TONGA GRM GUIDANCE May 2020 7 Kingdom of Tonga MINISTRY OF EDUCATION & TRAINING TONGA SAFE AND RESILIENT SCHOOLS PROJECT (P174434) and Additional Financing STAKEHOLDER ENGAGEMENT PLAN TONGA GRM GUIDANCE May 2020 April 2022 Document history Revision history Version # Date Description Name 1 01/06/21 First Draft Prepared by Greg Andrews CSU Safeguards Revision incorporating 1 01/06/21 Greg Andrews MET comments Revision incorporating 2 31/08/21 Greg Andrews CSU Safeguards WB comments 15/09/21 Revision further 3 incorporating WB Greg Andrews CSU Safeguards comments 12/04/22 Revision incorporating Michelle Dooley, WB safeguards 4 Additional Finance Final Final (pdf) TSRSP SEP September 2021 Abbreviations and Acronyms AF Additional Financing CESMP Contractor Environmental and Social Management Plan COC Code of Conduct CRPD Convention on the Rights of Persons with Disabilities CSU Central Services Unit (MOF unit supporting WB Project implementation) EHS Environmental Health and Safety EMIS Education Management Information System ESF Environmental and Social Framework ESMP Environmental and Social Management Plan E&S Environmental and Social ESS Environmental and Social Standard GBV Gender Based Violence GOT Government of Tonga GRM Grievance Redress Mechanism IA Implementing Agency IDA International Development Association MET Ministry of Education and Training Ministry of Meteorology, Energy, Information, Disaster Management, MEIDECC Environment, Climate Change and Communications MCCTIL Ministry of Commerce, Consumer, Innovation, Trade, and Labour MIA Ministry of Internal Affairs MLNR Ministry of Lands and Natural Resources MOF Ministry of Finance MOI Ministry of Infrastructure OHS Occupation Health and Safety PAP Project Affected People PMU Project Management Unit PREP Pacific Resilience Program PSC Project Steering Committee PTA Parents and Teachers Association SEP Stakeholder Engagement Plan SET Skills and Employment for Tongans (WB project) TOR Terms of Reference TSRSP Tonga Safe and Resilient Schools Project (the Project) WB World Bank ii TSRSP SEP September 2021 Contents Document history ............................................................................................................... ii Abbreviations and Acronyms ............................................................................................ ii 1 INTRODUCTION ........................................................................................................... 1 2 OBJECTIVES OF THE SEP .......................................................................................... 2 3 TONGAN REGULATIONS ............................................................................................ 3 4 PREVIOUS ENGAGEMENT ACTIVITIES...................................................................... 3 5 STAKEHOLDER IDENTIFICATION .............................................................................. 4 Project Affected People ...................................................................................... 5 Other Interested Stakeholders ............................................................................ 6 Vulnerable Stakeholders ..................................................................................... 6 6 SEP Programme ........................................................................................................... 7 7 SEP IMPLEMENTATION ............................................................................................. 15 8 ROLES AND RESPONSIBILITIES .............................................................................. 16 9 GRIEVANCE REDRESS MECHANSIM ....................................................................... 18 10 MONITORING, EVALUATION AND REPORTING................................................... 22 APPENDIX 1 PROPOSED WORDING FOR THE WEBSITES ........................................... 24 APPENDIX 2 COMMUNICATION PLAN ............................................................................ 25 APPENDIX 3 COMPLAINT FORM ..................................................................................... 27 APPENDIX 4 GRM REGISTER .......................................................................................... 30 APPENDIX 5 GRM STANDARD RESPONSE LETTER ..................................................... 31 APPENDIX 6 GRM PLAN OF ACTION (POA) ................................................................... 33 APPENDIX 7. WORLD BANK GRIEVANCE REDRESS SERVICE .................................... 34 iii TSRSP SEP September 2021 1 INTRODUCTION The Government of Tonga (GOT) has requested funding for the Tonga Safe and Resilient Schools Project (TSRSP) under the WORLD Bank (WB) International Development Association 19 (IDA19) grant. The implementing agency (IA) will be the Ministry of Education and Training (MET) and funding will cover implementation of technical components, and project management. The ‘Project’ describes the Parent Project (which was approved in late 2021) plus Additional Financing(AF) which will both be supported by this document and will include the following four components, with funding to be refined during project preparation: 1. Improving Multi-hazard Resilience of Education 1.1. Resilient Infrastructure Investments 1.2. Strengthening Education Infrastructure Planning and Maintenance 2. Establishment of Education Management Information System (EMIS) and improved quality of teaching 2.1. Establish a comprehensive EMIS to inform policy decision making 2.2. Upgrading the quality of the teaching profession 3. Contingent Emergency Response Component (CERC) - Unallocated project funds may be requested for re-allocation to support response and reconstruction in case of a major crisis or emergency. 4. Project Management Activities which will be financed by the TSRSP include (but are not limited to): • Project Management Unit (PMU) positions • Local technical consultants and firms to provide design or technical assistance for the project • International technical consultants and firms to provide design or technical assistance for the project • Civil works contractors to implement construction works under contract. Activities to be undertaken under the Project are required to comply with the WB Environmental and Social Framework (ESF)1 and the Project has been rated by the WB as having moderate environmental and social risks2 given risks and impacts are not likely to be significant, large or complex and are expected to be predictable, temporary and reversible. Risks are expected to be easily mitigated in a predictable manner and the project is expected to be largely positive. The Environmental and Social Standards (ESSs) within the ESF that are considered relevant to the Project are: • ESS1 Assessment and Management of Environmental and Social Risks and Impacts 1 2016. World Bank Environmental and Social Framework. World Bank, Washington, DC. https://pubdocs.worldbank.org/en/837721522762050108/Environmental-and-Social-Framework.pdf 2 Concept Environmental and Social Review Summary, Concept Stage (ESRS Concept Stage), Date Prepared/Updated: 02/26/2021 | Report No: ESRSC01848 1 TSRSP SEP September 2021 • ESS2 Labour and Working Conditions • ESS3 Resource Efficiency and Pollution Prevention and Management • ESS4 Community Health and Safety • ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement • ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources • ESS8 Cultural Heritage (chance finds) • ESS10 Stakeholder Engagement and Information Disclosure. This document provides the SEP, to facilitate planning and implementation of ESS10 for the TSRSP (including the AF). 