The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) Appraisal Environmental and Social Review Summary Appraisal Stage (ESRS Appraisal Stage) Public Disclosure Date Prepared/Updated: 11/17/2022 | Report No: ESRSA02426 Nov 17, 2022 Page 1 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Comoros EASTERN AND SOUTHERN P179291 AFRICA Project Name Shock Responsive and Resilient Social Safety Net Project in Comoros Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Social Protection & Jobs Investment Project 11/11/2022 12/20/2022 Financing Borrower(s) Implementing Agency(ies) UNION OF COMOROS MINISTRY OF HEALTH, SOLIDARITY, SOCIAL PROTECTION AND GENDER PROMOTION Public Disclosure Proposed Development Objective To provide emergency cash transfers and improve the resilience of vulnerable households Financing (in USD Million) Amount Total Project Cost 30.00 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? Yes C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] The Project Development Objective (PDO) of the project is to provide emergency cash transfers and improve the resilience of vulnerable households. The project builds on the involvement of the World Bank in social protection and emergency response in Comoros for the past decade, and benefits from ongoing engagement through the COVID-19 response. The proposed project has immediate and medium-term objectives. The project has 4 components. Component 1: Ensuring Immediate Response to Shock (9.50 millions USD) Nov 17, 2022 Page 2 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) Component 1 will provide Social Cash Transfer (SCTs) to support poor and vulnerable households avoid a significant erosion of their living conditions and human capital, given the adverse effects of decreasing purchasing power and consumption. The component will support the vertical expansion of the Social Safety Net program (P150754) in areas where they are operational and horizontal scale-up to new beneficiaries. A combination of geographical, community- based and Proxy-Means Targeting (PMT) mechanisms will be used in a complementary way to identify beneficiaries and minimize exclusion and inclusion errors. Validation of enrolled beneficiaries will be done through community visits, processing of potential complaints, and public meetings. For the targeting process, tools and monitoring systems will be prepared in advance, and the project will be assisted by external consultants and NGO. The payment system will use mobile money whenever possible, and communication will also be strengthened throughout the program. Activity implementation under this component will be supported by accompanying measures (AM) and community mobilization. AM are designed to encourage early childhood development, human capital development (education, health, nutrition), women’s empowerment, etc. Component 2: Establishing economic opportunities– US$16.5 million equivalent. This second component aims to provide economic opportunities and support job creation for the most vulnerable households and strengthen their resilience. This component has two sub-components: (i) livelihood and income generating activities (ii) cash-for-work for resilience program,. Sub-component 2.1: Supporting livelihood and income generating activities. This activity targets poor and vulnerable households and aims to contribute to their economic and financial autonomy and stronger resilience by creating jobs. Public Disclosure This sub-component will provide beneficiaries with conditional productive funding to invest in eligible income- generating activities of their choice, along with technical training to build their capacity as well as AM. Beneficiaries will be provided with the necessary skills and support to develop their income-generating activities and ensure they meet the conditions for livelihood grants. Technical training will also be provided throughout the entire duration of the program; this will provide beneficiaries with skills specifically relevant to their chosen field of activity (e.g., modern methods of planting, farming, organic composting, etc.). Throughout the program, targeted households will be supported through AM. Beneficiaries will participate in sensitization sessions and receive nudges on self- confidence and planning. They will be trained on the following themes: Financial literacy; Citizen governance; Wash, nutrition, sanitary and health practices, early childhood development; Youth reproductive health (fight against teenage pregnancies, abortion); Fight against HIV-AIDS; Sex education and fam ily planning; Gender-based violence (GBV); Marketing and processing; Business plan; green economy and Livelihood diversification. Households will also benefit from coaching providing them with advice and recommendations regarding their chosen activity. Disabled households will receive accompanying measures and technical training which will be customized to their disability. The program will also enhance early childhood development through AM and mother leaders. The program will be led in the community by mother leaders and father leaders who will help mothers from beneficiary