The World Bank SADC Regional Statistics Project (P175731) Concept Environmental and Social Review Summary Concept Stage (ESRS Concept Stage) Public Disclosure Date Prepared/Updated: 12/01/2022 | Report No: ESRSC03125 Dec 01, 2022 Page 1 of 12 The World Bank SADC Regional Statistics Project (P175731) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Southern Africa EASTERN AND SOUTHERN P175731 AFRICA Project Name SADC Regional Statistics Project Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Poverty and Equity Investment Project 2/2/2023 7/28/2023 Financing Borrower(s) Implementing Agency(ies) Republic of Mozambique, Southern African Republic of Madagascar, Development Community Republic of Malawi, African Union, Southern African Development Public Disclosure Community, Democratic Republic of São Tomé and Príncipe Proposed Development Objective The project seeks to strengthen regional harmonization, dissemination, and use of core economic and social statistics for beneficiary countries, aligned with the Strategy for Harmonization of Statistics in Africa 2017-2026 (SHaSA2). Financing (in USD Million) Amount Total Project Cost 185.00 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] Dec 01, 2022 Page 2 of 12 The World Bank SADC Regional Statistics Project (P175731) The proposed SADC Regional Statistics Project will promote harmonization of regional statistics, the production of high-quality statistics, and timely dissemination to enhance their use. With the help of the project and coordination of the regional body of SADC, quality and harmonized D4P statistics will be produced and disseminated. The timely release of better disseminated statistics will lead to enhanced use of statistics, which – in turn – encourages more production of statistics creating a positive feedback loop enhancing the sustainability of the project objective. Specialized training and capacity-building activities on national monitoring and evaluation systems, involving NSOs and to specialized agencies from the Governments of participants countries, will be implemented to promote evidence-based policy. At country level, a wide range of activities will close statistical capacity gaps based on specific requirements at country level. The proposed regional project will cover three SADC IDA countries: Madagascar, Malawi, and Mozambique but is expected to be expanded because more countries have expressed interest in joining. A non-SADC state, Sao Tome and Principe, has expressed interest to be part of the project as well. The project has three components: Component 1: Improve harmonization, quality, and dissemination of core social and economic statistics is a regional level component which seeks to address the challenge of limited capacity to monitor economic progress and inform regional policy decisions. It aims to support the implementation of continental and regional agreements on statistics – specifically the SHaSA2 initiative by the African Union as well as SADC’s RSDS 2020-2030. It will also produce a harmonized toolkit and thus improve harmonization and quality of statistics; improve human resource capacity; and improve access, dissemination, and use of data and statistics to support evidence-based policy and decision making. This component, therefore, underscores statistics as a public good for Public Disclosure regional integration. Component 2: Close data production, infrastructure, and statistical capacity gaps at country level is a country level component to address capacity constraints that are not necessarily common to all countries but that will enable NSOs to leverage regional activities, for instance, filling infrastructure and software needs. In the main, the country level component seeks to extend the D4P package in beneficiary countries under the harmonizing guidelines, recognizing initial institutional and human resource capacities and the amount of already existing core statistics. The activities within this component, will therefore, aim to close data production, infrastructure, and statistical capacity gaps at country level. Component 3: Project Management will oversee, supervise and monitoring the first two components. The World Bank’s support is planned for five years. The estimated cost is US$194 million, to be provided through a combination of International Development Association (IDA) credits and grants from country-specific and regional windows. 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 proposed SADC Regional Statistics Project will promote harmonization of regional statistics, the production of high-quality statistics, and timely dissemination to enhance their use. With the help of the project and coordination of the regional body of SADC, quality and harmonized D4P statistics will be produced and disseminated. The timely release of better disseminated statistics will lead to enhanced use of statistics, which – in turn – encourages more production of statistics creating a positive feedback loop enhancing the sustainability of the project objective. Dec 01, 2022 Page 3 of 12 The World Bank SADC Regional Statistics Project (P175731) Specialized training and capacity-building activities on national monitoring and evaluation systems, involving NSOs and to specialized agencies from the