2 OBJECTIVES OF THE SEP The WB ESF ESS10 recognizes the importance of open and transparent engagement between the TSRSP and stakeholders as an essential element of good international practice. Effective stakeholder engagement can improve the environmental and social sustainability, enhance project acceptance, and make a significant contribution to successful project design and implementation. ESS10 objectives are: • To establish a systematic approach to stakeholder engagement that will identify stakeholders and build and maintain a constructive relationship with them, in particular project-affected people (PAP). • To assess the level of stakeholder interest and support for the project and to enable stakeholders’ views to be taken into account in project design and environmental and social performance. • To promote and provide means for effective and inclusive engagement with PAP throughout the project life cycle on issues that could potentially affect them. • To ensure that appropriate project information on environmental and social risks and impacts is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner and format. • To provide PAP with accessible and inclusive means to raise issues and grievances, and allow the TSRSP to respond to and manage such grievances. The project continues a number of activities which were undertaken as part of the Pacific Resilience Program (PREP) which undertook widespread consultation and was well supported. TSRSP benefits from the high awareness and positive support of PREP, with an expectation that is will also produce positive community benefit expected to improve education, access and infrastructure sustainability. There is a risk the project will fail to provide adequate information and involve the local community, staff and families in construction planning and programming. A staged construction program which would result in a continuous education service will reduce the risk of service interruptions, address contractor occupation of the site (works, administration, facilities etc) and student safety. This risk is minimal and unlikely, if the Project incorporates lessons learnt from the school’s construction activities undertaken by the PREP and ensures the school community and administration is involved in project planning. During preparation, the MET will revise the SEP to identify/confirm existing 2 TSRSP SEP September 2021 stakeholders, describe the process for sharing information on project activities, and seeking/incorporating feedback on project design and implementation. 3 TONGAN REGULATIONS This SEP takes into account the existing institutional and regulatory framework within the context of the following Tongan legal instruments: • Environment Impact Act • Land Act • Local Government Act. 4 PREVIOUS ENGAGEMENT ACTIVITIES Component 1.1 is fundamentally a continuation of the PREP school’s construction with current consultation activities building upon the broad public consultation that was previously undertaken to build project awareness and ownership of the project. This broad public consultation was undertaken during the development of the PREP ESIA/ESMP (CARDNO, 2019) then continued throughout project implementation by the PMU, contractors and TA. Current consultation leverages the relevant engagement for PREP on the repair and reconstruction of 43 buildings (33 reconstructed), and 21 toilet blocks. Additional consultation was also undertaken during the implementation phase with the development of the CESMP. The same approach will be used for the TSRSP. With the disclosure of this document for public comment, consultation with key stakeholders for the design phase and then school and community engagement for the construction phase. TSRSP targeted consultation has been undertaken by MoET focussing on the School Reconstruction component, actively engaging with school communities, Parents and Teachers Associations (PTAs) and key technical stakeholders. Broad engagement will be undertaken as part of the school selection and detailed design process and will include PAPs, vulnerable stakeholders and current school staff and families. Key stakeholders include the Ministry of Infrastructure, contractors, design consultants, school communities, P&T and special interest groups (these groups were utilised on PREP as community reference groups, with a similar model planned for TSRSP) seeking feedback on construction plans & methodology, impact mitigation and WASH design. Methods of engagement have included face to face site meetings, group consultations, technical working groups and surveys. PREP has provided key lessons learnt which will contribute to The Project’s development with the PMU M&E officer engaging all schools under the reconstruction component (package 1-7) and WASH facilities (Package8) to seek feedback and to determine levels of stakeholder satisfaction. In regards to TSRSP, technical working groups, sessions have been undertaken which have involved international consultants, Government staff, School P&T, PMU and WB representatives, As the project progresses, the PMU, DSC and the contractors will continue to consult during design and development of the CESMP to communicate and elicit feedback to manage the impacts and risks associated with each of the specific construction sites. Section 8.2 details a broad programme for consultation and engagement. 3 TSRSP SEP September 2021 All project documents, including this SEP, have been disclosed on the MET, Ministry of Finance (MOF), Central Services Unit (CSU) websites and the WB website. 5 Meaningful consultations with different categories of stakeholders, and disclosure of relevant information to the different stakeholders in a timely manner, is an essential part of risk management and stakeholder ownership of the Project. 6 STAKEHOLDER IDENTIFICATION In order to develop an effective SEP, it is necessary to determine who the stakeholders are and understand their needs, expectations, priorities and objectives in relation to the Project. This information will be used to tailor engagement to each key stakeholder. Engagement will be directly proportional to the risks and impacts of each Project activity. As the extent of the risks and impacts of a Project activity on a stakeholder increases, the level and type of engagement needs to be assessed and adjusted. With the social risks associated with the Project identified as moderate and many of the risks associated with Component 1 (infrastructure), which is a continuation of the PREP under Ministry of Meteorology, Energy, Information, Disaster Management, Environment, Climate Change and Communications (MEIDECC), the project consultation will build upon existing knowledge and support, and focus on targeted consultation, with project messages building upon existing information and understanding of previous works. Engagement will be targeted with the key stakeholders identified in Table1, as the Project advances this list needs to be adjusted as new stakeholders are identified through assessment processes such as Environmental and Social Management Plan (ESMP). Table 1 Key stakeholders Stakeholder Type of Engagement To be kept updated by the PMU on project progress and issues, and to be World Bank consulted on appropriate approaches with regards financial management, E&S, procurement and M&E To be kept updated by the PMU on project progress and issues and to Ministry of Education and disclose all Project documents on their website. To keep the PMU informed Training (MET) on any relevant ministry and GOT policies that may affect the Project To be kept updated by the PMU on project progress and issues and to keep Project Steering Committee the PMU informed of any changes to GOT policies or requirements for the (PSC) project To facilitate the disclosure of all documents and information and to support Project Management Unit (PMU) contractor consultations and the movement of all information to relevant stakeholders on matters affecting the Project To be kept updated by the