Republic of Senegal ----------------------------- Ministry of Territorial Collectivities of Development and Land Use Planning ----------------------------- CASAMANCE ECONOMIC DEVELOPMENT PROJECT (CEDP) P175325 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Draft January 2022 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of the Republic of Senegal (hereafter referred to as the Recipient) shall implement the Casamance Economic Development Project (CEDP) through the Ministry of Territorial Collectivities, Development and Land Use Planning, which oversees the CEDP Project Coordination Unit (PCU), the entity responsible for implementing the project. The International Development Association (IDA) (hereinafter referred to as (the Association) has agreed to provide financing for the project in the form of a Credit. 2. The Recipient shall, and shall cause the PCU to, ensure that the Project is implemented in accordance with the Association’s Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Association. This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, to be carried out or caused to be carried out by the Recipient, including the timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, grievance management and the environmental and social assessments and instruments to be prepared or updated, disclosed, consulted, adopted and implemented under the ESCP and the ESSs, in a manner acceptable to the Association. 3. The Recipient shall also comply with the provisions of all the environmental and social documents required under the Environmental and Social Framework (ESF) and referred to in this ESCP, such as the Environmental and Social Management Framework (ESMF) including the Action Plan for Mitigation and Responses to Exploitation and Sexual Abuse and Sexual Harassment (ESA/SH) (ESA/SH Action Plan), the Resettlement Policy Framework (RPF), the Stakeholder Engagement Plan (SEP) including a Grievance Redress Mechanism (GRM), and the Labor Management Procedures (LMP). Other documents shall be prepared according to the timing indicated in the ESCP. These include Environmental and Social Impact Assessments (ESIAs) with Environmental and Social Management Plans (ESMPs), Resettlement Action Plans (RAPs), including livelihood improvement plans where necessary. The deadlines specified in these E&S instruments shall be followed and maintained up to date by the Recipient. 4. The Recipient is responsible for compliance with all ESCP requirements, even where the implementation of specific measures and actions is the responsibility of the ministry, unit, or public agency mentioned in paragraph 1 above. 5. The implementation of the specific measures and actions defined in the present ESCP shall be permanently monitored by the Recipient, and periodic reports shall be communicated to the Association, in application of the provisions of the ESCP and the conditions of the legal agreement, while the Association shall ensure the monitoring and evaluation of the progress and realization of these specific measures and actions, throughout the Project implementation 6. As agreed by the Association and the Recipient, this ESCP may be revised from time to time during the implementation of the Project, in a manner that reflects the adaptive management of changes or unforeseen situations that may arise in connection with the Project, or in response to an assessment of Project performance conducted under the ESCP itself. In such situations, the Recipient, through the Project Management Unit (PMU), shall agree on these changes with the Association and revise the ESCP accordingly. The agreement on the Page 2 modifications made to the ESCP shall be attested by the exchange of letters signed between the Association and the Recipient. The Recipient shall promptly disclose the updated ESCP. 7. When the Project performance, unforeseen situations or Project changes occurring in the framework of its implementation, result in changes to the risks and effects during the implementation of the Project, the Recipient shall provide additional funds, where appropriate to carry out actions and measures to address these risks and effects/impacts that may include environmental and social risks, health, safety for the populations, risks related to the influx of labor seeking employment, the risk of degradation of natural resources and pollution of the physical environment (soil, air, surface and ground water, noise on the construction sites), the risk of disrupting the free movement of people and goods, the risk of social conflicts, and the risks to the health and safety of the population (including outbreak of diseases among the population and workers, accidents linked to construction site activities, health risks linked to poor management of waste from the shipyards, loss of land and property, and gender-based violence - sexual harassment, rape, unwanted pregnancies among the Recipient populations, etc.); and risks related to child labor. 