families learn and apply effective parent-child interaction and nutrition practices. Sub-component 2.2: Cash for work for resilience. This sub-component will provide employment to unskilled and semi- skilled workers on labor intensive interventions, support beneficiaries with additional income to meet their immediate needs while building their skills, generate community assets for local development and further address food insecurity. The works carried out under this sub-component will provide public goods such as improved productive infrastructure for landscape management, the prevention of soil degradation, and reforestation, which will yield public benefits for the communities. Only labor-intensive activities that are of common public interest or that Nov 17, 2022 Page 3 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) benefit the whole community are eligible under this sub-component. This sub-component will not finance infrastructure for private, administrative, political, or religious purposes; projects planned to be financed by other programs; and projects that might cause involuntary displacement or income loss for any group of people. This subcomponent will allow local communities to undertake activities that are centered on climate change adaptation and resilience building at community level. Those activities will focus on biotechnology, waste treatment and recycling, tree or fruit tree nurseries, water security improvement, soil erosion reduction, reforestation, small construction projects to improve productive capacity or water infiltration and storage, and livelihood diversification. Projects under this sub-component will also include agricultural works that will promote adoption of climate-smart agricultural practices. This program will provide economic and training opportunities to vulnerable households in poor areas where there is a potential to increase local agricultural production. Component 3: Strengthening safety net coordination, project management, monitoring and evaluation – US$4 million equivalent Sub-component 3.1: Building institutional capacity. The proposed sub-component ensures continuity of technical and institutional capacity building of the relevant departments of the GoC. Capacity building will include, but will not be limited to, transfer of capacity and knowledge, further supporting the government in its effort to establish a social registry, development of safety net delivery systems which include operational procedure for registration, enrolment, targeting, registering grievances, payment delivery, community outreach, monitoring, and impact evaluation. This subcomponent will enhance the institutional framework and facilitate policy dialogue, as well as enhance coordination across relevant sectors. This will include support to the social protection committee and establishment Public Disclosure of the National Social Protection Strategy. It will also support enhancement of the legal and institutional framework of the social protection sector in Comoros Sub-component 3.2: Project management, monitoring and evaluation. This sub-component will finance all project management costs, including implementation and monitoring of E&S risk management and the implementation and strengthening of social accountability mechanisms and the project Grievance Redress Mechanism (GRM) . Component 4: Contingency Emergency Response Component (CERC). Following an eligible crisis or emergency, the Borrower may request the Bank to re-allocate uncommitted project funds to support emergency response. This component will allow for rapid reallocation of credit and grant uncommitted funds in the event of an eligible emergency as defined in the World Bank Operational Policy. D. Environmental and Social Overview D.1. Detailed project location(s) and salient physical characteristics relevant to the E&S assessment [geographic, environmental, social] The Comoros is an island nation off the coast of East Africa, in the Indian Ocean between northern Mozambique and northern Madagascar. Comoros is made up of three islands that have inadequate transportation links, a young and rapidly increasing population, and few natural resources. This country is densely populated, with approximately 465 inhabitants per km2, and 53% of the population is under 20 years of age. High population density places intense Nov 17, 2022 Page 4 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) pressure on natural resources and the environment. The country’s location and topography are among the most climate vulnerable in the world and 54.2% of the population live in at-risk areas. The project will provide national coverage and will be implemented in the three islands, Mweli, Anjouan and Grandes Comores. The islands of the Comoros Archipelago were formed by volcanic activity. Many areas in Comoros constitute some ecoregion. But now, less than one-sixth of the land remains covered with forest, and rapid deforestation caused mainly by domestic firewood consumption threatens to reduce the islands’ forested land still more. Cyclones and other climatic factors such as droughts and erratic rainfall