PMU on project progress and issues and to disclose all Project documents on their CSU website. The Tonga Digital Government Support Project (TDGSP) being financed by the WB and Ministry of Finance (MOF) managed by the MOF has synergies with TSRSP and as such will require consultation with regards the Education Management Information System (EMIS) To be kept updated by the PMU on project progress and issues and to Ministry of Internal Affairs (MIA) facilitate any synergies between the TSRSP and the Skills and Employment for Tongans (SET) Project particularly around the EMIS 4 TSRSP SEP September 2021 Stakeholder Type of Engagement To be kept updated by the PMU on project progress and issues and to Ministry of Infrastructure (MOI) provide permits for construction when necessary and information around projects which may cause cumulative impacts To be kept updated by the PMU on project progress and issues and to Ministry of MEIDECC leverage knowledge and lessons learnt from the PREP Project. To be engaged early on in the process for any required environmental permits To be kept updated by the PMU on project progress and issues and to Ministry of Lands and Natural provide necessary support on land access or occupation issues where Resources (MLNR) necessary To undertake consultation won proposed design and activities with school’s Design and Supervision administration and PTAs and be kept up to date by the PMU on all issues Consultant (DSC) and changes related to design and construction, procurement and E&S To be informed about contract opportunities and upon being contracted, Contractors undertake community awareness and consultation around their activities including promoting the GRM To be consulted during the design/approval and construction phases of the School administration, boards project then to be kept updated by the PMU on project progress and issues. and governance structures . Formal consultation will be required with these stakeholders. To be consulted during the design/approval and construction phases of the Parents and Teachers project then to be kept updated by the PMU on project progress and issues. Associations (PTAs) . Formal consultation will be required with these stakeholders. To be widely consulted regarding the room designs, EMIS and teacher Teaching staff professional development To be informed of construction activities, site and construction risks Students including traffic To be consulted where direct impacts have been identified through the Project Affected People (PAP) impact assessment process. To be kept informed and have ample opportunity to provide feedback and grievances To be kept informed of all Project activities and have ready access to Project Relevant non-government documents and access to channels for communicating feedback and organisations (NGOs) grievances. To participate in targeted consultation Media To be used to channel information and provide feedback To be kept informed of all project activities and have ready access to project documents and access to channels for communicating feedback and General public grievances. In particular the general public and key stakeholders should be made aware of changes to privacy if relevant to the EMIS. To be provided the opportunity to participate in targeted consultation Project Affected People Project affected people (PAP) are those people that are directly or indirectly affected by the Projects activities. Component 1.1 Resilient Infrastructure Investments will have the greatest impacts and risk associated with its activities. The locations of the sites are yet to be determined, however the impacts are likely to be constrained to the construction site and intermittently, construction material transport routes. Any specific site issues will be identified by the DSC and the PMU during the design phase and prior to implementation of construction. Any PAP that are identified as not having sufficient information will be identified and included in the required engagement detailed in the Contractors Environmental and Social Management Plan (CESMP). The PAP include: 5 TSRSP SEP September 2021 • School administrative officers • Parents and teachers • Students • Communities or individuals that may be directly adjacent to Project construction activities and be impacted by such issues as construction noise, dust, and traffic and any community health and safety issue that may be identified in the projects E&S assessments • Communities or individuals that may be directly affected by the Projects development of an EMIS, such as privacy and data security and those that will be directly impacted by teacher professional development activities. Other Interested Stakeholders Any other interested stakeholders that are identified through the design and implementation of the project can be included and added to the SEP with details of type of engagement required. Other interested stakeholders could include: • Church groups, particularly where the school is a Church run establishment • Education NGOs • Other organisations that target children such as sporting organsiations. Vulnerable Stakeholders Vulnerable stakeholders identified for the Project primarily include those associated with gender imbalance, disability access issues, female headed and poor households and any socially excluded group relevant to the education sector. Engagement will include discussions around the recommendations on universal access from the World Bank’s Global Program for Safer Schools (GPSS). The reports3 by ARUP noted the need for: • Improved privacy screens for female toilet blocks • Improved access for females to appropriate female hygiene disposal facilities • Access to universal access/disability toilets • Level well drained walkways and ramps into all new classrooms During the implementation of Component 1 these issues should be specifically raised by the DSC during PTA and school’s administration meetings. Results of these consultations can then be used to include appropriate and simple gender and disability interventions into the bidding documents. 3 ARUP: Tonga, Model School Design Review (Nov 2018) and Tonga Risk Assessment Report (Nov 2019) - Global Program for Safer Schools - Pacific Roadmap 6 TSRSP SEP September 2021 7 SEP Programme The SEP programme is set out in Table 2 which details the information and disclosure required during Project preparation and implementation. This document has been disclosed along with the other ESF documents including: • Environmental and Social Commitment Plan • Labour Management Procedures • Contingency Emergency Response Component (CERC) Environmental and Social Management Framework (ESMF) • Covid 19 Safety Protocol • Environmental and Social Management Plan (Component 1.1) The ESMP had a 30 day (August 25 to September 23, 2021) public comment period, any additional stakeholders or issues from the public consultation period will be incorporated into the relevant implementing documents such as the CESM. This SEP Programme outlines the broad engagement and disclosure for the entire Project including a press release and disclosure of documents for public comment on the CSU and Ministry websites. Where individual Component Activities require additional consultation, these will be included in the relevant documentation such as the CESMP. Any consultation undertaken will consider current Tonga Health guidelines and the COVID-19 Safety Protocol developed for the project. 