Kingdom of Lesotho September 2023 Ministry of Finance and Development Planning Lesotho Public Sector Foundations for Service Delivery Project (P174141) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) [TBU before Signing] 1|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Kingdom of Lesotho (Recipient) will implement the Lesotho Public Sector Foundations for Service Delivery Project (LPSFSDP) (the Project), with the involvement of the Ministry of Finance and Development Planning (MFDP), as set out in the Financing 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, 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 Finance (MoF), and the Association agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient. The Recipient shall promptly disclose the updated ESCP. 2|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY MONITORING AND REPORTING A REGULAR REPORTING Prepare and submit to the Association regular monitoring reports on the environmental, Monthly Reporting throughout project PIT within MoF social, health and safety (ESHS) performance of the Project, including but not limited to implementation. the implementation of the ESCP, status of preparation and implementation of E&S instruments required under the ESCP, stakeholder engagement activities, and Semi-annually as part of Project functioning of the grievance mechanism(s) progress reports. B INCIDENTS AND ACCIDENTS Promptly notify the Association of any incident or accident related to the Project which Notify the Association no later than 48 PIT within MoF has, or is likely to have, a significant adverse effect on the environment, the affected hours after learning of the incident or communities, the public or workers, including, inter alia, cases of sexual exploitation and accident. abuse (SEA), sexual harassment (SH), and accidents that result in death, serious or multiple injury. Provide sufficient detail regarding the scope, severity, and possible Provide subsequent report to the causes of the incident or accident, indicating immediate measures taken or that are Association within a timeframe planned to be taken to address it, and any information provided by any contractor acceptable to the Association. 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 Project Implementation Team (PIT) with qualified staff and The Organizational structure should be MoF resources to support management of ESHS risks and impacts of the Project including an fully established within 90 days after Environmental and Social Specialist (ESS). Project effectiveness. The organizational structure, including the specialists, should be maintained throughout Project implementation. 1.2 ENVIRONMENTAL AND SOCIAL INSTRUMENTS 3|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1. Develop, disclose and implement a Stakeholder Engagement Plan (SEP) for the Project, 1. Adopt and implement the SEP prior PIT within MoF consistent with ESS10. to Appraisal, and throughout the project thereafter. 2. Develop, disclose and implement a Labour Management Procedures (LMP) for the Project, consistent with ESS2, as part of the Project Operation Manual. 2. Adopt the LMP prior to project effectiveness, and throughout the 3. Develop and cause the PIT to implement the site-specific Environmental and Social project thereafter. Management Plan (ESMP), for any subprojects as needed. 2. Adopt the ESMP prior to the carrying out of any subproject that requires the adoption of such an ESMP. Once adopted, implement the respective ESMP throughout Project life. 1.4 TECHNICAL ASSISTANCE Ensure that the consultancies, studies, capacity building, training, and any other Throughout the project PIT within MoF technical assistance activities under the Project are carried out in accordance with terms implementation. 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 is relevant. 2.1 LABOR MANAGEMENT PROCEDURES Develop, disclose, and implement Labor Management Procedures (LMP) for the Project, To be developed as an annex to the PIT within MoF including, inter alia, provisions on working conditions, management of workers Project’s Operations Manual and relationships, occupational health and safety (including personal protective equipment, disclosed before project effectiveness. and emergency preparedness and response), code of conduct (including relating to SEA and SH), forced labor, child labor, grievance arrangements for Project workers, and To be implemented throughout project applicable requirements for contractors, subcontractors, and supervising firms. implementation. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish, maintain and operate a grievance mechanism for Project workers, as described To be established in the same PIT within MoF in the LMP and consistent with ESS2. timeframe as 2.1. 4|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY To be implemented throughout project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT is relevant 3.1 WASTE MANAGEMENT PLAN Develop and implement a E-Waste Management Plan (WMP), to manage hazardous and Prepare and adopt the E-WMP, prior to PIT within MoF non-hazardous wastes, consistent with ESS3. Appraisal, and thereafter implement the WMP throughout Project implementation. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Incorporate resource efficiency and pollution prevention and management measures in Once adopted, implement the ESMP PIT within MoF the ESMP to be prepared under action [1.2] above. requirements throughout Project implementation. ESS 4: COMMUNITY HEALTH AND SAFETY is not currently relevant. 4.2 COMMUNITY HEALTH AND SAFETY Adopt and implement occupational health and safety (OHS) measures, including specific Adopt before Appraisal and implement PIT within MoF measures to ensure that all Project activities minimize the spread of infectious diseases throughout project life. like TB, HIV/AIDS and COVID-19. Assess and manage specific risks and impacts to the community arising from Project activities, including, inter alia, response to emergency situations, and include mitigation measures in the ESMP. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT (Not Relevant) ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES (Not Relevant) 6.1 ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES (Not Relevant) ESS 8: CULTURAL (Not Relevant) 8.1 5|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 8.2 ESS 9: FINANCIAL INTERMEDIARIES [This standard is only relevant for Projects involving Financial Intermediaries (FIs).] (Not Relevant) ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE is relevant 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Develop and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent Disclose and adopt the SEP prior to PIT within MoF with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, Appraisal and thereafter implement the relevant, understandable and accessible information, and consult with them in a SEP throughout Project culturally appropriate manner, which is free of manipulation, interference, coercion, implementation. discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM Establish, publicize, maintain, and operate an accessible grievance mechanism, to GRM to be established in the same • MoF receive and facilitate resolution of concerns and grievances in relation to the Project, timeframe as 10.1 and maintained • LPSFSDP - PIT promptly and effectively, in a transparent manner that is culturally appropriate and throughout project implementation. 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 6|Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – [name] Project MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY CS1 The GoL will design and implement training for targeted groups involved in the Project to Training of target groups to be • PIT within MoF improve their awareness of risks and mitigate the impacts of the LPSFSDP. delivered within 90 days following • World Bank The target groups for this training include Beneficiary/Participating Ministries, District project effectiveness. Councils. This plan will be adapted to meet needs This ESCP proposes a preliminary training plan covering the following topics. during Project implementation. • ESF Requirements. • Roles and responsibilities for environmental and social issues. • Occupational health and safety (including TB, HIV/AIDS and COVID-19 recommendation). • Grievance Mechanisms and codes of conduct CS2 The GoL will design and implement training for the project workers improve their Training for PIT and project staff • PIT within MoF awareness of risks and mitigate the impacts of the LPSFSDP. delivered within 90 days following • World Bank The Project workers include PIT staff, Contractor staff and staff of other project service project effectiveness. providers. The training will cover the following topics. • ESF Requirements, including grievance mechanisms. Training for PIT consultants Repeated as • Roles and responsibilities for environmental and social issues. necessary throughout project. • Occupational health and safety (including TB, HIV/AIDS and COVID-19 recommendation). This plan will be adapted to meet needs • Labour requirements. during Project implementation. • Emergency prevention and preparedness and response arrangements to emergency situations. • Managing GBV/SEA risks. • Maintaining GRM and keeping GRM log. • E-Waste Management. 7|Page