in the Southern Africa region are making the agricultural lean season longer, thus increasing risk of food insecurity. The COVID-19 pandemic and inflation have increased the vulnerability of the Comorian population and highlighted the gaps on social protection. The proposed project, fully aligned with the World Bank's Country Partnership Framework (CPF) for the Comoros for the 2020 to 2024 financial years, aims to support the country in finding a sustainable growth path and strengthening the resilience of its population in the face of multidimensional shocks. The project provides support to poor and vulnerable households operating in farming (cattle, poultry, sheep, etc.), agriculture (market gardens, subsistence agriculture, cash crop production), nursery production, fishery, local commerce, and vocational training professions (plumbing, masonry, sewing, etc.) and conducts activities involving agricultural works, anti-erosion works, reforestation, small construction to improve productive capacity or water infiltration and storage, rehabilitating damaged small community infrastructure, removing sand, and clearing roads. s. The project is structured around four components. Through Component 1 and 2, the relevant E&S Standards include: Public Disclosure ESS1 to ensure adequate E&S risk management; ESS2 related to the hiring of project workers at national and local level, risks associated mainly with Occupational Health and Safety as well as labor conditions ; ESS3 because of the resources consumption and pollution potentially during rehabilitation works; ESS4 mainly due to the for risks of SEA/SH, social conflicts due to misunderstanding of cash transfer beneficiaries, spread of the Covid-19, risks for the communities related to road traffic and hazards induced by civil works; ESS5 related to Rehabilitation and construction of community-based infrastructure (Sub- Component 2.2) which could lead to land acquisition, access restriction and economic displacement ; ESS6 because of some subproject activities related to the cash for work (component 2.2) may have direct, indirect or cumulative impacts on critical or sensitive natural habitats; ESS8 if previously unknown cultural heritage is encountered during project activities ; and ESS10 related to the identification and coordination of various stakeholders with different interests and levels of influence, stakeholders engagement, inclusion of disadvantaged and vulnerable groups and project information disclosure. D. 2. Borrower’s Institutional Capacity The implementation arrangements will remain the same as in the Social Safety Net Project (P150754) by the PIU called ‘’Unité de Gestion de Projet Filets Sociaux de Sécurité ‘’ (UGP-FSS) established under the Ministry of Health, Gender, Solidarity and Social protection (MoHSSPGP). The UGP-FSS is responsible for the day-to-day operation of the project, ensuring the implementation and monitoring of project activities, including the E&S risk managements. The UGP-FSS has a good record in implementing World Bank projects under safeguard policies. However, a preliminary assessment has shown that this PIU has limited E&S capacity and is not familiar with the ESF. The Bank team will therefore make sure (i) that the projectconfirm the existing Environment Specialist and hire the social specialist (this central level PIU will be supported by the Regional Implementation Units with one Assistant Environmental Specialist and 1 Assistant Social Specialist). and , (ii) that the required capacity building and training requirements are identified and reflected in the ESCP. To build the capacity of the PIU staff, training shall be provided on stakeholder mapping and engagement; specific aspects of environmental and social assessment; emergency preparedness and Nov 17, 2022 Page 5 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) response; community health and safety; Occupational Health and Safety; incident reporting; ESF, and World Bank Group EHS Guidelines;; GBV/SEA-SH risk mitigation; inclusion of vulnerable and disadvantaged groups in the consultation process; GRM; Development, implementation, monitoring and reporting in accordance with the LMP; Awareness and prevention on sexually transmitted infections: HIV/AIDS, etc.; Awareness on GBV, SEA-SH and child protection; Raising awareness on barrier measures against the spread of Covid-19; Implementation of RP. II. SUMMARY OF ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Moderate Environmental Risk Rating Moderate The project’s environmental risk is classified as Substantial. The overall adverse risks and potential adverse impacts to be generated on the environment are site-specific, reversible and will be mitigated by specific mitigation measures. The main environmental risks and impacts are associated with activities under component 2.1 providing support to poor and vulnerable households operating in farming (cattle, poultry, sheep, etc.), agriculture (market gardens, subsistence agriculture, cash crop production), nursery production, fishery, local commerce, and vocational training professions (plumbing, masonry, sewing, etc.); component 