The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) Appraisal Environmental and Social Review Summary Appraisal Stage (ESRS Appraisal Stage) Public Disclosure Date Prepared/Updated: 05/05/2022 | Report No: ESRSA02183 May 05, 2022 Page 1 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Uganda Eastern and Southern Africa P176747 Project Name Generating Growth Opportunities and Productivity for Women Enterprises (GROW) Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Social Sustainability and Investment Project 4/22/2022 6/16/2022 Inclusion Financing Borrower(s) Implementing Agency(ies) Ministry of Finance, Ministry of Gender, Labor Planning and Economic and Social Development, Development Private Sector Foundation Uganda Public Disclosure Proposed Development Objective To increase access to services that enable women entrepreneurs to grow their enterprises in targeted locations, including host and refugee communities Financing (in USD Million) Amount Total Project Cost 250.00 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] The project will primarily focus on supporting interventions that address the constraints to women’s economic empowerment with particular focus on women entrepreneurship, thereby enhancing women’s income, productivity and both the economic and social support systems that enable their success as entrepreneurs and leaders in their communities. In addition, the project will support the Government of Uganda’s gender-inclusive recovery from COVID19 and the gender targets under the Uganda Green Growth Development Strategy (UGGDS) (2017/18 – 2030/31). The project aims to create an enabling environment for women entrepreneurship with (a) increase in May 05, 2022 Page 2 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) access to finance through provision of strategic investment funds and linkages to financial institutions; this will allow women to invest in expansion of their businesses, thereby increasing their revenues and profits; (b) human capital development through provision of technical skills, socio-emotional skills, and digital skills that will enhance their productivity; (c) building social capital through creation of platforms that increase quality and size of women’s professional and business networks and provide access to new information and market opportunities to expand and successfully manage their businesses; (d) tackling social norms that hinder women’s economic participation and productivity through sessions on GBV, engagement with men, and gradual individual and community level norm change etc.; and (e) access to economic and social infrastructure through provision of common-user facilities for women businesses, childcare, and other infrastructure that contributes to an enabling environment for women owners/managers of growth-oriented businesses. The project interventions will support women entrepreneurs to generate more income, more profit and potentially expand the business to employ other women, thereby, creating jobs for women. The project consists of four components that together constitute a comprehensive package of customized support for empowering female entrepreneurs to grow and transition their enterprises from micro to small and from small to medium. Component 1 will provide enterprise development services for women through training (technical, life-skills, digital), business advisory services, and enhanced networks for women through platforms that facilitate market linkages and value chain development. In addition, this component will seek to change negative social norms through sessions on preventing and responding to GBV, engaging with men and community leaders, and the like. Component 2 will support creation of revolving funds that provide credit to women entrepreneurs. Component 3 will support investments in enabling infrastructure and facilities including common-user facilities and child-care centers to ensure Public Disclosure that women have access to economic and social infrastructure. Component 4 will support project management, policy innovations aimed at facilitating WEE, and evidence generation. The project will be coordinated by a Project Steering Committee chaired by the Ministry of Gender, Labour and Social Development (MGLSD), including key ministries such as the Ministry of Finance, Planning and Economic Development, Office of the Prime Minister, Ministry of Agriculture, Animal Industries and Fisheries, Ministry of Education and Sports, among others. The role of the PSC will be to provide policy guidance, approve annual work plans and budgets, oversee project progress and ensure coordination. MFLSD will implement the project through a Project Implementation Unit. 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 project is expected to have nationwide coverage also covering refugee settlements and refugee hosting communities. The initial phase of the project will cover 30 districts in Year 1 selected from all the 14 sub-regions of the country and Greater Kampala Metropolitan, increasing to 103 districts (two-thirds of the 146 districts of the country) in Year 3 and 4. Environment Deforestation is one of the leading environmental challenges in Uganda. The project should therefore avoid location of sub-projects close to or within protected forests, which could exacerbate the situation. Due to the uniqueness and diversity of ecosystems and variation of climatic conditions in Uganda, the country hosts 53% of the world’s mountain May 05, 2022 Page 3 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) gorillas, 11% of the global recorded species of birds, 7.8 % of global mammalian species, 19% of Africa’s amphibians and 14% of African reptilians. The country also hosts a high number of globally threatened species i.e. 39 mammals, 25 birds, 12 amphibians, 3 reptiles and 45 plants. General threats to biodiversity include conversion and degradation of the natural ecosystem, invasive species, excessive harvesting of flora and fauna, illegal wildlife trade, poaching, human-wildlife conflict, disease outbreaks, plastic waste and pollution of water bodies. Project should therefore avoid impact on natural habitats. Uganda is host to a number of wetlands of international importance but over the years, the country’s wetland cover has reduced due to wetland degradation. Construction and civil works especially under Components 2 and 3 are not expected to impact wetland resources, however, some contractors may use swamps along roads as water and sand sources for construction works. There is therefore a risk that they may exacerbate the problem of wetland pollution or destruction, for example when construction waste is illegally dumped in swamps adjoining roads. Site-specific ESIAs and ESMPs will be prepared, with clear mitigation measures to address this risk. Construction works especially involving earthworks could be affected by extreme climatic conditions such as floods or its consequence – landslides. The design of the subprojects, and accompanying ESMPs, will adopt elements of climate resilience, as technically and financially feasible. Social According to national census data 2019 estimates, the population of Uganda is 41.58 million, with females constituting about 51% of that population. 