REPUBLIC OF THE GAMBIA Ministry of Finance The Gambia Resilience, Inclusion, Skills, and Equity Project (RISE) (P179233) Draft for Appraisal ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) 9th July ,2023 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of The Gambia (the Recipient) will implement The Gambia Resilience, Inclusion, Skills, and Equity Project (the Project), with the involvement of the Ministry of Finance and Economic Affairs (MoFEA), the Ministry of Basic and Secondary Education (MoBSE), Ministry of Higher Education, Research, Science & Technology (MoHERST), and the National Nutrition Agency (NaNA) as set out in the Financing Agreement. The International Development Association (the Association), has agreed to provide the 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, through the Ministry of Finance and Economic Affairs, and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Permanent Secretary of the Ministry of Finance and Economic Affairs. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – The Gambia Resilience, Inclusion, Skills, and Equity Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Submit quarterly reports to the Association throughout The Central Fiduciary Unit (CFU) of Prepare and submit to the Association regular monitoring Project implementation, commencing three months MoFEA reports on the environmental, social, health and safety after the Project Effective Date. Submit each ESHS report (ESHS) performance of the Project, including but not to the Association no later than 15 days after the end of limited to the implementation of the ESCP, status of each reporting period. preparation and implementation of E&S instruments required under the ESCP, stakeholder engagement activities, and functioning of the grievance mechanism(s), Environmental and Social Management Plans (ESMPs) and the Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH) Prevention and Response Action Plan. B INCIDENTS AND ACCIDENTS Notify the Association no later than 48 hours after The Central Fiduciary Unit (CFU) of MoFEA Promptly notify the Association of any incident or accident learning of the incident or accident, and 24 hours for any related to the Project, which has, or is likely to have, a fatalities or incidents related to SEA/SH. significant adverse effect on the environment, the affected communities, the public or workers, including, inter alia, Provide subsequent report to the Association within a incidents or accidents on project sites, labour influx, cases timeframe acceptable to the Association of exclusion of vulnerable groups (i.e., women, youth, people with disabilities) cases of sexual exploitation and abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or 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, the Recipient shall 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 The Central Fiduciary Unit (CFU) of MoFEA Require contractors to provide monthly monitoring reports as annexes to the reports to be submitted under action on ESHS performance in accordance with the metrics A above. specified in the respective bidding documents and contracts and submit such reports to the Association. 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – The Gambia Resilience, Inclusion, Skills, and Equity Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY D NOTIFICATIONS RELATING TO DAAB COMPLIANCE No later than 7 days after the issuance or receipt, as The Central Fiduciary Unit (CFU) of MoFEA REVIEW OF CONTRACTOR COMPLIANCE WITH SEA/SH applicable, of the relevant document (i.e., referral to the PREVENTION AND RESPONSE OBLIGATIONS DAAB, issuance of DAAB decision, Notice of Dissatisfaction, notice of commencement of Notify the Association of any referral submitted to the emergency/full arbitration, emergency/full arbitration Dispute Avoidance and Adjudication Board (DAAB) to order, as applicable). initiate a process of compliance review in relation to a contractor’s obligations to prevent and respond to sexual exploitation and abuse (SEA), and/or sexual harassment (SH) specified in the respective works contract with such contractor; and, in the event of any such referral, notify the Association of: (i) the DAAB’s decision on such referral; (ii) the contractor’s Notice of Dissatisfaction, if any , with such DAAB decision; (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 Establish and maintain the CFU as set out in the MoFEA Establish and maintain a Central Fiduciary Unit (CFU) Financing Agreement. within the Ministry of Finance and Economic Affairs Hire or appoint one environmental specialist, one social (MoFEA) with qualified staff and resources to support development specialist with gender and GBV/SEA/SH management of ESHS risks and impacts of the Project experience no later than three (03) months after Project including one environmental specialist and one social Effective Date, and thereafter maintain the CFUPIU and development specialist with gender and GBV/SEA/SH these positions throughout Project implementation. experience, with qualifications, experience, and conditions of employment acceptable to the Association. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS The Central Fiduciary Unit (CFU) of MoFEA 1. Prepare, disclose, adopt and implement an 1. Finalize, disclose, and adopt the project ESMF Environmental and Social Management including the prevention and response plan for Framework (ESMF) for the project including a plan gender-based violence (GBV), sexual exploitation for prevention and response to gender-based and abuse (SEA) and sexual harassment (SH) prior to violence (GBV), sexual exploitation and abuse the project’s appraisal. Thereafter, implement the (SEA) and sexual harassment (SH) with Codes of ESMF throughout Project implementation. Conduct, consistent with the relevant ESSs. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – The Gambia Resilience, Inclusion, Skills, and Equity Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 2. Prepare, disclose adopt and implement an 2. Adopt and disclose an Environmental and Social Environmental and Social Impact Assessment Impact Assessment (ESIA) and an Environmental and (ESIA) and a corresponding Environmental and Social Management Plan (ESMP) before launching Social Management Plan (ESMP) for the before launching of the bidding process for the construction of Technical and Vocational respective sites and prior to the implementation of Education and Training (TVET) Center of each construction activity. Once adopted, implement Excellence (CoE) in selected trades (under the ESIA and ESMP throughout Project Component 1) consistent with the relevant ESSs. implementation 3. Adopt and implement the site-specific 3. Adopt the ESMP before launching the bidding Environmental and Social Impact Environmental process for the respective Project activity that and Social Management Plan (ESMP), when requires the adoption of such ESMP. Once adopted, applicable, as set out in the ESMF. The proposed implement the respective ESMP throughout Project activities described in the exclusion list set out in implementation. the ESMF shall be ineligible to receive financing under the Project. 1.3 MANAGEMENT OF CONTRACTORS As part of the preparation of procurement documents The Central Fiduciary Unit (CFU) of MoFEA Incorporate the relevant aspects of the ESCP, including, and respective contracts. inter alia, the relevant E&S instruments, the Labor Supervise contractors throughout Project Management Procedures, and code of conduct, SEA/SH implementation. Action Plan, into the ESHS specifications of the procurement documents and contracts with contractors and supervising firms. 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. The Central Fiduciary Unit (CFU) of MoFEA 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. 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – The Gambia Resilience, Inclusion, Skills, and Equity Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.5 CONTINGENT EMERGENCY RESPONSE FINANCING a) The adoption of the CM in form and substance MoFEA and the designated authority for the a) Ensure that the CERC Manual (CM) as specified the legal acceptable to the Association is a withdrawal condition CERC agreement includes a description of the ESHS assessment under Section D of Schedule 2 of the Financing and management arrangements including the ESMF CERC Agreement for the Project. Addendum that will be included or referred to in the ERM for the implementation of the CERC Part, in accordance with b) Adopt any required E&S instrument and include it as the ESSs. part of the respective bidding process, if applicable, and in any case, before the carrying out of the relevant b) Prepare, consult, adopt, and disclose any environmental Project activities for which the E&S instrument is and social (E&S) instruments which may be required for required. Implement the E&S instruments in accordance activities under the CERC Part of the Project, in accordance with their terms, throughout Project implementation. with the CM and, if applicable, CERC-ESMF or CERC-ESMF Addendum and the ESSs, and thereafter implement the measures and actions required under said E&S instruments, within the timeframes specified in said E&S instruments. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Adopt the LMP prior to Project Effective date and The Central Fiduciary Unit (CFU) of MoFEA Adopt and implement the Labor Management Plan (LMP) thereafter implement the LMP throughout Project for the Project, including, inter alia, provisions on working implementation. 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 Establish grievance mechanism prior to engaging Project The Central Fiduciary Unit (CFU) of MoFEA Establish and operate a grievance mechanism for Project workers and thereafter maintain and operate it contractors/sub-contractors workers, as described in the LMP and consistent with ESS2. throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Same timeframe as for the adoption of the project The Central Fiduciary Unit (CFU) of MoFEA Adopt and implement a Waste Management Plan (WMP) ESMF, site specific ESIA/ESMP, C-ESMPs and thereafter /contractors as part of the project ESMF, sites specific ESIA/ESMP and implement the WMP throughout Project contractors ESMPs, to manage hazardous and non- implementation. hazardous wastes, consistent with ESS3. 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – The Gambia Resilience, Inclusion, Skills, and Equity Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION Same timeframe as for the adoption and The Central Fiduciary Unit (CFU) of MoFEA AND MANAGEMENT implementation of the ESMF, ESIA/ESMP and C-ESMPs. /Contractors Incorporate resource efficiency and pollution prevention and management measures in the ESMF, ESIA/ESMP to be prepared under action 1.2 above, and C-ESMPs. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY Same timeframe as for the adoption and The Central Fiduciary Unit (CFU) of MoFEA Adopt and implement measures to manage traffic and implementation of the ESMF, ESMP, as well as C-ESMPs /Contractors/Sub-Contractors road safety risks as required in the ESMF, /ESMP to be prepared under action 1.2 above, and C-ESMPs. 