2.2 relating to cash-for-work resilience activities that may involve agricultural works, anti-erosion works, reforestation activities, small construction projects to improve productive capacity or water infiltration and storage, and service road and small crossing works; and rehabilitation of community-based infrastructure. The implementation of activities is anticipated to present occupational health and safety (OHS) as well as labor management risks for project workers as beneficiaries, and direct, indirect and Public Disclosure cumulative environment, health and safety risks and impacts associated with any construction and operations activities in these sectors, including risks and impacts related to waste management, pest management, conversion of natural habitats, soil erosion, noise and dust generation., and community health and safety (mainly due to construction-induced traffic). Social Risk Rating Moderate In line with the World Bank ESF guidelines, the project’s social risks are assessed as Substantial. The Project will generate many social positive impact as it will address the immediate needs of vulnerable households and enhance the resilience and improvement of human capital outcomes. Project activities consist mainly of (i) social cash transfer (SCT) and accompanying measures (AM) for component 1; (ii) cash for work and rehabilitation/reconstruction of small community infrastructures, conditional livelihood grant and technical trainings with component 2; and (iii) institutional capacity building under the component 3. The project’s activities are not expected to produce any large- scale, significant and/or irreversible adverse impacts. Given that the civil works are expected to be minor (rehabilitation/contruction of small community infrastructure under component 2), the Project is not expected to lead to induce significant labor influx. However, there are potential adverse social risks and impacts attributable to project activities such as (i) social exclusion and elite capture during the selection beneficiaries under components 1 and 2; (ii) OHS risks related to civil works under the component 2 with the rehabilitation works, (iii) social conflicts due to community misunderstanding of selection process; (iv) potential gender-based violence (GBV) risks and/or sexual exploitation and abuse (SEA) and sexual harassment (SH); (v) child labor among community workers; (vi) beneficiaries security issues related to cash payment ;; and (vii) lack of stakeholder engagement in coordination and weak implementation capacity. While no large-scale land acquisition is expected under this project, activities under component 2.2 might result land acquisition as it might involve rehabilitation and/or construction of community Nov 17, 2022 Page 6 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) infrastructure. In addition, the PIU has limited E&S risk management capacity to address all ESF requirements. The Bank team will keep providing training on implementing the ESSs during project implementation to strengthen the PIU capacity on E&S impact and risk management for the project. This social risk rating will be revisited before appraisal and will continue to be assessed and re-assessed during implementation. B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: The ESS1 standard is relevant. The project will finance (i) social cash transfer (SCT), community mobilization and accompanying measures (AM) for component 1; (ii) cash for work, rehabilitation/reconstruction of small community infrastructures and early recovery response, conditional livelihood grant for vulnerable households, technical trainings and sensitization sessions trough component 2; and (iii) institutional capacity building for line ministries to strengthening safety net coordination under the component 3. The Project will have overall positive environmental and social impacts as it will strengthen resilience of poor and vulnerable households through social safety net in selected areas in Comoros island. However, these project activities may also induce potential adverse E&S risks and impacts. The selection of SCT beneficiaries under the component 1 may cause risks related to elite capture and exclusion of disadvantaged groups and conflict within communities regarding the result of the selection. It is also possible that project activities in all Public Disclosure components including the intensive labor interventions and the rehabilitation/construction of community infrastructure could induce labor related risks such as child and forced labor, discrimination, poor working conditions and SEA/SH risks. For Sub-component 2.2, the risks and impacts associated with construction and rehabilitation of the community infrastructure are occupational health and safety (OHS) risks, generation of solid waste, dust and noise generation, erosion and road safety hazards. Also, risks associated with pest management might be induced by the labor-intensive interventions that involve agricultural works, anti-erosion works and reforestation activities, planned under Sub-components 2.1 and 2.2 . Those community based civil works