73% of population live in rural areas, the rest of the population resides in the urban settings. The sub-regions in Uganda are Buganda South, Buganda North, Kampala, Busoga, Bukedi, Elgon, Teso, Karamoja, Lango, Acholi, West Nile, Bunyoro, Toro, Kigezi and Ankole. Buganda South had the highest percentage of the population (13%) followed by Buganda North (11%) and Busoga (10%) respectively while Karamoja Public Disclosure had the lowest (3%) followed by Kigezi and Kampala (4% each respectively). The population size and distribution are a reflection of the number of people that are likely to be impacted by the project. The number of beneficiaries from the GROW Project will be determined upon the confirmation of the project areas within which the project will be implemented. Literacy rates for residents in urban areas were much higher than for the rural counterparts (85% and 73% respectively). The literacy levels were much lower among females in rural areas (68%) than in the urban areas (82%). In areas with lower literacy levels especially among women could lead to a number of women potential beneficiaries being excluded. Uganda’s female labour force participation rate is generally low estimated at 44.9% compared to 61.2% for men. This implies that 55.1% of working age females are outside the labour force. The women who participate in the labour force face specific barriers, constraints and challenges such as sociocultural norms that affect their career and business progression. In addition, many women (50.5%) aged 18-30 years are not in Education, Employment or Training (NEET) compared to 29% for their male counterparts. The implication is that 73.7% of the women in employment are self-employed. It is important to note that a large proportion of women in self- employment (22.2%) are compelled by family while 38.1% joined self-employment because they could not find a job. This implies that majority are in non-satisfactory self-employment and would want to change the job if there was an opportunity. The VMGs in Uganda include ethnic minorities, refugees and the associated host communities, people living with disabilities, female youth, elderly females, people living with HIV, survivors and those at risk of GBV. Communities, which meet the conditions of SSAHUTLC under ESS7 are the Batwa in the West; IK and Tepet in the Karamoja Region; and Benet in the Elgon Region of Uganda, are referred to as vulnerable and marginalized in Uganda. Project activities will need to be designed to ensure these groups can access project benefits. Prevalence rates of GBV in Uganda are high compared to both global and regional averages. Overall, 51 percent of all women and 52 percent of all men aged 15-49 in Uganda reported experiencing physical or sexual violence (by any perpetrator) at least once since the age of 15. Similarly, one in five women (22%) and men (20%) have also experienced physical violence (UDHS 2016). Given this, the Project is including measures to prevent and respond to GBV as part of Project design. May 05, 2022 Page 4 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) D. 2. Borrower’s Institutional Capacity Government will establish a Project Steering Committee (PSC) to oversee and coordinate implementation of the project at the policy level. The Permanent Secretary of the MGLSD will chair the PSC and have overall responsibility for project coordination. The PSC will consist of the permanent secretaries of the implementing agencies (the Ministry of Finance, Planning and Economic Development (MOFPED) and the MLG), the Executive Director of Private Sector Foundation Uganda (PSFU) as well as key technical ministries and agencies (the Office of the Prime Minister (OPM), the Uganda Investment Authority (UIA), the Ministry of Trade, Industry and Cooperatives). The PSC will liaise with an advisory group that will comprise selected women entrepreneur bodies. Different agencies will implement different components, MGLSD will implement Component 1A and 1B, Component 2A, 3 and 4B. The PSFU will implement component 1C and 1D, and Component 2B. Both MGLSD and PSFU will constitute Project Implementing Teams (PITs). The MGLSD, in collaboration with the PSFU and the MOFPED, will utilize the same Project Advisory Committee for Refugees (PACR) established as part of the Bank-financed INVITE project (P171607). The PACR will consist of representatives of the OPM and the United Nations High Commission on Refugees, and selected representatives of other implementing agencies. Its purpose is to ensure coordination and complementarity with other implementing agencies, consolidate lessons learned from other projects and policy initiatives, and provide feedback in the implementation of programmed Refugee Hosing District (RHD) activities. The use of this PACR will avoid institutional Public Disclosure duplication and further strengthen coordination with the INVITE project, including the units within the PSFU implementing these activities. The project will finance two Project Implementation Teams (PITs) that will enhance government capacity to ensure high quality delivery of project components: one each at the MGLSD and PSFU. Each PIT at MGLSD and PSFU will comprise a project coordinator, a deputy project coordinator, and key technical and operational staff, including finance, procurement, environment specialist, social development specialist and a gender specialist and monitoring and evaluation (M&E) specialist. A separate contracts committee