4.2 COMMUNITY HEALTH AND SAFETY Same timeframe as for the adoption and Assess and manage specific risks and impacts to the implementation of the ESMP. The Central Fiduciary Unit (CFU) of MoFEA community arising from Project activities including, inter alia, behavior of Project workers, risks of labor influx, response to emergency situations, and include mitigation measures in the ESMP to be prepared in accordance with the ESMF. 4.3 SEA AND SH RISKS Adopt the SEA/SH Action Plan at the same time as the The Central Fiduciary Unit (CFU) of MoFEA Adopt and implement a SEA/SH Action Plan [specify if part ESMP in section 1.2 and thereafter implement the of another instrument, e.g., as part of the ESMP], to assess SEA/SH Action Plan throughout Project implementation. and manage the risks of SEA and SH. 4.4 SECURITY MANAGEMENT Same timeline as for the preparation of the ESMF, site The Central Fiduciary Unit (CFU) of MoFEA Assess and implement measures to manage the security specific /ESMP, C-ESMP and Prior to engaging security /Contractors risks of the Project, including the risks of engaging security personnel and thereafter implement security measure personnel to safeguard project workers, sites, assets, and throughout Project implementation. activities, as set out in the ESMF, sites specific /ESMP, C- ESMP, 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 7|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – The Gambia Resilience, Inclusion, Skills, and Equity Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY This performance standard is not relevant as there will be no land acquisition in the project. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 This ESS is not relevant based on information received Same timeline as for the adoption and implementation The Central Fiduciary Unit (CFU) of MoFEA to date. At this stage there is not enough information of the ESMF, site specific ESMP, C-ESMPs and thereafter /contractors on the sensitivity of the intervention areas regarding implement these measures throughout Project biodiversity. The environmental and social assessment implementation. to be developed will be assessed and if confirmed will propose appropriate mitigation measures. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES This standard is not relevant to the project. ESS 8: CULTURAL HERITAGE 8.1 CULTURAL HERITAGE RISKS AND IMPACTS Same timeline as for the adoption and implementation The Central Fiduciary Unit (CFU) of MoFEA Adopt and implement measures to protect Cultural of the ESMF, site specific ESMP, C-ESMPs and thereafter /Contractors Heritage as part of the site specific ESIA/ESMP, C-ESMPs, in implement these measures throughout Project accordance with the guidelines of the ESMF prepared for implementation. the Project, and consistent with ESS8. 8.2 CHANCE FINDS Describe the chance find procedures in the ESMF and The Central Fiduciary Unit (CFU) of MoFEA Describe and implement the chance finds procedures, as ESMP. Implement the procedures throughout Project part of the ESMF and the ESMP of the Project. implementation. 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 The SEP will be completed and disclosed prior to The Central Fiduciary Unit (CFU) of MoFEA IMPLEMENTATION Appraisal, and thereafter implement the SEP throughout Adopt and implement a Stakeholder Engagement Plan Project implementation. (SEP) for the Project, consistent with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, relevant, understandable and accessible information, and consult with them in a culturally 8|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – The Gambia Resilience, Inclusion, Skills, and Equity Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism no later than 3 The Central Fiduciary Unit (CFU) of MoFEA Establish, publicize, maintain, and operate an accessible months after project approval. grievance mechanism, 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 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 to be provided The Central Fiduciary Unit (CFU) of MoFEA Immediately after Project Effective Date and during The MoFEA’s CFU shall ensure that relevant project actors project implementation are trained in the following areas: • The project’s GM, including the processes for handling sensitive complaints such as SEA/SH incidents • Stakeholder Engagement Plan and good practices related to engaging stakeholders in an ethical and responsive way • Labor Management Procedures • E&S requirements (impacts and mitigation measures) of sub-projects • Subproject Environmental and Social screening • Occupational Health and Safety for Contractors • Emergency preparedness and response • Communication strategy on COVID-19 and activities/protocols regarding prevention and mitigation of transmission, PPE, OHS 9|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – The Gambia Resilience, Inclusion, Skills, and Equity Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY • SEA/SH/VAC risk awareness; SEA/SH Prevention and Response Action Plan, content, and sanctions of CoCs, and GM of project (i.e., importance, objectives, content, how to prepare it, who implements it, and how to ensure a GM-sensitive SEA/SH issues • Disability inclusion training and training on inclusion of other vulnerable groups • Documentation, monitoring and reporting • Gender inclusion action plan • World Bank ESF and ESSs • Other (to be determined according to needs) CS2 Project workers to receive training on: Immediately after Effectiveness Date and during project The Central Fiduciary Unit (CFU) of MoFEA • Stakeholder Mapping and Engagement implementation • Environmental and Social screening • Environmental and social risk and impact management • SEA/SH risk management and GM • Labor Management Procedures and GM • Training for Project workers on occupational health and safety including on emergency prevention and preparedness and response arrangements to emergency situations, including Occupational Health and Safety, Community Health and Safety (i.e., including traffic and road safety, mitigation measures related to communicable diseases), COVID-19 mitigation; Codes of Conduct , Emergency preparedness and response (CERC), SEA/SH risks, reporting requirements 10 | P a g e