and construction of infrastructure under component 2.2 might cause loss of land. Other social risks might include (i) difficulty to maintain stakeholders’ engagement for component 3 which will enhance the institutional framework and facilitate policy dialogue, coordination within the social protection sector as well as intersectoral coordination; (ii) robbery attack related to cash payment under the SCT and the cash for work (iii) propagation of diseases including STD/HIV, COVID 19 and (iv) SEA/SH risk which may induced by abuse of power for sexual purpose during the cash payment. The scope and scale of the anticipated risks and impacts are expected to be site-specific, limited, localized, temporary and largely reversible. Since the nature and emplacement of all the infrastructure to be constructed or rehabilitated will only be identified during the first year of project implementation, the Borrower has prepared an advanced Environmental and Social Management Framework (ESMF) which could be disclosed by appraisal. The ESMF will be finalized prior to the disbursement of Component 2 and shall be disclosed accordingly. The ESMF describes the overall project, its baseline conditions, applicable policies and legislation, and overall key environmental and social considerations and potential impacts. The proposed subprojects described in the exclusion list set out in the ESMF shall be ineligible to receive financing under the Project. This project will not finance infrastructure for private, administrative, political, or religious purposes.; projects planned to be financed by other programs; and projects that might cause involuntary Nov 17, 2022 Page 7 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) displacement or income loss for any group of people .However, project activities under sub-component 2.2 (cash for work involving small construction of community based infrastructure) might induced the land acquisition even if it will be mainly proceed by community land donation. For all activities that will be designed and executed during Project implementation, the Environmental and Social Commitment Plan (ESCP) specified that the detailed site-specific planning shall include corresponding Environmental and Social Impacts Assessments (ESIA) and site-specific ESMPs development for the component 2.2 , which must, in turn, be consulted upon with relevant stakeholders, disclosed, and approved by the Bank prior the commencement of civil works. The ESMF also includes adapted measures tailored to mitigate the risks of SEA/SH under project implementation, which are outlined under the project’s SEA/SH Action Plan (annexed to the ESMF). These plans shall include specific requirements for Occupational Health and Safety (OHS) issues, work conditions, waste management plans, integrated pest management plan and prevention of child and force labor, SEA/SH and transmissible diseases. The ESMF also is proposing approaches to ensure the coordination with key stakeholders to facilitate project implementation and monitoring at the local level. The project has a Contingency Emergency Response Component (CERC). The ESMF should contain guidance regarding the implementation of the CERC. To mitigate the project E&S risks, the project has drafted and will disclose by appraisal (i) an Environmental and Social Commitment Plan (ESCP), (ii) a Stakeholder Engagement Plan (SEP); Labor Management Procedures (LMP); and by the end of appraisal (iv) a draft Environmental and Social Management Framework (ESMF) which will include an Integrated Pesticide Management Plan, the GBV/SEAH/SH action plan and guidance regarding the implementation of CERC; and (v) a draft Resettlement Framework (RF). Site-specific environmental and social instruments for sub- Public Disclosure projects will be prepared as and when required during the project implementation covered by the ESMF. The ESMF and RF shall be finalized prior to disbursement of component 2 , and thereafter implement throughout Project implementation ESS10 Stakeholder Engagement and Information Disclosure ESS10 is relevant. At this stage, stakeholders identified for the project include, but are not limited to the Ministry of Health, Gender, Solidarity and Social Protection (MoHSSPGP), the PIU represented by the ‘’Unité de Gestion de Projet Filets Sociaux de Sécurité ‘’ (UGP-FSS); other lines ministries and local authorities involved in the beneficiaries selection, private sector (microfinance and telecommunication companies); and households beneficiaries. Public consultations were carried out by the the UGP-FSS and the MoHSSPGP as part of the environmental and social assessment of the project. A prior information meeting was organized by the existing PIU during the supervision mission of the ongoing Social Safety Net Project (P150754) targeting the main stakeholders involved in the implementation of the proposed Project including the authorities or their representatives, technical specialists of the WB, as well as relevant development partners, representatives of NGOs and private operators in telecommunication. Several additional and inclusive consultations also have