will be set up in each implementing agency. For Component 1 the MGLSD will contract qualified training providers to conduct the training in the different regions. The PITs will report to the responsible Permanent Secretary (or Executive Director at PSFU) that sits on the PSC and is responsible for implementation in their respective ministry or agency. The Permanent Secretary will assign government officials or recruit external professional staff to fill the positions of each PIT, with the operational costs and eligible staffing costs financed from subcomponent 4A. Each PIT will include a refugee specialist to support MGLSD, PSFU to allow appropriate coordination with refugee stakeholders at the national and sub-national levels. They will ensure that the capacity building activities are appropriately delivered within RHDs. The MGLSD refugee specialist will also sit within the Secretariat for the Jobs and Livelihoods Integrated Response Plan to ensure GROW’s close alignment and ability to support implementation of the JLIRP and alignment with Uganda’s CRRF. The refugee specialist in the PSFU PST will also coordinate with the INVITE PIU to ensure close alignment of the two projects. Project monitoring and evaluation staff will be responsible to ensure that appropriate data is collected within refugee settlements in liaison with OPM and UNHCR. May 05, 2022 Page 5 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) MGLSD will also establish a Memorandum of Understanding with the Office of the Prime Minister (OPM) that will enable the project to use OPM’s Development Response to Displacement Impacts Project (DRDIP) (P152822) implementation structures for implementation in Refugee and Host Community (RHC) districts. At the district level, the project will work closely with the district level administration structure. The district implementation support teams will consist of designated government staff and contract staff, depending on the capacity and need of the district. The district implementation team will be led by a district government official to ensure ownership and sustainability. The project will use the district structure that includes the departments of community development, production, planning etc. These departments will be supported through project resources to allow them carry out their responsibilities under the project. The MGLSD as the main implementing agency, has no prior experience in managing the implementation of any World Bank-funded projects under the ESF. PSFU will be the apex institution for administering the grants. The PSFU has experience in project coordination and implementation of Bank supported projects including the ongoing Competitiveness and Enterprise Development Project (CEDP) and Skills Development Project under the safeguard policies, and the recently approved INVITE project which is under the ESF. The capacity of the PFIs will be assessed once they are identified, including their institutional capacity to manage E&S risks and their knowledge of the ESF or similar donor standards. Although some staff at the MGLSD has undertaken ESF training, a E&S capacity needs assessment will be conducted and a capacity building plan developed and implemented to strengthen teams’ capacity from the MGLSD, PSFU, the PITs and the local government levels so the team is well equipped to effectively and efficiently manage any project related E&S risk. This has been included in the ESMF with a budget allocated for it to develop and implement the Capacity Building Plan prior to Project effectiveness and continuously throughout Project Public Disclosure implementation. II. SUMMARY OF ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Substantial Environmental Risk Rating Substantial Overall, the project will generate positive outcomes through enhancing women’s income, productivity, and household welfare. Notwithstanding, the project will support activities under Components 2 and 3, and to a lesser extent under Components 1 and 4, that are likely to generate environmental health and safety risks and impacts. Component 2 will provide funds to women to transition from micro to small enterprises, and from small to medium enterprises, which could result in small-scale civil works. Sub-component 2b will enable the target beneficiaries to access the credit they need to expand their enterprises by providing a complementary grant that leverages Participating Financial Institutions (PFIs) to provide the credit component from their existing capital as well as relevant credit lines. To manage EHS risks and impacts associated with the use of PFIs, PFIs shall be required to put in place an Environmental and Social Management System (ESMS) and have adequate tools and capacity to address the specific needs for EHS risk management for activities financed, prior to disbursement of funds to the PFIs. Component 3 will finance demand driven enabling infrastructure and facilities. Sub-component 3a (Childcare infrastructure and facilities) will finance: (a) Childcare infrastructure: the construction, rehabilitation or upgrading of childcare facilities (b) Childcare equipment: May 05, 2022 Page 6 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) c) Digital access points (d) Childcare training and limited start-up funding to establish quality childcare centers (e) Local and community capacity building: for the local department of education and local Women’s Councils. Sub- component 3b (Household and socio-economic infrastructure and technology) will finance: (a) Energy: (i) off-grid solar systems, (ii) upgrades and rehabilitation of community-level electricity distribution systems, (b) Water: (i) rehabilitation of water supply systems, such as wells, boreholes, pumps, water tanks, etc. (ii) extension of existing water supply systems (c) Market and Transport Safety and Access Enhancements: (i) construction or upgrading of marketplaces and stalls; (ii) installation of lighting; (iii) construction of water and toilet facilities for markets; and (iv) construction of child care facilities (d) GBV One-Stop-Shop Service Facilities: construct and/or rehabilitate facilities for delivering integrated GBV services. (d) Time-saving connections and technology. small one-off grants ($300) for appliances and eligible connection costs. Sub-component 3c (Multi-purpose service and production facilities) will