Governments of participants countries, will be implemented to promote evidence-based policy. At country level, a wide range of activities will close statistical capacity gaps based on specific requirements at country level. The proposed regional project will cover three SADC IDA countries and one non-SADC state these are Madagascar, Malawi, and Mozambique and Sao Tome and Principe but is expected to be expanded because more countries have expressed interest in joining. The project has three components: Component 1: Improve harmonization, quality, and dissemination of core social and economic statistics is a regional level component which seeks to address the challenge of limited capacity to monitor economic progress and inform regional policy decisions. It aims to support the implementation of continental and regional agreements on statistics – specifically the SHaSA2 initiative by the African Union as well as SADC’s RSDS 2020-2030. It will also produce a harmonized toolkit and thus improve harmonization and quality of statistics; improve human resource capacity; and improve access, dissemination, and use of data and statistics to support evidence-based policy and decision making. This component, therefore, underscores statistics as a public good for regional integration. Component 2: Close data production, infrastructure, and statistical capacity gaps at country level is a country level component to address capacity constraints that are not necessarily common to all countries but that will enable NSOs to leverage regional activities, for instance, filling infrastructure and software needs. In the main, the country level Public Disclosure component seeks to extend the D4P package in beneficiary countries under the harmonizing guidelines, recognizing initial institutional and human resource capacities and the amount of already existing core statistics. The activities within this component, will therefore, aim to close data production, infrastructure, and statistical capacity gaps at country level. Component 3: Project Management will oversee, supervise and monitoring the first two components. The World Bank’s support is planned for five years. The estimated cost is US$185 million, to be provided through a combination of International Development Association (IDA) credits and grants from country-specific and regional windows. D. 2. Borrower’s Institutional Capacity The Project is a regional integration project which intends to strengthen the regional statistical system of SADC member countries through supporting the harmonization, production, dissemination, and use of quality controlled social and economic statistics for evidence-based policy making. The project exactly intervention locations are not known at this stage and will be determined during project implementation. However, the project will have a national scope in the participating countries (Mozambique, Madagascar, Malawi and São Tomé and Príncipe) targeting both rural and urban settings through the agricultural, enterprise and household surveys. The project will also take place in ministries, particularly the national statistical offices (NSOs) which will be strengthened including the AU and SADC Secretariat in Ethiopia and Botswana, respectively. Given the development challenges faced by Sub-Saharan Africa (SSA), data remains a strategic asset that can inform and improve the formulation and implementation of policy, responsiveness of government and provision of public services. While significant progress in reducing poverty has been made in recent decades, substantial challenges Dec 01, 2022 Page 4 of 12 The World Bank SADC Regional Statistics Project (P175731) remain. SSA is the region with not only the highest poverty rate but also has the highest number of people living in poverty as economic growth has failed to keep up with the rising population. Non-monetary indicators of wellbeing estimations reveal a similar story of slow progress in reducing different forms of deprivation and poverty. They also point to inequality in access to basic infrastructure and services. These regional trends are also seen in the countries that this project targets, the Southern African Development Community (SADC) – a Regional Economic Community (EC) comprising 16 member states: Angola, Botswana, Comoros, Democratic Republic of Congo, Eswatini, Madagascar, Malawi, Mauritius, Mozambique, Namibia, Seychelles, South Africa, Tanzania, Zambia and Zimbabwe. Sao Tome and Principe, as an IDA country, a Portuguese-speaking country, such as Mozambique and Angola in SADC, and with a similar statistical development status to that of SADC countries included in the project, will be also part of the regional project. In fact, SSA broadly and SADC specifically remains one of the most unequal regions in the world. The COVID-19 pandemic has exacerbated poverty and inequality. Overall, these challenges suggest there is an important role that data can play to better advance the region’s development objectives. The regional project will use a modular approach (not having all the same components in every country) to introduce the D4P package, but the speed and process will be different for each country, recognizing initial institutional and human resource capacities and the amount