been conducted in the targeted three regions in the island with current beneficiaries, and local communities representatives. These consultations mainly served to inform stakeholders of the consistency of the proposed project and highlighted their expectations in relation to the expected results of the project. A combination of geographical, community-based and Proxy-Means Targeting mechanisms will be used in a Nov 17, 2022 Page 8 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) complementary way to identify beneficiaries and minimize exclusion and inclusion errors. Enrolled beneficiaries will undergo validation through community visits and public meetings. The SEP includes stakeholder mapping and communication strategy for interested parties, various beneficiaries and project affected persons, including disadvantaged and vulnerable groups, to ensure adequate inclusion of vulnerable people and allow for meaningful stakeholder consultations and inputs in the project design. The Government of Comoros has prepared this SEP according to the requirements of ESS10 which promotes participation of vulnerable groups and considers sensitivities of SEA/SH issues, special needs such as cultural practices or any other obstacles for effective engagement and consultation throughout the project lifecycle. The SEP has established a Communications Mechanism to receive concerns, complaints, suggestions and feedback from stakeholders and potential beneficiaries as well as affected people including the vulnerable groups. Detailed GM procedures are presented in the SEP including responsible to receive and address grievances, different means of receiving grievances and stipulated time frames to address and respond to grievances. In addition, the SEP has been designed to improve vulnerable group consideration to by the project by applying measures to remove barriers to their participation. The SEP has set appropriate measures on how to engage all key stakeholders in the context of COVID-19 without spreading the disease amongst them. Specific communication techniques have been proposed to ensure that social interactions are minimized. The SEP will be disclosed by appraisal. Public Disclosure B.2. Specific Risks and Impacts A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions ESS2 is relevant. The Project workers for this project include (i) direct workers (including staff hired under the PIU), (ii) contracted workers including NGOs and the private sector to support the project on communications, (iii) civil servants working at the MoHSSPGP to be involved under the component 3, and (iv) and community workers linked to the cash for work activities under component 2. Project’s workers who are in the public sector (civil servants), they will remain subject to the terms and conditions of the national labor code. The project is not expected to entail any large-scale construction activities, but it will finance a community-based cash for work program and rehabilitation of small community infrastructure. These types of activities will likely involve community workers. A combination of geographical, community-based and Proxy-Means Targeting (PMT) mechanisms will be used in a complementary way to identify beneficiaries and minimize exclusion and inclusion errors. Validation of enrolled beneficiaries will be done through community visits, processing of potential complaints, and public meetings. Since the specific locations and interventions of the project are not yet determined, it is not possible to determine at this stage the size of the labor force that will be employed by this project, but it will be estimated by appraisal. Workers can be exposed to a wide variety of risks such as: (i) occupational health and safety risks at the workplace due to mishandling tools by community workers, pollutions related to civil works; (ii) non-respect of workers' rights, poor working condition and potential child labor and (iii) SEA/SH risks. Nov 17, 2022 Page 9 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) To manage risk related to Project workers, draft Labor Management Procedures (LMP) have been prepared which set out measures to mitigate the OHS risks, and protect workers’ rights as set out in ESS2 and to prohibit child labor and forced labor. The LMP includes the terms and conditions of employment, non-discrimination and equal opportunities, workers' organizations, GRM for labor issues, and measure to mitigate SEA/SH risks for both direct and contracted workers. The LMP should be cleared and disclosed in-country and on the Bank’s website by appraisal. The OHS measures will be included in activity/site specific ESMPs, while for contract and community workers common risks and impacts will be assessed and addressed in the ESMF. The measures will include requirements for the use of Personal Protective Equipment (PPE), planning of training activities, and investigation/reporting of accidents. Regarding risks related to SEA/SH, the government will ensure that all project workers are adequately instructed and trained, on a regular basis, on prevention and reporting procedures available for SEA and SH as