TDB Environmental and Social Action Plan (ESAP) for the Accelerating Sustainable and Clean Energy Access Transformation - Regional Energy Access Financing Platform (P181328). ESAP Action Completion date PS 1 Assessment and Management of Environmental and Social Risks and Impacts 1 TDB will upgrade its current Environmental and Social Management System (ESMS) by creating a guidance document that encompasses E&S requirements and procedures for: a) Prior to disbursement of a) Lending through financial intermediaries including funds for on lending to PFIs procedures for cascading down the E&S compliance requirements to the financial intermediaries b) Technical assistance activities covering development of b) Prior to undertaking any terms of reference for TA activities consistent with World technical assistance activity Bank PSs under the facility c) incorporate the following: (i) project specific list of c) Prior to disbursement of restricted activities to exclude high risk activities from funds from the World Bank direct and indirect lending; (ii) expanding the E&S risk to TDB section to encompass additional sectors like housing, solar home systems, and mini-grids and Including screening procedures for avoidance of significant risks and impacts; (iii) defining the role of a potential E&S analyst, including field supervision responsibilities if any; (iv) enhancing the reporting template, mandating project submissions covering E&S performance, life & fire safety, OHS data, workplace environment data, grievance information, and ESMP updates; and (v) Incorporating PFI training provisions. TDB’s Senior Management shall endorse the upgraded ESMS along with the Guideline Notes and its disclosure. The guidance notes will be appended to the existing ESMS. 2 TDB will have as a condition with each PFI the requirement for the Prior to signing financing PFI to have in place an ESMS in line with the World Bank PSs and EHS agreements with each PFI, Guidelines that mirrors the TDB ESMS and ensure its throughout project operationalization and ongoing implementation. Implementation TDB will require all PFIs to disclose their ESMS. 3 TDB will include the following requirements in all its financing At all times, throughout agreements signed with PFIs under the Facility: implementation a. PFIs will not support any subproject that is on the list of restricted activities. b. PFIs will support only those DRE projects that are under 2 MW and do not entail significant risks. c. PFIs will exclusively support DRE projects only if unencumbered land is readily accessible. 4 a) TDB will recruit a dedicated, technically qualified E&S specialist a) Prior to project supported by E&S consultants for the facility. effectiveness b) TDB will undertake third-party monitoring of ESMS implementation by PFIs including ESDDs and supervision of b) Throughout project subprojects undertaken by PFIs. implementation c) TDB will require and ensure each PFI has a focal point dedicated for ESMS implementation and technically qualified consultants c) Prior to disbursement of on call to support the E&S focal point undertake ESDD and funds from TDB to PFIs ongoing monitoring of subprojects. 5 a) TDB will maintain its existing external communication a) throughout mechanism throughout project implementation to receive, implementation register, screen and assess, track, respond to, and act upon external inquiries and complaints from the public regarding their operations. b) TDB will require all PFIs to develop, disclose and implement an b) As a condition of external communication mechanism to receive, register, screen disbursement from TDB to and assess, track, respond to, and act upon external inquiries and PFIs, and throughout complaints from the public regarding their operations. implementation c) All subprojects, financed directly by TDB or through PFIs, will be c) As a condition of required to develop and implement stakeholder engagement disbursement from TDB/ plan including a grievance mechanism commensurate with the PFIs to subprojects, and subproject E&S risks. throughout implementation d) TDB will cause PFIs to report to TDB all complaints and grievances d) Through implementation that may arise because of project implementation, including how they have been resolved and closed out. 6 TDB will prepare and implement an E&S Capacity Building Plan for Plan finalized and agreed with itself and PFIs for the implementation of the Facility in accordance the Bank within first 3 months with the World Bank E&S requirements. of project effectiveness and implemented per the schedule therein 7 TDB to submit to the World Bank for review and approval, the As soon as the first projects are E&S instruments for the first few sub-projects and subsequently identified for financing under of all subprojects involving resettlement, directly financed from the project (hopefully within project funds. the first two years of project effectiveness) TDB will submit to the World Bank for review and approval, the E&S instruments of all sub-projects that displace more than 100 people physically or economically. 