of already existing core statistics. Sequencing needs will be considered when determining the project's timeline, and the project’s introduction will be phased such that the workload for institutions is distributed over time. Some countries are more advanced than others in terms of data availability. Some NSOs are also well staffed, whereas others lack qualified staff and therefore do not have the capacity to conduct multiple surveys in the same year. Different donor partners are present in the selected SADC countries. All these factors are considered in the design of the project. The proposed regional project will start with four SADC IDA countries: Madagascar, Malawi, and Mozambique but is expected to be expanded because more countries have expressed interest in joining. A non-SADC Public Disclosure state, Sao Tome and Principe will also participate in the project. The main reasons for starting with a limited number of countries are; (i) the start-up costs of covering all countries would be large and implementation challenging, (ii) some of SADC countries have ongoing statistical projects, and these could be included into this project. II. SCREENING OF POTENTIAL ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Moderate Environmental Risk Rating Moderate The environmental risk rating is considered 'Moderate' due to the some potential adverse risks and impacts on the physical environment that are likely to be non significant, temporary, site-specific, reversible and easily mitigated. The project will not support major civil works or new constructions although there maybe some minor civil works during renovation of offices. Under Component 1, the improvement of harmonization, quality, and dissemination of statistics will involve human resource development through workers capacity building workshops and trainings that could lead to transmission of communicable diseases such as COVID-19. COVID-19 risk is expected to be minor since public institutions have been enforcing national protocols for prevention of the disease at workplace. This measure will be reinforced trough the use of World Bank guidelines such as “Technical Note: Public Consultations and Stakeholder Engagement in WB-supported operations when there are constraints on conducting public meetings” and its appropriate measures inclusion in the Project Implementation Manual. Under Component 2, minimal environmental Dec 01, 2022 Page 5 of 12 The World Bank SADC Regional Statistics Project (P175731) risks are foreseen related to the ICT and statistical infrastructures, such as the replacement or purchase of new ICT are not expected to exceed the minimal threshold for management of e-Waste management issues. However, a simple Code of Practices for e-Waste will be prepared. Civil works under this component are anticipated to be of minor and simple physical renovation therefore the risks and impacts (small quantities or level of dust, noise, vibration, waste, etc.) likely to arise are negligible, site specific, reversible and the Borrower can easily manage them. As such simply best practices procedures and national environmental legislation provisions will be included on the Project Operations Manual (POM) to assist the Borrower to address potential minor risks and impacts. The agricultural, enterprise and household surveys will involve contact with the public associated risks of COVID-19 transmission as such a COVID-19 Contingency Plan will be prepared. Under Component 3, Project Management and Monitoring and Evaluation, mainly technical assistance will be provided at (i) regional level with PIUs established at AU and SADC secretariats and at (ii) country level where NSOs will be the main implementing agencies of the project in each country. At regional level an E&S specialist will be recruited whereas at national level E&S focal points will be recruited to support managing the project environmental and social impacts and risks. Component 1, 2 and 3 all include Technical Assistance activities such as trainings and workshops classified as Type-3 (capacity building) that have diffuse and induced impacts, often playing out over a longer term, however the Type-2 activities (policies, plans & strategies) including updating National Strategies for the Development of Statistics (NSDS), development of statistical regulations and review and amendment of laws have potential significant downstream E&S impacts, as such the Terms of Reference will be reviewed and approved by WB to ensure that it considers adequate assessment of environmental and social implications and that the advice provided through the TA for addressing those implications is consistent with the ESF. Social Risk Rating Moderate Public Disclosure The Social Risk Rating is considered to be moderate. Project activities are expected to strengthen the regional statistical system of participating countries through supporting the harmonization, production, dissemination, and use of quality controlled social and economic statistics for evidence-based policy making. However, achieving such outcomes may imply social risks and impacts. Key adverse social risks and impacts that have been identified at this stage of project preparation relate to ensuring that (i) any statistical guidelines and frameworks