establish and operate a grievance mechanism for Project workers, consistent with ESS2 implementation of the POM. and as described in the simplified LMP. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the adoption and PIU/MoE Incorporate resource efficiency and pollution prevention and management measures, implementation of the POM. including, inter alia, waste management measures to manage hazardous and non- hazardous waste including electronic waste (e-waste), in the E&S Provisions of the POM, to be prepared under action 1.2 above, consistent with ESS3. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY Same timeframe as for the adoption and PIU/MoE Assess and manage specific risks and impacts to the community arising from Project implementation of the POM. activities, including, inter alia, behavior of Project workers and response to emergency situations, and include mitigation measures in the E&S provisions of the POM, to be prepared under action 1.2 above. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT Not Currently Relevant ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES Not Currently Relevant ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not Currently Relevant ESS 8: CULTURAL HERITAGE Not Currently Relevant ESS 9: FINANCIAL INTERMEDIARIES Not Currently relevant ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 8 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – OECS- Skills and Innovation Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Submit the final SEP for the Association’s prior PIU/MoE review and no objection, and thereafter adopt Update, consult, adopt and implement a Stakeholder Engagement Plan (SEP) for the and disclose the SEP no later than 60 days after Project, consistent with ESS10, which shall include measures to, inter alia, provide the Effective Date. 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. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism along with the PIU/MoE SEP, no later than 60 days after the Effective Date, Establish, publicize, maintain, and operate an accessible grievance mechanism, to and thereafter maintain and operate the receive and facilitate resolution of concerns and grievances in relation to the Project, mechanism 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 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 Training shall be facilitated and provided as applicable and appropriate to PIU staff, Training to be delivered throughout Project PIU/MoE Project workers, contractors and supervision firms on: implementation. � environmental and social requirements and implementation � community health and safety. � SEA/SH prevention and response measures � emergency preparedness and response 9 | Page