finance: (a)Feasibility assessments: for multi-purpose facility (b)Multi-purpose facility construction and/or upgrading: design and construction of up to 25 multi-purpose service and production facilities. (c) Multi-purpose equipment and training: equipment for the facility and relevant training. The skills enhancement and training under Components 1 and 4 may also lead to downstream activities with EHS risks. Key risks and impacts associated with the activities, that will largely occur during the construction phase, include noise, dust emission, solid waste accumulation, occupational health and safety risks (OHS), community health, and safety risks (CHS) during implementation of civil works and during operation of the project facilities, and the risks of communicable diseases including COVID-19 pandemic. The operation and maintenance of the constructed facilities and SMEs may lead to moderate environmental risks and impacts related to OHS and CHS aspects during the operation of equipment and disposal of solid waste from the facilities operations. Although the identified risks are localized in nature, of low magnitude, and temporary duration, and the low magnitude of the cumulative risks from the project activities, the overall Environmental Risk rating at this Public Disclosure stage is Substantial due to the current low capacity of the MGLSD to manage environmental risk and the wide range of possible subprojects. Social Risk Rating Substantial The project is designed to contribute to social economic empowerment and generate opportunities for women to grow their micro and small enterprises in targeted districts, including in refugee and host communities. For component 1 the selection criteria and screening of beneficiaries needs to be clear, inclusive and acceptable to the Bank and beneficiaries to otherwise exclusion of potential beneficiaries can occur including women with disability, Indigenous women, widows, single women, poorer women and all other marginalized categories of women. Regional balance should also be considered and intensive publicity of the project through accessible channels undertaken to ensure full participation of the target groups. Component 2: should consider the generally low literacy levels among women which could lead to several potential women beneficiaries being excluded and SEA/SH risks likely to be faced by women. Provision of appropriate programs and inclusive selection criteria PSFU will be the apex institution for administering the grants and will therefore need to establish the overall ESMS as such training and capacity building will be needed on the ESMS with the PFIs who will in turn need to provide support to the entrepreneurs. Component 3 will support Demand-driven Enabling Infrastructure and Facilities Development for Enterprise Growth and Transition. Due to the anticipated small scale of these works, the influx of labor into benefiting communities is not expected, thus issues such as SEA/SH and the spread of communicable diseases associated with the presence of workers will be negligible. Due to the community nature of works risk such as working without contracts, child labor, discrimination, and lack of access to GRM. Physical and economic displacement are not expected, however, a Resettlement Policy Framework has been developed to provide guidance in the event of any such displacement is to happen. A Labour Management Procedure will be developed to guide the process in line with ESS2. A Vulnerable and Marginalize Group Framework has been put in place for the VMG. Component 4, the project needs to strengthen the May 05, 2022 Page 7 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) social risk management team, by hiring a social development specialist for each PIT who will focus on social risk management of the project and in addition continue to build capacity of the MGLSD and PSFU teams on efficient and effective management of the social risk to strengthen management of social risk management. However, the MoGLSD has no experience implementing World Bank projects under the ESF and they will require capacity building efforts to equip them to manage social risks. The Ministry is currently under resourced in terms of personnel and funding to manage social risk. As such the social risk rating is substantial. 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 project will support activities under Components 2 and 3 that are likely to generate environmental health and safety as well as social risks and impacts. Component 2 will provide funds to women to transition from micro to small enterprises, and from small to medium enterprises, which could result in small-scale civil works, while Component 3 will finance demand driven enabling infrastructure and facilities including childcare facilities, common production facilities (e.g. milling, pasteurization, storage, cooling, printing, and packaging), upgraded input and craft markets and trading centers as well as water, electricity, and digital access points. While all the activities are expected to carry relatively moderate E&S impacts due to the limited scope of the works, there are inherent risks such as those related to ESHS, labor issues, GBV/SEA, social exclusion, and a security risk in some parts of the country. In the short term, Public Disclosure the project activities may be affected by the ongoing COVID-19 pandemic, which requires the project activities to apply the relevant disease preventive measures. Component 4 covers Project Management, Policy Innovation, and Evidence Generation with activities including enhancing the capacity of national, district, and community institutions to implement the project (financing of Project Support Teams (PSTs) at the key implementing agencies (MGLSD, PSFU, and MLG) as well as financing capacity building activities) and implementing a learning agenda for the project as well as generate evidence that will underpin dialogue and reforms on creating an enabling policy environment for female entrepreneurship and women’s economic empowerment (WEE). These activities are anticipated to have minimal E&S risks. As such, the project has prepared an Environmental and Social Management Framework (ESMF), which includes Labor-Management Procedures to address these risks. The major objectives of the ESMF are to: provide guidance to project stakeholders for integration