7 TSRSP SEP V2 August 2021 Table 2 SEP Programme Stakeholder Role Actions Channel Phase Compo (i) DISCLOSURE To provide oversight, Disclosure of documents on WB website, World Bank approvals, feedback and Disclosure All All CSU Website technical support Review and feedback on appraisal Document control Project appraisal All documents, SEP, LMP, ESMP, ESCP To provide project Facilitate the disclosure of all documents for MET management as the MET Website, MOF CSU website Project appraisal All project appraisal Executing Agency (EA) The monitoring and reporting of the activities and actions outlined in this SEP will be undertaken MET to develop a page on their webpage to Webpage (wording for webpage introduction within the E&S section of PMU identify the project and upload relevant Appendix 1) All All the PMU with reporting documents for disclosure requirements including frequency to the respective agencies (WB, MET and MOF) To be kept updated by the PMU on project progress MET PMU to provide the necessary reporting MOF and issues and to disclose Reports and document disclosure All All and disclosure of information to the MOF all Project documents on their CSU website To provide operational Webpage introduction to include the CSU to add the project to their webpage and CSU advice and capacity message (or similar) as detailed in All All disclose all relevant Project documentation building support Appendix 1. 8 TSRSP SEP V2 August 2021 Undertake necessary targetted consultation To provide design and with village administration and the general DSC supervision of Disclosure through media outlets Implementation 1 public on proposed designs and infrastructure works. constructions. For technical inputs there will be greater detail of engagement activities to be undertaken; levels of stakeholder involvement (particularly for affected communities, women and Information Disclosure vulnerable people/groups); the issues Implementation 1&2 discussed and outcomes; and the extent to To provide technical inputs which stakeholder issues, priorities and and civil works and to be concerns are reflected in the ESMPs Contractor Information Disclosure Implementation 1&2 informed of contracting opportunities Communicate expected risks and impacts Consultation with key stakeholder and All 2 and notify PAP information disclosure Consult widely on the security and use of data within the EMIS. PTAs Actively participate in engagement activities To provide feedback to and provide feedback to the PMU, DSC and Targeted consultation Project Implementation 1&2 project implementors Teaching Staff technical contractors for the EMIS To actively participate where appropriate to assist Access to document disclosure General public project development and Actively participate in engagement activities Project start-up and implementation 1&2 Local Media implementation and provide feedback 9 TSRSP SEP V2 August 2021 (ii) Project Planning and Preparation To provide oversight, Review and feedback on appraisal World Bank approvals, feedback and Document control Project appraisal All documents, SEP, LMP, ESMP, ESCP technical support To provide oversight, Review of engagement activities for ESMP World Bank approvals, feedback and Document control Project appraisal 1 and other assessments technical support To provide information and MET to facilitate document sharing with MIA discussion on Project and SET PMU to brief staff on the upcoming MIA Direct communication/consultation Project Start up 2 linkages and coordination TSRSP and facilitate any coordinated with the SET Project activities To provide project Establishment of the PMU through an open Standard procurement processes, public MET management as the Project start-up All and fair process advertising of positions Executing Agency (EA) MET PMU to facilitate early engagement with To provide necessary MEIDECC MEIDECC during ESMP and other permitting Direct communication/consultations Project start-up 1 permitting requirements To actively participate where appropriate to assist General public project development and Actively participate in engagement activities Public meetings and minutes recorded Project Start up 1&2 implementation and provide feedback (iii) Implementation To provide oversight, Review and feedback on appraisal World Bank approvals, feedback and Document control Project appraisal All documents, SEP, LMP, ESMP, ESCP technical support Review of engagement activities for ESMP Project appraisal and Document control 1 and other assessments implementation Monitor and evaluation of project activities as Monitoring and evaluation reporting against Project implementation All detailed in the POM results framework Implementation support Support missions Aide Memoires Project implementation All 10 TSRSP SEP V2 August 2021 To provide technical and Regular PSC meetings, briefings to relevant Provide support to the PMU and provide a PSC bureaucratic support and Ministries and departments, feedback to Project implementation All conduit for information flow oversight PMU To provide project Regular internal reporting as determined by management for project Reports to MET CEO Project implementation All the CEO implementation. Regular reporting to WB as determined by Reports to WB Project implementation All the POM The monitoring and Collaboration with MOF CSU Direct communication/consultation Project implementation All reporting of the activities and actions outlined in this Introductory Consultation Meeting Initial Meeting with relevant stakeholders Project implementation All PMU SEP will be undertaken Disclosure as determined by the WB within the E&S section of procurement process the PMU with reporting Call for bids on component activities Project implementation All Communication strategies to be advertised requirements including widely frequency to the respective agencies (WB, MET and Oversight of contractor’s consultation PMU E&S Officer Project implementation All MOF) processes Details for the GRM are presented in Establish a functional GRM Implementation 1&2 Section 9 To provide operational GRM detailed in Section 9 CSU advice and capacity Provide a link to the GRM Project implementation All building support Provide regular feedback to PMU To provide information and MET to facilitate document sharing with MIA discussion on Project and SET PMU to brief staff on the upcoming MIA Direct communication/consultation Project Implementation 2 linkages and coordination TSRSP and facilitate any coordinated with the SET Project activities Provide necessary permits for construction Standard MOI permitting process with To provide permitting and Project implementation 1 activities consultation MOI advice for school construction Provide technical advice and compliance Direct communication/consultation Project implementation 1 auditing for school construction 11 TSRSP SEP V2 August 2021 MET PMU to facilitate early engagement with To provide necessary MEIDECC MEIDECC during ESMP and other permitting Direct communication/consultations Project implementation 1 permitting requirements Direct communication/consultations To provide necessary MET to facilitate discussions with MLNR as MLNR support around land issues required and to be informed of their role within Project implementation 1 and any required permits the GRM GRM detailed in Section 9 Provide regular feedback to PMU Direct communication To provide design and Undertake necessary targeted consultation Public meetings DSC supervision of with village administration and the general Project implementation 1 infrastructure works public on proposed designs and construction Community presentations and factsheets MET PMU to facilitate access to a fair and Normal WB approved contractor Project implementation 1&2 open bidding process procurement process ESMP engagement For technical inputs there will be greater detail of engagement activities to be undertaken; Direct consultation with PAP utilising levels of stakeholder involvement (particularly various methods appropriate to the for affected communities, women and individual stakeholder or group. To provide technical inputs Project implementation 1&2 and civil works and to be vulnerable people/groups); the issues Contractors