8 a) In line with the Bank’s ERESIRT procedure, TDB will notify the Throughout project World Bank within 72 hours of becoming aware of any incidents, implementation accidents, or other circumstances related to any program component, whether implemented directly or through PFIs that may have a material impact on compliance with the Performance Standards. Following the notification, TDB will undertake a root cause analysis and share the report with the Bank within one week b) TDB will require all subprojects, directly finance by it, to report with 48 hours of occurrence of any incidents, and accidents, that may have a material impact on compliance with the Performance Standards. c) TDB will require the PFIs to report within 48 hours of becoming aware of any incidents, accidents, any such incident or other circumstances within their respective portfolio. 9 TDB will develop and implement an inclusion strategy that will enable Prior to disbursement of funds vulnerable and marginalized groups and individuals to benefit from from the World Bank to TDB the Project. TDB will be required to cascade the strategy to PFIs. PS 2 Labor and Working Conditions 10 a) TDB will require and ensure PFIs have HR systems including OHS Prior to disbursing project systems and procedures that comply with Performance Standard funds to the PFIs 2 requirements and are in line with the EHS Guidelines and GIIP. b) TDB and PFIs will ensure, through specific clauses in the financing agreements signed with subprojects that they have in place Ongoing during implementation appropriate HR, including OHS, system or procedures to comply with local labor laws, and Performance Standard 2 requirements. The subprojects will develop and implement OHS plans that are in line with the World Bank EHS Guidelines and GIIP. PS 3 Resource Efficiency and Pollution Prevention 11 TDB and PFIs will assess and mitigate through site-specific Ongoing during implementation management plans such as waste management, hazardous material, resource efficiency, etc. risks and impacts associated with PS 3 in all subprojects they finance under the Facility. PS 4 Community Health, Safety and Security 12 TDB and PFIs will assess and mitigate through site-specific Ongoing during implementation management plans including road safety and traffic management, security, disaster risk, etc. risks and impacts associated with PS 4 in all subprojects they finance under the Facility. PS 5 Land Acquisition and Involuntary Resettlement 13 a) TDB and PFIs will assess risks and impacts associated with PS5 in Ongoing during implementation all subprojects proposed for financing under the Facility (through their respective ESDDs and if needed, through land acquisition audits), and ensure that land for subprojects being financed have been acquired in line with PS5. b) Should the ESDD/Audit find any land acquisition inconsistencies with PS5, the inconsistencies will be addressed before such subprojects are financed under the Project. c) For subprojects impacting people above the agreed E&S threshold, TDB and PFIs will seek the World Bank approval prior to committing financing for such subprojects. d) TDB will require all PFIs to ensure compliance with the E&S thresholds agreed with the World Bank. e) PFIs will exclusively support DRE projects only if unencumbered land is readily accessible. Essentially, PFIs will support only those DRE subprojects where all land and resettlement issues have been addressed and finalized, and land for the proposed DRE subproject is available and has no encumbrances. PS 6 Biodiversity Conservation and Sustainable Management of Living Natural Resources 14 TDB and PFIs will assess and mitigate through site-specific Ongoing during implementation management plans, including a biodiversity management plan, risks and impacts associated with PS 6 in all subprojects they finance under the Facility. All subprojects with significant risks to critical or sensitive habitats are excluded from the facility. PS 7 Indigenous Peoples 15 a) TDB and PFIs will assess risks and impacts associated with PS 7 Ongoing during implementation in all subprojects they finance under the Facility. b) Should a project financed activity be located in areas where IPs are present, TDB will share with the Bank for review and concurrence, any instruments such as IPPs prepared to ensure the inclusion and access to project benefits by IPs. PS 8 Cultural Heritage 16 TDB and PFIs will assess and mitigate risks and impacts associated Ongoing during implementation with PS8 in all subprojects they finance under the Facility and put in place measures for handling any chance finds during ASCENT financed activity.