set out in ESMP and SEP. All workers will be expected to sign a code of conduct to prevent and address potential harassment, gender or SEA/SH issues, intimidation and/or exploitation during the implementation of the activities financed under this project. Moreover, given that pesticides will be used for the agriculture, agroforestry under component 2, this may induce risks of exposure for the workers handling and applying the pesticides. As part of the ESMF, the project will adopt and implement specific provisions for pesticide management to protect workers from risk of exposure. ESS3 Resource Efficiency and Pollution Prevention and Management ESS3 is relevant. The Project is national wide and involve construction/rehabilitation of community-based infrastructure as well as labor intensive intervention to support agriculture, reforestation and water infiltration. The project could result in pollution of land, water, and air as well as use of natural resources, groundwater pollution and Public Disclosure wind drift beyond the target application area. The project is not anticipated to result in consumption of significant quantities of energy, water or raw materials or emit signfiicant quantities of greenhouse gases. Water may be used for dust suppression and domestic use at project sites. Pollution during the project execution may include air emissions such as exhaust from vehicles, noise emission and fugitive dust generated during transportation of materials, and rehabilitation works. Construction materials are expected to be obtained from sources close to project areas, such as licensed quarries and approved vendors, depending on the needs. The activities may generate erosion, dust, noise from equipment and vehicle movements, water, soil and air pollution. The relevant E&S subproject instruments related to the activities will identify all sources of hazardous and nonhazardous waste from the project activities, and will include screening and scope of climate risks (through climate and disaster risk screening technical note) and propose mitigation measures to manage those as well as environmental measures related to the risks and impacts likely to be generated. Potential risks associated with the use of pesticides such as groundwater pollution and wind drift beyond the target application area might be induced by the component 2. The preparation of a pesticide management plan is not necessary at this stage. Standardized mitigation measures to address pesticides management can be incorporated in the ESMP section of the ESMF. ESS4 Community Health and Safety ESS4 is relevant to the project. The community is the center of the project activities that may induce community health and safety issues under the component 1 and 2 such as exposure to COVID-19 risks and other communicable diseases, road safety and exposure to hazards due to civil works both under the cash for work activities and the Nov 17, 2022 Page 10 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) rehabilitation/construction of community infrastructure, associated SEA/SH risks for community beneficiaries related to potential abuse for sexual purposes. However, as mentioned in ESS2, the Labor Intensive Work activities will be conducted by community members thus reducing the risk of labor influx and its associated impacts on the community. These risks are assessed as part of the ESMF), and appropriate measures have been developed. A pesticide management plan will be developed and inserted in the ESMF to help protect communities and ecosystem services. Infrastructure rehabilitation and construction works could generate road accidents particularly risks related to the transport of project workers to work sites and community risks for travel through active construction zones. Beneficiaries security issues related to cash payment is expected during the payment. The current ESMF in preparation is re-assessing the level of risk and will provide additional measures as necessary. The ESMF will include measures to improve road safety and and reduce traffic accidentsprovide guidelines for developing either specific traffic management plans for subprojects or integrated traffic safety into subproject instruments. Community health and safety risks will be mitigated among others while respecting ( (i) the measures defined in the plan to prevent the spread of COVID- 19, (ii) social distancing and (iii) by conducting an awareness campaign for workers and communities concerned by the project. The SEA/SH risk of the project has been classified as substantial. Additional activities are included in the SEA/SH action plan are specific actions (training, public awareness, etc.) to avoid such risks. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement ESS5 is relevant to the project. Project activities under sub-components 2.2 will finance some agriculture work, Public Disclosure reforestation and water infiltration activities, as well as construction/rehabilitation of community infrastructure that might cause land acquisition although mainly expected to be land donation (based on the experience of ongoing safety net project). However, at this stage, the footprint of the project and the nature and magnitude of land acquisition are not yet known. It is not expected that those activities would result in large scale land acquisition. To mitigate any risk that would result from the implementation of this component 1, a draft Resettlement Framework (RF) is in preparation in accordance with ESS5 requirements. The RF will identify all potential risks that could occur during the construction and rehabilitation works and set mitigation and compensations principles that would be applied by the Government of Comoros. The draft RF will be consulted upon and will be disclosed by the end of appraisal. The final version of the RF will be a disbursement condition of this component 2. The potential risks and mitigation measures for the impact on the population will be detailed subsequently in the site-specific Resettlement Action Plans (RAPs) to be prepared during the project’s implementation as necessary. ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources ESS6 is relevant as some of the project's objectives are aligned with the ESS6 objectives, especially through reforestation. The sites and details related to these activities are yet not available at this stage. The ESMF will include guidance on screening out the proposed subprojects that may have direct, indirect or cumulative impacts on critical or sensitive natural habitats and natural resources and will provide guidance on addressing biodiversity-related risks and impacts to mitigate the alteration, destruction or degradation of relevant habitats and natural resources. Nov 17, 2022 Page 11 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) Because the project will be implemented in several locations (precise location unknown for now), as part of the mitigation hierarchy, and the project will be undertaking an analysis of alternatives for each sub-project location to investigate the ways and means to avoid, minimize the impacts on sensitive environmental, social and cultural receptors, minimizing land acquisition as set out in relevant ESSs. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities ESS7 is not relevant for the project. There are no Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities that meet the criteria of IP/SSHAUTLCs, per the requirements of this Standard, in the project area. ESS8 Cultural Heritage ESS8 standard is not relevant. At this stage, the presence of culturally significant sites associated with the project activities cannot be determined. Given the scale and nature of project activities no tangible or intangible cultural heritage is expected to be impacted. However, during project implementation, if any potential risk of affecting cultural heritage will be identified, the Project will develop as part of the ESMF and subsequent ESMPs a Cultural Heritage Management procedure with a clear Chance Finds Procedure to be implemented for both tangible and intangible cultural heritage. ESS9 Financial Intermediaries Public Disclosure The ESS9 standard is not relevant for this project. C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No Not relevant for the project OP 7.60 Projects in Disputed Areas No Not relevant for the project B.3. Reliance on Borrower’s policy, legal and institutional framework, relevant to the Project risks and impacts Is this project being prepared for use of Borrower Framework? No Areas where “Use of Borrower Framework” is being considered: N/A IV. CONTACT POINTS Nov 17, 2022 Page 12 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) World Bank Contact: Julia Rachel Ravelosoa Title: Senior Social Protection Economist Telephone No: 5339+6028 Email: jravelosoa@worldbank.org Contact: Julia Rachel Ravelosoa Title: Senior Social Protection Economist Telephone No: 5339+6028 Email: jravelosoa@worldbank.org Contact: Julia Rachel Ravelosoa Title: Senior Social Protection Economist Telephone No: 5339+6028 Email: jravelosoa@worldbank.org Contact: Julia Rachel Ravelosoa Title: Senior Social Protection Economist Telephone No: 5339+6028 Email: jravelosoa@worldbank.org Contact: Julia Rachel Ravelosoa Title: Senior Social Protection Economist Telephone No: 5339+6028 Email: jravelosoa@worldbank.org Contact: Julia Rachel Ravelosoa Title: Senior Social Protection Economist Telephone No: 5339+6028 Email: jravelosoa@worldbank.org Public Disclosure Borrower/Client/Recipient Borrower: UNION OF COMOROS Implementing Agency(ies) Implementing Agency: MINISTRY OF HEALTH, SOLIDARITY, SOCIAL PROTECTION AND GENDER PROMOTION V. FOR MORE INFORMATION CONTACT The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Julia Rachel Ravelosoa, Julia Rachel Ravelosoa, Julia Rachel Ravelosoa, Julia Rachel Ravelosoa, Leader(s): Julia Rachel Ravelosoa, Julia Rachel Ravelosoa Practice Manager Africa Eshogba Olojoba Cleared on 17-Nov-2022 at 14:01:36 GMT-05:00 (ENR/Social) Nov 17, 2022 Page 13 of 14 The World Bank Shock Responsive and Resilient Social Safety Net Project in Comoros (P179291) Safeguards Advisor Maria Do Socorro Alves Da Cunha (SAESSA) Concurred on 17-Nov-2022 at 16:08:0 GMT-05:00 ESSA Public Disclosure Nov 17, 2022 Page 14 of 14