of social and environmental aspects throughout the project life; enhance the positive environmental and social aspects of the project whilst avoiding, minimizing, managing and compensating for any potentially adverse aspects/impacts; clearly define the roles and responsibilities of the key actors, for the management of environmental and social issues on the project; ensure that the necessary framework for monitoring environmental and social aspects is in place and ideally based on a proactive approach; enhance capacity building, knowledge and awareness in environmental and social risk management for all project stakeholders. The ESMF provides a sub-project screening and assessment mechanism, and also (1) utilizes the WBG General Environmental, Health, and Safety Guidelines; (2) includes templates for Health, Safety and Environmental (HSE) plan, Waste Management Plan, and a Chance Find procedure; and (3) provides references to relevant disease preventive measures, since the project activities, may be affected by ongoing COVID-19 pandemic in short-term. The ESMF will be consulted upon and disclosed by project appraisal. During implementation, screening shall be carried out utilizing the screening form presented in the ESMF and basing on the findings of the screening (risk level of the proposed subproject) an Environmental and Social Impact Assessment (ESIA) or Environmental and Social May 05, 2022 Page 8 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) Management Plans (ESMPs) will be undertaken in order to adequately manage any potential risks and impacts, including risk hazard analysis and relevant mitigation. The Ministry has low capacity with low funding to manage environmental and social risks. The MGLSD has no experience implementing World Bank projects under the ESF and will require capacity building effort to equip them to support environment and social risk management. The Ministry is currently under resourced in terms of personnel and funding to manage environment and social risks. Due to this a capacity assessment shall be conducted and a capacity development plan on E&S risk management for Ministry staff, PSFU and implementing local governments will be an integral part of the project from inception in order to strengthen E&S risk management though out the project and this has been included as part of the ESCP. The capacity building plan will be implemented prior to project effectiveness and continued throughout the project implementation. Component 4 will fund the implementation of the ESMF, including training and capacity building, staff recruitment, assessment of E&S risks and impacts and preparation of ESIAs and ESMPs. In addition, the ESMF includes a screening checklist for Component 2 to screen Business Plans from potential beneficiaries for potential E&S impacts and propose mitigation measures Security assessment shall be conducted and a security management plan adopted prior to implementation of activities. ESS10 Stakeholder Engagement and Information Disclosure The project assessment and implementation procedures should promote and allow for meaningful and culturally appropriate consultation and participation of beneficiaries, identified stakeholders, refugees and that of host Public Disclosure communities at the different levels, including the right to public information and disclosure. ESS 10 recognizes the importance of open and transparent engagements between stakeholders and the need to respond to concerns and grievances raised by stakeholders through an established Grievance Redress Mechanism (GRM). A Stakeholder Engagement Framework has been developed and a plan shall be developed in addition to consultations already undertaken to date. The project has identified stakeholders with different interests on the project and has engaged with some of them from project identification stage and the engagement is ongoing details of engagements undertaken issues and concerns raised are captured in the SEF, the ESMF and it has informed the drafting of the VMGF, RPF this document and the ESCP draft, the identified project stakeholders include; i) government ministries, departments and agencies with mandates to generate opportunities for women to grow their micro and small enterprises; ii) Local Government/national authorities, iii) Private sector, iv) Research and training institutions, v) NGOs/CSOs, including community based organizations; vi) Institutions representing Vulnerable and Marginalized groups (Batwa, IK, Tepeth and Benet) vii) Financing institutions; viii) National and international NGOs, and, Micro and small-scale entrepreneurs and host communities including neighbouring communities. Given the current stage of the Project (i.e. the specific locations, stakeholder groups, and schedule of activities are not known), the community stakeholders at this levels cannot yet be identified. During engagement stakeholders raised the following key concerns: i) the need to ensure the project complement existing interventions and doesn’t duplicate efforts; ii) that the common user facilities have clear guidelines for operation; iii) that there is land available to support SME activities; iv) the need to undertake ESIAs and RAPs or due diligence in line with national laws and to minimize grievances; v)the need to include vulnerable and marginalized groups and ensure training is understandable for these groups; vi) the need to engagement men to ensure they understand the project and address concerns around GBV; vii) the importance of working with local government structures to support the project. May 05, 2022 Page 9 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) The Stakeholder Engagement Plan shall be developed prior to Project Effectiveness and implemented throughout Project implementation period. To realize effective, efficient and meaningful consultation the SEF (and eventually the Plan) once finalised should take into consideration the following principles including those based on ESS10 and International Best Practice (IBP): • Active participation of affected parties in the engagement process. • Early, meaningful and inclusive participation of all project stakeholders including vulnerable groups and the right to redress system in case of disputes. Meaningful information should be disclosed to the stakeholders to allow for active and informed engagement. • Attention