established under the project include considerations of digital data protection and digital security; (ii) there is appropriate stakeholder engagement at the regional and national level with all stakeholders, including civil society and marginalized groups, in a manner that is understandable and transparent and explains the benefits and impacts of the activities; (iii) labor conditions, especially with regards to HR restructuring activities, salary re-adjustments and skills needs assessments, as well as occupational health and safety (minor cuts and injuries, road safety, etc. during work); (iv) ensuring that inclusion and data protection covers vulnerable and marginalized groups; and (v) possible risks of sexual exploitation and abuse and sexual harassment (SEA/SH) at the work place and during the roll out of surveys/censuses. Capacity of the PIU and respective implementing agencies to manage social risk is expected to be limited, however, as the nature of the proposed social risks are relatively low these risks and impacts should be manageable through known mitigation measures. 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: Dec 01, 2022 Page 6 of 12 The World Bank SADC Regional Statistics Project (P175731) Project activities are expected to strengthen the regional statistical system of participating countries through supporting the harmonization, production, dissemination, and use of quality controlled social and economic statistics for evidence-based policy making. However, achieving the above outcomes may imply environmental and social risks. Key adverse environmental and social risks and impacts relate to ensuring that (i) minor civil works and installation of ICT equipment are managed adequately considering mitigation hierarchy, particularly in relation to construction waste generation and occupational health and safety issues; (ii) the replacement, transportation and disposal of old ITC equipment (e-waste) as well new acquired are undertaken properly; (iii) TA activities including face-to-face trainings, workshops and statistical survey follows prevention measure against COVID-19; (iv) the Terms of Reference for TA type-2 activities (review or development of new policies, plans & strategies) have been reviewed and approved by WB to ensure consistency with the ESF; (v) any statistical guidelines and frameworks established under the project include considerations of digital data protection and digital security; (vi) there is appropriate stakeholder engagement at the regional and national level with all stakeholders, including civil society and marginalized groups, in a manner that is understandable and transparent and explains the benefits and impacts of the activities; (vii) labor conditions, especially with regards to HR restructuring activities, salary re-adjustments and skills needs assessments, as well as occupational health and safety (minor cuts and injuries, road safety, etc. during work); (viii) ensuring that inclusion and data protection covers vulnerable and marginalized groups; and (iv) possible risks of sexual exploitation and abuse and sexual harassment (SEA/SH) at the work place and during the roll out of surveys/censuses. Capacity of the PIU and respective implementing agencies to manage environmental and social risk is expected to be limited, however, as the nature of the proposed environmental and social risks are relatively low to moderate these Public Disclosure risks and impacts should be manageable through known mitigation measures. The project will be required to prepare a Code of Practices for e-Waste Management , COVID-19 Contingency Plan, Environmental and Social Commitment Plan, Stakeholder Engagement Plan and Labor Management Procedures. Areas where “Use of Borrower Framework” is being considered: The use of Borrower Framework is not currently being considered. ESS10 Stakeholder Engagement and Information Disclosure The project will require inputs from different stakeholder groups. Preliminary groups that have been identified are likely to include government departments and ministries and national statistics offices of member states who will be the main beneficiaries of the TA and capacity building activities. In addition, academics (universities who may work on issues related to statistics and use of data); development partners; NGOs and CSOs at both the national and regional level addressing issues related to data protection, use of statistics etc. as well as organizations representing the rights of vulnerable and marginalized groups have all been identified. The Project PIU within SADC will be required to develop a framework Stakeholder Engagement Plan (f-SEP) for the Regional Project that will set out the approach to stakeholder engagement that is envisioned across the participating countries. The f-SEP will guide the development of country specific SEPs, as soon as the specific locations, stakeholder groups, and schedule of activities are known. The scope and level of detail of the framework SEP shall be commensurate with the nature and scale, potential risks, and impacts of the project and the level of concern in the project area. Dec 01, 2022 Page 7 of 12 The World Bank SADC Regional Statistics Project (P175731) Considering Covid-19 restrictions, the SEP