discussed and outcomes; and the extent to informed of contracting Obtain and list of priority issues and opportunities which stakeholder issues, priorities and suggested solutions concerns are reflected in the ESMPs Development of E&S risk and impact Communicate expected risks and impacts strategies within the CESMP for schools Project implementation 1&2 and notify PAP 12 TSRSP SEP V2 August 2021 Contractors to hold public meetings prior to commencement of works to inform and disclose the activity GRM and contact information to PAP, staff, PTAs, students Facilitate awareness for PAP and school administration Project implementation 1&2 Signs adjacent work sites with clear information for contact person and GRM School Targeted consultation and recording of administration, Actively participate in engagement activities issues that may occur To provide feedback to boards and and provide feedback to the PMU, DSC and Project Implementation 1&2 project implementors governance technical contractors for the EMIS structures Actively participate in engagement activities Targeted consultation To provide feedback to PTAs and provide feedback to the PMU, DSC and Project Implementation 1&2 project implementors technical contractors for the EMIS Actively participate in engagement activities Targeted consultation To provide feedback to Teaching staff and provide feedback to the PMU, DSC and Project Implementation 1&2 project implementors technical contractors for the EMIS Actively participate in engagement activities Public meetings and minutes recorded Project implementation 1&2 and attend public meetings To provide feedback to PAP Communicate messaging Access to disclosed documents Project implementation 1&2 project implementors Facilitate understanding of GRM and access Access to the GRM Project implementation 1&2 to information To actively participate where appropriate to assist General public project development and Actively participate in engagement activities Public meetings and minutes recorded Project implementation 1&2 implementation and provide feedback 13 TSRSP SEP V2 August 2021 14 TSRSP SEP V2 August 2021 8 SEP IMPLEMENTATION The following steps should be undertaken to implement the SEP (Figure 1). Project Preparation, Appraisal and Approval This SEP is the key guide for stakeholder engagement throughout the Project cycle and is a prerequisite for the appraisal and approval process the WB undertakes for the Project. The SEP will be disclosed on the Ministry of Finance, CSU website (http://www.finance.gov.to/csu/projects/tsrsp) and should be disseminated amongst other key stakeholders where relevant. Project Implementation The key to Project start-up success will be the early procurement of the PMU including the key position for the implementation of this SEP, the PMU E&S Officer (or equivalent). The PMU E&S Officer will, as the Project progresses, continue to identify and consult appropriately with key stakeholders including PAP and any vulnerable individuals or groups that may be impacted by the Project. Component Consultation As described earlier this Project does not present significant risks with regards to stakeholder engagement. There has been broad support for the current school’s component under PREP and it is envisaged that this will continue for the TSRSP under MET. Prior to any consultation activity it is advised that a brief Communications Plan (Appendix 2) be developed by the PMU to guide messaging and how that messaging is communicated. Component Implementation During the procurement of contractors for the implementation of component activities it is important that the requirements for stakeholder engagement are clearly defined in the procurement (bidding docs - RFQ, ROI etc). Contractors undertaking construction will be required to develop a Contractors Environmental and Social Management Plan (CESMP - for major works) or an Environmental and Social Code of Practice (ESCOP - for minor works). These documents will clearly indicate the consultation and disclosure activities that will be required by the contractors. For each engagement the PMU E&S Officer should prepare, or assist contractors to prepare a brief plan for the engagement which will guide the messaging and channels for communication. A template for the Communications Plan has been developed to assist this process and is detailed in (Appendix 2). 15 TSRSP SEP V2 August 2021 Figure 1 Implementation steps for the SEP • Develop SEP and other E&S documents • Consultation to be undertaken during ESMP • Disclose all Project documents on websites Project Preparation, • WB approval Appraisal & • MET to facilitate information flow with other GOT Ministries Approval • PMU to facilitate communication and ongoing disclosure of documents • All PMU staff to be aware of SEP requirements Project • Ongoing stakeholder identification as project comonents are finalised Implementation • Consultation and feedback from ESMP public disclosure fed back into SEP • Consultation by contractors on design schools and EMIS Component • Ongoing communication and consultation with relevant GOT Ministries (identification of Consulation permits or support required from other ministries) • Requirement of CESMP or ESCOP included in procurement documents and contracts • Site consultation during development of CESMP • Disclosure of activities and GRM on commencement of works Component Implementation • Feedback and GRM mechanisms are functional • Organise consultation material/records (database/filing) • Anlayse material and feed into planning and safeguard instruments • Report results Analysis & • Maintain GRM and contact with key stakeholders, feed infomation back to stakeholders Reporting 9 ROLES AND RESPONSIBILITIES The MET is primarily responsible for implementation of the Project through the PMU. The following positions will be responsible for the implementation of this SEP: • The MET PMU PM is responsible for overseeing and coordinating all activities associated with the Project. • PMU E&S Officer is responsible for implementing this SEP and any associated community engagement activities. • PMU Procurement Officer and Contract Manager are responsible for communicating proposed contract opportunities to industry and members of the general public that include required E&S obligations. There are a number of other responsibilities with regards to grievances outlined in Section 8. 16 TSRSP SEP V2 August 2021 PMU PM The PMU Project Manager will be responsible to develop and maintain relationships whilst communicating with Government ministries and departments and the media. Media engagements may be required throughout the Project’s life and decisions taken as a result of these engagements could potentially impact MET’s relationships with communities. Stakeholder engagement activities may influence the activities of other departments or require their inputs. The PMU PM is to facilitate communication with the managers of other projects, ministries and departments to keep them informed on the stakeholder engagement process. The flow of information from these managers to the PMU PM is also important as activities that they may be undertaking can impact project outcomes and create risk. PMU E&S Officer The PMU E&S Officer needs to manage and facilitate all stakeholder engagement. Responsibilities of the PMU E&S Officer including: • Manage all stakeholder engagement related activities for the Project and the implementation of this SEP. • Manage the GRM as described in Section 9. • Support the development, implementation and monitoring of all stakeholder engagement activities for Project ESMP by external consultants. • Facilitate the public disclosure of ESMP documents and collate and analyse public responses to these and facilitate changes to ESMP, SEP and any other relevant E&S documents from public