to modalities of engagement to ensure its effectiveness and achieve a “social license” to operate, which depends on mutual trust, respect and transparent communication between implementing agencies, MGLSD, PSFU and its stakeholders. • Follow-up actions of the engagement process. • Inclusive engagement achieved when broad participation is encouraged and supported to ensure appropriate participation opportunities for all. • No intimidation/manipulation/coercion; deliberations should be free and fair. • Cultural appropriateness of the process. Cultural norms and values can prevent stakeholders from freely participating in the engagement process. In case of any conflicting demands within a community, it may become challenging for a project to identify stakeholders who are representative of common interests. Such tensions might be avoided by employing local community leaders who are sensitive to local power dynamics which require PSFU, MGLSD and other project proponents to develop awareness or identify structures to support and foster effective Public Disclosure stakeholder engagement. Such level of cultural sensitivity is particularly relevant to activities involving members of VMGs who will be engaged through a separate process (as part of VMGPs preparation). • Upholding integrity during the engagement process to foster mutual respect and trust. • Cultivating respect by recognizing the rights, interests, values and cultural beliefs of stakeholders and neighbouring/host communities. • Demonstrating transparency and accountability by responding to community concerns in a timely, open, and effective manner. • Emphasis on a two-way engagement tailored to the project. • Involvement of all players in the implementing entity. • Involvement of stakeholders in the project implementation and monitoring. • Channels of communication are to be open throughout the Project for addressing each grievance by persons trained and capable of receiving and communicating with vulnerable social groups in a sensitive and culturally appropriate manner. • Written records: A Grievance Record Register is maintained, in a prescribed Form attached in the SEF which includes the tracking process of resolution. 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 May 05, 2022 Page 10 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) The project will involve direct workers, contracted workers and primary supply workers. The project will adhere to Uganda's Labor Laws and the requirements of ESS2 concerning labor conditions including regulations on child labor and Occupational Health and Safety (OHS). Requirements shall be noted in the LMP, to be developed, cleared and disclosed prior to disbursement of funds. The project presents occupational health and safety risks that may arise from the construction, equipping and operating the public facilities. To ensure the health and safety of workers during the construction and operational phases of the project, the Borrower shall develop a Health, Safety, and Environmental (HSE) plan prior to disbursement of funds for component 3 as part of the project specific ESIAs and ESMPs, in line with World Bank Group General Environment, Health, and Safety (EHS) Guidelines. These plans will include procedures on investigation and reporting of incidences and non-conformances, emergency preparedness and response procedures, and continuous training and awareness to workers. Impacts associated with labor influx are expected to be minimal, furthermore contractors will be required to hire local labor as one measure to reduce on influx. ESS3 Resource Efficiency and Pollution Prevention and Management Due to the nature and relatively low scale of the activities, the risks and impacts related to resource efficiency and pollution will be minor, temporary, and confined to the area immediately surrounding the construction. These risks include the typical impacts of civil works (i.e., generation of solid waste, dust and noise generation, air emissions from vehicles, soil erosion, pollution from construction wastes, and water use) and in instances where fumigation is conducted for the disinfection of COVID-19 this could pose a risk to environment and population depending on the disinfectants being used. The implementation of mitigation measures, which are proposed in the ESMF, ESIAs and Public Disclosure ESMPs (including those proposed in WB General Environmental and Health Safety Guidelines (EHSGs)) such as dust suppression where applicable and vehicle and truck maintenance shall be applied to minimize the impact of air emissions during construction/rehabilitation, and residual impacts are expected to be limited in scope and duration. The noise generated from the use of construction machinery and truck movements is expected to be short-term. Given the nature and scale of the sub-projects, the project is not expected to be a significant user of raw materials. Nevertheless, to ensure sustainable use of the construction materials, the project should only source materials from licensed facilities (e.g. borrow sites, quarries etc.). In cases where new materials sites are to be set up, the project will be required to carry out the requisite environmental and social assessments and develop site-specific ESMPs and obtain the statutory approvals prior to use of the sites. During the operational phase, depending on the nature of support and enterprises developed, there could be the generation of wastes and chemicals. Adequate training and provision of waste management procedures have been incorporated into the project ESMF. Waste Management Plans will be developed as part of the ESIAs and ESMPs. Based on the ESMF, it was estimated that the GHG emissions from the project activities are not likely to be significant. Some of the beneficiary enterprises or their sub projects may be consuming energy or other resources such as water, as part of their processes, such as motors, pumps, and fans; compressed air systems and heating, ventilation and air conditioning systems (HVAC); and lighting systems. To achieve resource efficiency, the project will implement technically and financially feasible measures or improving efficient consumption of energy, water, and raw materials. The project will ensure that these energy and water conservation aspects are addressed as per the guidelines. ESS4 Community Health and