will identify ways to ensure consultations are fit for purpose, effective and meaningful in order to meet Program and stakeholder needs in line with national regulations as well as WHO guidelines. COVID-19 measures shall include smaller meetings, to be conducted as appropriate taking full precautions with all stakeholders, one-on-one interviews through phones and online meetings platforms with stakeholders. The approaches taken will thereby ensure that information is meaningful, timely, and accessible to all affected stakeholders. The f-SEP will outline the Grievance Mechanism (GM) at the regional level, subsequently country level GMs will be developed as part of the country specific SEPs as actions in the ESCP prior to commencement of any country level activities and shall be aligned with the regional GM. The GMs shall provide multiple avenues of access, a fair, transparent, and rapid decision-making process, as well as monitoring and reporting processes by the PIUs. 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 The standard is currently considered relevant for the project. The Project will require the use of Direct Project Workers and Contracted Workers to undertake the TA to develop institutions and frameworks for the development and harmonization of data. This is likely to involve desk-based research, workshops and meeting with stakeholders from participating countries. The program may engage consulting firms to support technical capacity building Public Disclosure activities. The SADC statistics department will prepare Labor Management Procedures (LMP) proportionate to the activities, risks and impacts which provide detailed information on the work terms and conditions before commencement of activities. The Project is not expected to finance any physical infrastructure with civil works, however, there may be installation of IT equipment and renovation of offices. As such, very minor waste management issues and occupational health and safety (OHS) risks are anticipated as such simply best practices procedures and national environmental legislation provisions will be included on the POM. Although labor risks are expected to be minimal, including OHS, child labor and labor influx risks, the procedures will include codes of conduct acceptable to the Bank to mitigate the risk of Sexual Exploitation and Abuse / Sexual Harassment or misconduct. The LMP will also ensure that national labor-related laws are upheld, such as public service act, labor law, and public service human resource policy and institutional roles related to enforcement of the laws, and recruitment, discipline, appraisals and dismissals. A grievance mechanism (GM) for work-related grievances will be provided to project workers including consultants, with necessary considerations for confidentiality and whistle-blower protection. This may build on existing GMs that are already in place. To mitigate risks of COVID-19 transmission during TA activities a Contingency Plan shall be prepared, consulted upon and disclosed prior to appraisal. The Terms of Reference for TA type-2 activities (review or development of new policies, plans & strategies) will be reviewed and approved by WB during project implementation to ensure consistency with the ESS2. ESS3 Resource Efficiency and Pollution Prevention and Management This standard is currently considered relevant to the project activities. The proposed project activities may generate some adverse impacts related to disposal and management of waste during the renovation works and pose some Dec 01, 2022 Page 8 of 12 The World Bank SADC Regional Statistics Project (P175731) non-significant public health concerns due to nuisance related to dust, vibration and noise emissions. The POM will also include risk management procedures to manage with construction debris and hazardous or non-hazardous materials that may need to be disposed of. Additionally, the installation of ITC infrastructure may pose environmental risks related to safe final disposal of hazardous and electric and electronic equipment waste. The purchase of new ICT is not expected to exceed de minimum threshold for management of e-Waste management issues. However, a simple Code of Practices for e-Waste will be prepared. All equipment and infrastructure deployed and procured will follow resource efficiency standards. It is not expected that the project generates large amounts of GHG emission, however some emissions are expected from fuel engines of project vehicles and back-up generators. The Terms of Reference for TA type-2 activities (review or development of new policies, plans & strategies) will be reviewed and approved by WB during project implementation to ensure consistency with the ESS3. ESS4 Community Health and Safety The standard is currently considered relevant. The project will involve procurement and installation of IT infrastructure and minor office rehabilitation, however, these infrastructures are limited to survey equipment and only limited site-specific installations would be required. Risks to community health and safety have been identified as potential electronic waste management and low risks of SEA/SH to communities and project workers given the nature of activities, mainly involving technical assistance and capacity building and where project workers are not expected to be interacting with communities. Nevertheless, the LMP will include measures such as codes of conduct and awareness raising to further reduce the risk. The project is not expected to induce labor influx. The Terms of Reference for TA type-2 activities (review or development of new policies, plans & strategies) will be reviewed and Public Disclosure approved by WB during project implementation to ensure consistency with the ESS4. ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement This standard is not currently relevant. Land acquisition, restrictions on land use and involuntary resettlement are not anticipated for the project. ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources This standard is not currently relevant. No specific activities which could affect biodiversity are anticipated for the project. ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities This standard is currently not considered relevant as groups that meet the aspirations of Indigenous Peoples/Sub- Saharan African Historically Underserved Traditional Local Communities (IPs/SSAHUTLC) as defined by ESS7 are not present in the selected countries ( Madagascar, Malawi, Mozambique and Sao Tome ). IPs/SSAHUTLC are present in several SADC member states that may participate in the project downstream project implementation, however, the nature of project activities are not expected that have differential impacts on IP/SSAHUTLC. As a precautionary measure, the framework Stakeholder Engagement Plan (SEP) will need to outline the approach to engagement with IP/SSAHUTLC - shall this become relevant - or given the nature of the program, groups (such as NGOs, CSOs) Dec 01, 2022 Page 9 of 12 The World Bank SADC Regional Statistics Project (P175731) representing their interests to determine if they have any specific concerns related to data collection and security which need to be addressed in the project design. ESS8 Cultural Heritage This standard is not currently considered to be relevant as no major civil works are envisaged and there is no proposed use of intangible cultural heritage as part of the project. The relevance of this ESS will further be assessed during project preparation. ESS9 Financial Intermediaries This standard is not relevant to this project as financial intermediaries will not be involved. C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No OP 7.60 Projects in Disputed Areas No Public Disclosure III. WORLD BANK ENVIRONMENTAL AND SOCIAL DUE DILIGENCE A. Is a common approach being considered? No Financing Partners There are no other known financing partners. B. Proposed Measures, Actions and Timing (Borrower’s commitments) Actions to be completed prior to Bank Board Approval: The SADC will need to: 1. Prepare, consult upon and disclose a Code of Practice for E-waste management , before appraisal, specifically for dealing with procurement and disposal of obsolete electric and electronic equipment and waste; 2. Prepare, consult upon, and disclose COVID-19 Contingency Plan. 3. Develop a framework Stakeholder Engagement Plan (SEP) and implement as early as possible and disclose it before appraisal; 4. Prepare an Environmental and Social Commitment Plan (ESCP) acceptable to the Bank. Possible issues to be addressed in the Borrower Environmental and Social Commitment Plan (ESCP): 1. Compliance with the Code of Practice for E-waste management and COVID-19 Contingency Plan throughout project implementation; 2. Develop country specific SEPs and GMs 3. Continued stakeholder engagement throughout project implementation and beyond project closure; Dec 01, 2022 Page 10 of 12 The World Bank SADC Regional Statistics Project (P175731) 4. Establish and ensure the functionality of the GM throughout the implementation period; 5. Ensure competent environment and social representation at the PIU to ensure proper implementation, monitoring, and reporting of ESF related issues including enforcement of the E-Waste Management Plan, SEP and ESCP; 6. Prepare, consult upon and disclose Labor Management Procedures C. Timing Tentative target date for preparing the Appraisal Stage ESRS 19-Jan-2023 IV. CONTACT POINTS World Bank Contact: Ana Maria Oviedo Silva Title: Senior Economist Telephone No: 5258+87812 / 43-1-8905887812 Email: aoviedo@worldbank.org Contact: Javier Eduardo Baez Ramirez Title: Lead Economist Telephone No: 5369+3108 / 27-12-742 Email: jbaez@worldbank.org Borrower/Client/Recipient Public Disclosure Borrower: Republic of Mozambique Borrower: Republic of Madagascar Borrower: Republic of Malawi Borrower: African Union Borrower: Southern African Development Community Borrower: Democratic Republic of São Tomé and Príncipe Implementing Agency(ies) Implementing Agency: Southern African Development Community V. FOR MORE INFORMATION CONTACT Dec 01, 2022 Page 11 of 12 The World Bank SADC Regional Statistics Project (P175731) 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): Ana Maria Oviedo Silva, Javier Eduardo Baez Ramirez Practice Manager (ENR/Social) Africa Eshogba Olojoba Recommended on 23-Nov-2022 at 04:00:31 GMT-05:00 Safeguards Advisor ESSA Peter Leonard (SAESSA) Cleared on 01-Dec-2022 at 17:55:20 GMT-05:00 Public Disclosure Dec 01, 2022 Page 12 of 12