comments. • Facilitate the movement of information between key stakeholders and ensure all relevant documents are disclosed. • Provide support for any activities that require ad hoc or intensive stakeholder engagement (community development and land acquisition/resettlement planning and implementation). • Liaise with other WB Project Managers and E&S Specialists/consultants to confirm that stakeholder engagement requirements/protocols are understood. • Proactively identify stakeholders, project risks, impacts and opportunities and inform the PMU PM to facilitate the necessary planning to either mitigate risk and impacts or take advantage of opportunities. The PMU E&S Officer needs to remain actively involved with the community development and land acquisition/resettlement planning (if any) and implementation of these activities in order to identify potential risks or opportunities and ensure that appropriate administrative support is provided. PMU Procurement Officer and Contract Manager The PMU Procurement Officer and Contract Manager will be required to facilitate the necessary terms and conditions for E&S commitments in bidding documents and contracts. There is also a need for these positions to manage the opportunities for contracts and contractor’s employment as these can become key issues with industry and the community if not seen to be open, fair and transparent. There are sensitivities around local employment and contracting that need to be managed with appropriate messaging. This requires clear and 17 TSRSP SEP V2 August 2021 transparent contracting processes f be adhered to and clearly communicated to the communities. 10 GRIEVANCE REDRESS MECHANSIM A GRM is a locally based, formalised way to accept, asses and resolve community feedback or complaints. The GRM provides important feedback for the continued improvement of projects. The GRM is a process for receiving, evaluating and addressing project-related complaints from communities at the level of project component or activity. The terms complaints4 and grievances5 are used interchangeably. The following are the GRM objectives: • To address complaints and enhance conflict resolution arising from, and during project implementation. • To provide transparency and accountability throughout the implementation of components/activities amongst the relevant stakeholders including project beneficiaries. • To resolve any emerging environmental and social complaints/issues at project sites. • To promote good relations between the project implementers, contractors and beneficiaries. Grievances raised by stakeholders need to be managed through a transparent process, readily acceptable to all stakeholders (particularly PAP), at no cost and without retribution. The grievance mechanism is appropriate to the scale of impacts and risks presented by the Project. The GRM does not impede access to other judicial or administrative processes. This GRM sets out a number of steps to be taken to resolve grievances, the role of different staff members involved and timeframes to reach a decision on grievances. The types of grievances stakeholders may raise include, but are not limited to: • Negative impacts on communities, which may include, but not limited to financial loss, physical harm and nuisance from construction or operational activities. • Health and safety risks. • Negative impacts on the environment. • Unacceptable behaviour by staff or employees. It is critical that stakeholders understand that all grievances lodged, regardless of the Project phase or activity being implemented, will follow this process. The GRM described in this section is distinct from the grievance mechanism to be used by the Project’s workforce as detailed in the TSRSP Labour Management Procedures (LMP). 4 Complaint: an expression of dissatisfaction that is related to an impact caused by a project activity, which has affected an individual or group. Adversely, the interests of an individual or group and the individual or group wants a proponent or operator (or contractor) to address and resolve it (e. g. problems related to dust deposition, noise or vibration). A complaint is normally of a less serious nature than a grievance 5 Grievance: a claim raised by an individual or group whose livelihood, health and safety, cultural norms and heritage are considered to have been adversely affected (harmed) by a project activity which, if not addressed effectively, may pose a risk to the MET Project. 18 TSRSP SEP V2 August 2021 Principles of the GRM The following are broad principles of the GRM: • Legitimate: enabling trust from the stakeholders and being accountable for the fair conduct of grievance processes. Accountability for ensuring that the parties to a grievance process cannot interfere with its fair conduct, is typically one important factor in building stakeholder trust. • Accessible: being known to all stakeholders and providing adequate assistance for those who may face particular barriers to access. Barriers to access may include a lack of awareness of the mechanism, language, literacy, costs, physical location and fears of comeback. • Predictable: providing a clear and known procedure with an indicative timeframe for each stage, and clarity on the types of process and outcome available and means of monitoring implementation. In order for a mechanism to be trusted and used, it will provide public information about the procedure it offers. • Equitable: seeking to ensure that complainant has reasonable access to sources of information, advice and expertise necessary to engage in the process on fair, informed and respectful terms. Where imbalances are not redressed, perceived inequity can undermine both the perception of a fair process and the GRM’s ability to arrive at sustainable solution. • Transparent: keeping parties to a complaint informed about its progress. Providing transparency about the GRM to wider stakeholders will be important to demonstrate its legitimacy and retain broad trust. At the same time, confidentiality of the dialogue between parties and of individuals’ identities will be provided where necessary. • Rights compatible: are consistent with applicable Tongan national recognised rights and customs. • Enabling continuous learning: drawing on relevant measures to identify lessons for improving the mechanism and preventing future grievances and harm. • Based on engagement and dialogue: consulting the stakeholders and focusing on dialogue as the means to address and resolve grievances • Consistent: that all complaints, irrespective of their nature or who makes them are treated the same. • Capable: seeking the necessary technical team to address grievances in a timely manner. Confidentiality Complaints may be made anonymously and confidentiality with the details of complainants being kept confidential in all instances, including when the person making the complaint is known. For this reason, multiple channels (email, phone, web based etc) to make a complaint will be established and conflicts of interest avoided. Specific procedures for Gender Based Violence/Sexual Exploitation and Abuse (GBV/SEA) and Sexual Harassment (SH) including confidential reporting with safe and ethical documentation of GBV/SEA cases will be undertaken through the process developed by the CSU with the Women’s and Children’s Crisis Centre (WCCC). Details of this mechanism will be included in the CESMPs and ESCOPs when finalised/ 19 TSRSP SEP V2 August 2021 GRM Process The purpose of the GRM is to address and record any complaints that may arise during the implementation of the project. The GRM works within existing legal and cultural frameworks, providing an additional opportunity to resolve grievances at the local, project level. The key objectives of the GRM are: • Settle the grievances via consultation with all stakeholders (and inform those stakeholders of the solutions). • Forward any unresolved cases to the relevant authority. • Record, categorize and prioritize the grievances. Community Level Local communities have existing traditional and cultural GRMs. It is expected that some disputes at the community level will be resolved using these mechanisms, without the involvement of the contractor(s), and or Government representatives at local and national levels. With disputes that include differences between households over land, or boundaries, even on issues triggered indirectly by the Project, the mechanism will involve the Town Officer, landowner(s) concerned, and if required, the representative from the MLNR and MET. It is expected that any land dispute issues pertaining to the Project would be resolved at this level given the nature of land ownership and the significant authority vested under the MLNR. Where issues caused by the project are raised and resolved through these existing community level mechanisms, it is important that a mechanism for reporting them to the MET is established. MET will record all complaints/outcomes, and if it involves land disputes, the MLNR will lead and record all complaints/outcomes. Project Level Many Project related grievances will be minor and site-specific, and can be easily resolved on-site by the Contractor’s Site Supervisor (CSS). They usually revolve around nuisances generated during construction such as obstruction of access, noise, dust, vibration, workers dispute’s etc. On-site grievances that are easily resolved still need to be communicated to the PMU E&S Officer for recording, including how the dispute came about and how it was resolved. However, some complaints are likely to unresolved on site. The CSS will then inform the PMU E&S Officer and the formal GRM will be activated. The PMU E&S Officer will, where possible, request the complainant to fill out the grievance form (Appendix 3), and on receipt of each complaint, note the date, time, name and contact details of the complainant, and the nature of the complaint in the Complaints Register (Appendix 4). The PMU E&S Officer will inform the complainant of the formal receipt of the complaint utilising a standard response letter (Appendix 5) and a timeframe for a response. In the first stage of the GRM the PMU E&S Officer will endeavour to address the issue with direct discussions with the complainant. Should the PMU E&S Officer not be able to resolve the complaint to the satisfaction of the affected persons, it will then be elevated to the PMU PM. The PMU PM and E&S officer will develop a Plan of Action (POA) to resolve the issue and communicate this back to the complainant for resolution. At all stages the complainant must be kept informed about the course of action being taken within a period of two weeks from the 20 TSRSP SEP V2 August 2021 date that the complaint was received. If it’s a land related issue, the PMU PM will inform the MET CEO who will consult the CEO MLNR on how best to proceed. If the complaint is not resolved by the PMU PM to the satisfaction of the complainant, it will then be referred by the MET CEO to the PSC. The PSC will be supported by the PMU to inform and advise. The PSC is required to address the concern within 1 month. The PMU E&S Officer will draft a revised POA to resolve the issue based on the PSC determination and take this POA to the complainant for resolution. Should measures outlined in the POA fail to satisfy the complainant, the aggrieved party is free to take his/her grievance to the Ombudsman’s Office for mediation and a decision by the Ombudsman. For land issues, it would be advisable for the complainant to take his/her issue to the Minister of MLNR for a final pronouncement. It is rare for a complaint to be unresolved after the Ombudsman’s decision or for MLNR’s resolution to be taken further. If the complainant does not accept any resolution at this stage, the GRM will not impede complainants’ access to the legal system. At any time, the complainant may take the matter to the appropriate legal or judicial authority as per the laws of Tonga. Complainants can also access the WB Grievance Redress System (GRS). To promote the GRM tool, signs must be erected at the sites of all works providing the public with updated project information and summarising the GRM process, including contact details of the PMU E&S Officer. Anyone will be able to lodge a complaint through a number of methods (including the complaints form, in person, by telephone, via the web in either English or Tongan). The PMU must provide a GRM that makes every effort not inhibit the lodgement of a complaint. The Complaints Register (Appendix 4) will be maintained by the CSU and PMU E&S Officer, who will log the details. This information will be included in PMU progress reports to the WB. Contact details for the GRM are: Web: http://www.finance.gov.to/csu/complaints Address: Level 4, National Reserve Bank of Tonga, Nukualofa, Tonga Phone: Ucall +676 28550 Digicel +676 68528550 Email: csu@finance.gov.to Table 3 GRM summary at Project Level (Figure 1 illustrates the steps for the GRM) Stage Process Duration The complainant can take his/her grievance directly to the CSS (if relevant) who will Anytime endeavour to resolve it immediately. If not satisfied with the onsite solution, the CSS will refer them to put in a formal grievance to the PMU E&S Officer (or the CSS can 1 offer to do this on their behalf by using a complaints form, Appendix 4). For complaints that were satisfactorily resolved by the CSS, the PMU E&S Officer must be informed to log the grievance and the actions that were taken. On receipt of a formal complaint, the PMU E&S Officer will respond (standard letter Within 2 weeks 2 Appendix 5) and endeavour to resolve it within 2 weeks of receiving the complaint. If the matter cannot be resolved by the PMU E&S Officer, he/she then notifies PMU Within 2 weeks 3 PM and they develop a POA (Appendix 6) to resolve the issue. The complainant must be notified that as a result of the PMU E&S Officer and the complainant failing to 21 TSRSP SEP V2 August 2021 Stage Process Duration resolve the issue it will be elevated to the PM and another two weeks for the development of a POA will be required. If it’s a land issue, the PM will advise the MET CEO, to engage the MLNR If the complainant is not satisfied with the POA, the MET CEO, will refer to matter to Within 1 month the PSC for a resolution. The PSC with the PMU E&S Officer and PM will develop a 4 revised POA to resolve the issue. The complainant must be notified that as a result of the PMs and the complainant failing to resolve the issue it will be elevated to the PSC and 1 month for the development of a revised POA will be required If the complainant is dissatisfied with the outcome proposed in the POA, he/she is Anytime 5 free to refer the matter to the Ombudsman’s Office If the issue remains unresolved through the Ombudsman’s decision or the Minister of Anytime Lands decision, then the complainant can take the matter to the Courts or Land Court 6 respectively to deliberate. Any such decisions are final. The complainant can also access the WB GRS (Appendix 7) if they have a specific grievance related to WB projects. 11 MONITORING, EVALUATION AND REPORTING Monitoring and evaluation (M&E) will be undertaken as a part of overall Project implementation. Specific key indicators for the SEP should be incorporated into the Project Operations Manual (POM) which will include how stakeholders can provide feedback. Activities related to the SEP should be reported in the E&S section of the normal reporting cycle for the Project as determined in the POM. Any key indicators for the SEP have been incorporated into the M&E framework for the Project. 