Safety May 05, 2022 Page 11 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) During the construction phase, the communities may be exposed to construction and transport vehicles, dust emissions from construction activities and haulage of materials, construction noise and vibration, potential construction site and material handling-related accidents including road accidents risk at road crossings and through trading centres especially for children, women and elderly people, public safety risks from construction traffic, safety risks for people near construction sites arising from falling debris, uncovered trenches or exposed electrical wires at or near construction sites etc.. During the operation and maintenance of the facilities and operation of the SMEs, the communities may be exposed to transport vehicles, noise, waste generation from the facilities operations, poor sanitation resulting from breakdown of the sewer lines of the structures and erratic supply of water, spread of diseases at the common user facilities due to congestion. The risks are expected to be avoided and/or mitigated through adopting best practices in line with General EHSGs. A risk hazard analysis and mitigation plan, proportionate to the risks identified, will be developed and included in the ESMP. Adverse social impacts such as gender-based violence (GBV), sexual exploitation shall be addressed in the ESMPs and managed by a qualified Gender Specialist hired on the project. The transmission of communicable diseases such as HIV/AIDS on affected communities may also occur because of project activities. Security risk in some parts of the country, currently consisting of cattle rustling in the Eastern Part of the country, poses a risk to the project implementing community, since the rustlers do not only steal the cattle but other valuables including food stuff. To manage the security risks of the Project, including the risks of engaging security personnel to safeguard project workers, sites, assets, and activities, Security Management Plans will be prepared as part of the site-specific ESIAs and ESMPs guided by the principles of proportionality and GIIP, and by applicable law, setting out measures to manage these risks in relation to hiring, rules of conduct, training, equipping, and monitoring of such personnel. Public Disclosure The country has been hit by the COVID-19 pandemic which is affecting the entire country and spread to both urban and rural communities. This might affect project activities, which requires the project activities to apply the relevant disease preventive measures provided for by Ministry of Health and World Health Organization. The client will be required to comply with the community health and safety requirements as stipulated in WBG EHS guidelines. The potential risks and mitigation measures for impacts on beneficiaries have been analyzed in the ESMF and will be detailed in site-specific ESIAs and ESMPs. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement Significant physical and economic displacement is not anticipated under the project since the public facilities to be constructed under Component 3 will be located on local government/district land. However, some activities under Component 3 especially those associated with last mile and household level gaps may require land to be acquired or restrictions on land use. In the event that any land will be required outside of government lands a Resettlement Policy Framework (RPF) has been developed to clarify resettlement principles, organizational arrangements, and design criteria to be applied to sub-projects or project components to be prepared during project implementation. Once the sub-project or individual project components are defined and the necessary information becomes available, the framework will be expanded into a specific plan proportionate to potential risks and impacts. Project activities that will cause physical and/or economic displacement will not commence until such specific plans have been finalized and approved by the Bank. Therefore, this Resettlement Policy Framework (RPF) will guide the management of social issues associated with infrastructure investments financed under the GROW project and guide the preparation of Resettlement Action Plans, whenever there arises impact on land for the project, to ensure that the May 05, 2022 Page 12 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) resettlement aspects of the project are adequately addressed. Special attention during the development of the RAPs should be paid to the current national social-economic dynamics (Vulnerable population – women, Indigenous People, Persons with Disability (PWDs), and with ensuring compliance with the World Bank Environment and Social Standard ESS5 on Land Acquisition, Restrictions on Land Use and Involuntary Resettlement. ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources Given the nature and scope of the project activities, there is minimal impact envisaged on the biodiversity, since the proposed projects are likely to be undertaken in the urban settings where the habitats may already be altered or destroyed. The ESMF provides guidance on screening and mitigation measures to ensure that project activities do not alter or cause the destruction of any critical or sensitive natural habitats. The project will avoid impacts on environmentally sensitive areas such as wetlands, river banks, lakeshores, protected areas such as forest reserves, wildlife reserves etc., and where such avoidance is not possible, will identify and implement measures to address these impacts in accordance with the mitigation hierarchy. Investment proposals under Component 3 will be assessed against a set of eligibility criteria (including no significant adverse social or environmental impacts), which will be included in the Project Operations Manual (POM) prior to project effectiveness, and updated as necessary. The selection of subprojects will also be guided by the screening process outlined in the ESMF. The ESIAs and ESMPs will provide mitigation measures to ensure that project activities in these protected areas (e.g. fish farming, bee- keeping in forests) if any does not cause any harm or alter habitat. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities Public Disclosure Due to the project's national coverage, it might impact communities that meet the conditions of SSAHUTLC (in Uganda referred to as the Vulnerable and Marginalized ) under ESS7. Communities, which meet the conditions of SSAHUTLC under ESS7 and might be affected by project activities are the Batwa in the West, IK, Tepeth in the Karamoja Region and Benet in the Elgon Region of Uganda. As such, a Vulnerable and Marginalized Group Framework (VMGF) has been prepared to provide guidelines on how to avoid adverse impacts (such as SEA/SH, displacement among others) of the project on these communities and ensure their access to the project and potentially participation and access to other project benefits. Project activities are not anticipated to cause relocation or impact resources or cultural heritage of Batwa, Ik, Tepeth, Benet, women, Indigenous People, Persons with Disability (PWD as marginalized groups, in case of any relocation the RPF developed provides a guideline for managing the process including development of a Resettlement Action Plan (RAP), while the VMGF provides guidance on acquiring land through Free, Prior and Informed Consent (FPIC) as needed. The SEF includes provisions for consultation with the marginalized groups indicated above which is provided for under ESS10 and provision for inclusion in the GRM. ESS8 Cultural Heritage As the project will finance some limited civil works, some excavation and movement of earth can be expected. The activities to be financed by the project are small scale and very limited in scope and the potential impact on known and unknown physical and cultural resources is likely to be minimal. At this stage in project preparation, the presence of culturally significant sites associated with the project cannot be determined. The project will avoid impacts on cultural heritage and where such avoidance is not possible, will identify and implement measures to address these impacts in accordance with the mitigation hierarchy. The project will implement measures for safeguarding cultural May 05, 2022 Page 13 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) heritage in accordance with the guidelines of the ESMF and consistent with the requirements of ESS8. A chance find procedure has been included in the ESMF and will be included in subsequent ESMPs and included in the works contracts. ESS9 Financial Intermediaries Under Component 2b, the project will provide grants to female entrepreneurs through PSFU (the apex FI) via a number of PFIs that are already supporting female entrepreneurs. While PSFU has been selected as the apex FI, the identification of the PFIs is not yet known. As such, the organizational capacity of the PFIs to manage these grants in line with the Bank’s ESF is not yet known. An assessment of PSFU’s ESMS is also required to ensure that as the apex lender it is able to manage the E&S risks associated with working with multiple PFIs including supporting with any capacity building that may be required. As such, both PSFU and the identified PFIs that will receive the GROW funds will be required to develop, maintain, and implement an ESMS to identify, assess, manage, and monitor the environmental and social risks and impacts of FI subprojects. The ESMS shall include, inter alia, the following elements: • Identification of the FI subprojects that may receive support from the Project. • An environmental and social policy endorsed by the FI senior management specifying any details on the E&S policy that may be relevant. • Clearly defined procedures for the identification, assessment and management of the environmental and Public Disclosure social risks and impacts of FI subprojects, in accordance with ESS9, including, inter alia, stakeholder engagement and disclosure requirements applicable to FI subprojects. • Exclusion list with the activities FI subprojects that are not eligible for financing in line with those included in the Operations Manual , • An organizational capacity and competency for implementing the ESMS with clearly defined roles and responsibilities detailing specific details. • Monitoring and reporting of environmental and performance of FI subprojects and the effectiveness of the ESMS. • Incidents and accidents notification and subsequent reporting requirements • An external communications mechanism, including measures to respond to public enquiries and concerns in a timely manner. For PSFU these monitoring requirements will need to demonstrate how they will review the subprojects being selected by the PFIs to ensure they are following the agreed screening approaches, exclusion criteria and management of E&S risks during implementation and ensuring there is the required level of management oversight. The project will conduct a readiness assessment of the apex FI’s ESMS as a condition of effectiveness. The PFIs will in turn need to adopt and operationalize an ESMS before carrying out screening of any proposed and prior to disbursement of Funds for FI subprojects. Once established, both PSFU and the PFIs will need to maintain and implement the ESMS throughout Project implementation and monitor compliance with the same. May 05, 2022 Page 14 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No OP 7.60 Projects in Disputed Areas No 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 World Bank Public Disclosure Contact: Margarita Puerto Gomez Title: Senior Social Development Specialist Telephone No: 5393+2258 / 256-414-302258 Email: mpuertogomez@worldbank.org Contact: Fatima Naqvi Title: Senior Social Protection Specialist Telephone No: 5393+2212 / 251-011-53932212 Email: fnaqvi@worldbank.org Contact: Samuel Thomas Clark Title: Senior Social Development Specialist Telephone No: 5327+3505 / 62-21-5299-3505 Email: sclark@worldbank.org Borrower/Client/Recipient Borrower: Ministry of Finance, Planning and Economic Development Implementing Agency(ies) Implementing Agency: Ministry of Gender, Labor and Social Development Implementing Agency: Private Sector Foundation Uganda V. FOR MORE INFORMATION CONTACT May 05, 2022 Page 15 of 16 The World Bank Generating Growth Opportunities and Productivity for Women Enterprises (GROW) (P176747) 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 Leader(s): Fatima Naqvi, Margarita Puerto Gomez, Samuel Thomas Clark Practice Manager (ENR/Social) Helene Monika Carlsson Rex Cleared on 05-May-2022 at 05:38:4 GMT-04:00 Public Disclosure May 05, 2022 Page 16 of 16