22 TSRSP SEP V2 August 2021 Figure 2 GRM Steps Site Supervisor Complainant Resolved PMU Safeguards Officer If unresolved MET PMU PM Plan of Action MET CEO MLNR CEO , PSC Plan of Action Ombudsman Office / MLNR Mediation Courts / Land Court 23 TSRSP SEP V2 August 2021 APPENDIX 1 PROPOSED WORDING FOR THE PROJECT WEBSITES Tonga Safe and Resilient Schools Project (TSRSP) To enhance the safety and resilience of selected educational facilities, and improve the effectiveness of selected educational programs in Tonga, the World Bank is providing funds under IDA19 for the Tonga Safe and Resilient Schools Project (TSRSP – P174434). The implementing agency will be the Ministry of Education and Training (MET). The project will include the following four components, with funding to be refined during project preparation: 1. Improving Multi-hazard Resilience of Education Facilities 1.1. Resilient Infrastructure Investments 1.2. Strengthening Education Infrastructure Planning and Maintenance 2. Establishment of Education Management Information System (EMIS) and improved quality of teaching 2.1. Establish a comprehensive EMIS to inform policy decision making 2.2. Upgrading curricula and assessments 3. Contingent Emergency Response Component (CERC) - unallocated project funds may be requested for re-allocation to support response and reconstruction in case of a major crisis or emergency. 4. Project Management For further information or feedback please contact MET CEO metceotonga@outlook.com 24 TSRSP SEP V2 August 2021 APPENDIX 2 COMMUNICATION PLAN The purpose of the Communications Plan template is to guide strategic thinking through the communications planning process. Specifically, prior to implementing communications, we should understand the purpose and desired outcomes and actions we want to see, who our target audience(s) is/are, the different channels we want to use to reach our audiences, and to understand what risks exist. The tool helps us to plan our activities step by step and provides a shareable document for coordination. The tool can be filled out in bullet form for simple communications activities and can be expanded for larger communications campaigns with multiple audiences, messages, and materials. The tool is to guide engagement activities. 1 INTRODUCTION • Provide a brief introduction/overview on the Component and activity this Plan is addressing. 2 PURPOSE • Describe the purpose of the communications activity. Why we are doing this communication. 3 OBJECTIVES • What are we trying to achieve? 4 RISKS AND MITIGATION • List any risk(s) involved in this communication • Suggest mitigation measure(s) to address the above risk(s) • Answer the question: What could prevent this communication activity from achieving its desired outcome? Could the communication activity trigger an undesired response? 4.1 Key Stakeholders, Message and Channel • List your key stakeholders for this engagement • List your key messages that you will use in your engagement o Where possible, test your messages with a test audience • List the means to which the messages will be communicated (channel): o Describe the different channels used to achieve the desired outcomes based on analysis of the target audiences -answers the question: How do we communicate with each target audience? o Describe how each channel will be used. o Where possible test your communications channel to see if it is effective 25 TSRSP SEP V2 August 2021 Example table to be used Stakeholder Key message Channel Frequency Feedback mechanism 5 Frequently asked questions • List out what you expect to be the FAQs from the audience • List out standard responses for your FAQs 6 ROLES and responsibilities • List out those people and organisations responsible for implementing this Communications Plan 26 TSRSP SEP V2 August 2021 APPENDIX 3 COMPLAINT FORM Name of Person Making the Complaint (information is optional and always treated as confidential) Address or contact information for Person Making the Complaint (information is optional and confidential) E-mail Phone Address Location where complaint/problem occurred (write in) Category of Grievance: � Environmental safeguards, � Social Safeguards including � Grievances regarding worker � Grievances regarding the � Grievances regarding abuse including waste, noise, dust and gender, labour, community health and safety and misuse of funds/lack of of power/intervention by project water runoff/pollution health and safety (including behaviour of workers on-site transparency, or other financial or government officials traffic) and child safety management concerns � Other (describe) 27 TSRSP SEP V2 June 2021 Brief Description of Complaint (provide as much detail and facts as possible attach additional pages if required) Please include any other information that you consider relevant, other matters or facts, including supporting documents (attach additional pages if required) Do you request that identity be kept confidential? �Yes � No Have you previously raised your complaint with the on-site Manager or others? �Yes (if YES, please provide the following) • When, how and with whom the issues were raised • Please describe any response received from and/or any actions taken by the NCU level grievance mechanism. Please also explain why the response or actions taken are not satisfactory �No (if NO, why not?) 28 TSRSP SEP V2 June 2021 Complaint Recipient (If Authorized Representatives are not complainants themselves, their names will be disclosed as needed, in order to ensure transparency) Name Position/Organization Contact number E-mail address Signature of the person making the complaint Signature Please send the complaint to Date: Grievance Redress Mechanism PMU (insert appropriate Project and address) Email (insert appropriate Project and address) Phone (insert appropriate Project number) Complaints may be submitted by, e-mail or hand delivery 29 TSRSP SEP V2 June 2021 APPENDIX 4 GRM REGISTER 30 TSRSP SEP V2 June 2021 APPENDIX 5 GRM STANDARD RESPONSE LETTER MINISTRY OF EDUCATION AND TRAINING Government of Tonga Reference No.: Type reference number Date: Type the date Type recipient’s name., Type recipient’s title., Type recipient’s address. Type the salutation, Re: Your complaint received regarding insert date and issueYour complaint received regarding insert date and issue Type body of letter. “All correspondences shall be as courteous, brief and concise as possible. Simple and everyday words shall be used where possible. Previous relevant correspondences or any relevant law, regulation, ruling shall also be quoted� (PSC Policy Manual, 2006) Thank you for your visit, letter, email, telephone call of insert date. We welcome and appreciate all feedback regarding our project. Please be assured that we will investigate the issues you have raised and provide you a written response within 2 weeks. We may contact you during this period for additional information. Until then if you require any further assistance do not hesitate in contacting insert PMU Safeguard Officers name and contact details who will be very happy to assist you. Type closing, ____________________ Type your name Project Manager TSRSP 31 TSRSP SEP V2 June 2021 32 TSRSP SEP V2 June 2021 APPENDIX 6 GRM PLAN OF ACTION (POA) Complaint # (from the complaints log) Name and details of complainant Date complaint received Date GRM PoA completed Date Plan discussed with complainant Nature of complaint (brief description) Proposed Solutions Consultation with the complainant (detail date and discussions had with complainant and other stakeholders in developing the solutions). Signature of Complainant (accepting the proposed solutions) Signature of on-site Supervisor (acknowledging implementation of the solutions) Signature of PMU Safeguards Officer (GRM Focal Point) 33 TSRSP SEP V2 June 2021 APPENDIX 7. WORLD BANK GRIEVANCE REDRESS SERVICE 34 TSRSP SEP V2 June 2021 35