8. The table below presents the important measures and actions required, the responsibilities of the actors involved in the Project, and the timeframes for implementing the selected measures and actions. Page 3 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING Prepare and submit to the Association environmental, social, health Quarterly, no later than the 5th of the Project Coordination Unit (PCU) and safety (ESHS) monitoring reports of the Project, including but month following the end of the quarter, not limited to the implementation of the ESCP, the degree of throughout Project implementation. preparation and implementation of environmental and social instruments required under the ESCP, Stakeholder engagement A compilation of these reports shall be activities and the functioning of the Grievance Redress Mechanism made on a quarterly basis and sent to the including those related to Gender-Based Violence/Sexual Bank starting at 3 months after Exploitation and Abuse (GBV/SEA), Sexual Harassment effectiveness date. (SH)/Violence Against Children (VAC) and Project workers. B INCIDENTS AND ACCIDENTS Notify the Association of all incidents or accidents directly or Incidents and accidents shall be reported Project Coordination Unit (PCU) indirectly related to or affecting the Project and likely to have immediately to the Task Team Leader serious consequences for the environment, communities, the (TTL) in writing, no later than 48 hours public, or personnel. after learning of the incident or Accident; within 24 hours in case of a fatality As an indication, any accident related to the Project or any Upon request, a detailed report on allegation of GBV/SEA/SH related to the Project should be reported specific information, (including causes, immediately consequences, actions taken, etc.), shall be provided within a period acceptable to The notification shall include sufficient details of the incident or the Association. accident, including the causes and measures taken or to be taken without delay to remedy the incident or accident and any This systematic notification system shall information made available by any supplier/service provider or be in force throughout the Project supervising entity, where applicable. Implementation. A model incident or accident notification form shall be shared with all suppliers and service providers. C MONTHLY REPORTS FROM SUPPLIERS AND PROVIDERS Require suppliers and contractors to prepare and submit monthly Monthly and throughout Project Project Coordination Unit (PCU) monitoring reports to the PCU, including implementation of implementation Contractors and subcontractors environmental, social, health and safety requirements. Share the reports with the Association. Page 4 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY D CONTINGENT EMERGENCY RESPONSE COMPONENT (CERC) Before the beginning of the emergency Project Coordination Unit (PCU) Prepare an addendum to the ESMF to cover the activities of the response activities. The request to CERC at the time of preparation of the CERC Manual. The activate the CERC shall come from the addendum shall be approved by the Association. Recipient. In the event of an emergency leading to the activation of the Project’s CERC, the Recipient shall prepare the necessary instruments and measures before undertaking the emergency response activities to ensure compliance with the E&S measures of the project. These instruments shall be submitted to the Association for approval ESS1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE Establish and maintain an organizational structure (Project An organizational structure comprising Project Coordination Unit (PCU) Coordination Unit) with qualified staff and resources to support two (2) specialists (an Environmental environmental and social risk management. Safeguard Specialist with expertise in OHS and a Social Safeguard Specialist) shall be established after Effectiveness. The organizational structure, must be maintained throughout the As part of the implementation of the Project, an Environmental implementation of the Project. The Safeguard Specialist with expertise in OHS and a Social Safeguard Specialists shall be mobilized after Specialist with solid experience in stakeholder engagement, GRM Effectiveness. operationalization, and GBV/SEA/SH issues shall be recruited with qualifications and experience under terms of reference acceptable The Project shall establish an agreement to the Association, to support environmental and social risk with DEEC to define its tasks. management. In addition, the Project shall also rely on the Direction of Environment and Classified Facilities (DEEC) / Regional Directions of Environment and Classified Facilities (DREEC) of Ziguinchor, Page 5 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY Kolda and Sédhiou to support the PCU in the environmental selection or screening process that shall allow the identification of the environmental and social Impact Assessment (ESIA, AEI) to be carried out for each subproject. Monitoring Contractors and Missions shall also be required to establish and maintain an organizational structure with qualified and appropriate staff and resources to assume responsibility for managing environmental and social risks and impacts, including specialists in environmental, social, health, and safety risk management. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT Adopt and implement the Environmental and Social Management ESMF to be disclosed prior to project Project Coordination Unit (PCU) Framework (ESMF) prepared for the Project in a manner acceptable appraisal to the Association. The ESMF will be consulted upon, approved, and disclosed. 1.3 MANAGEMENT TOOLS AND INSTRUMENTS Prepare and implement the following risk management and Project Coordination Unit (PCU) assessment tools and instruments (frameworks and plans): ▪ The Environmental and Social Management Framework (ESMF) Before project appraisal is developed and includes an assessment and mitigation measures of the Project's environmental and social risks and impacts, including contextual risks, risks related to GBV/SHA, and vulnerable groups. Environmental and social measures are proposed as part of the project implementation. ▪ Resettlement Policy Framework (RPF), ▪ Stakeholder Mobilization Plan (SEP), ▪ Labor Management Procedures (LMP), ▪ An Environmental and Social Commitment Plan (ESCP) is Specific Environmental and Social prepared and shall be implemented. Assessments (ESIA, EIA, ESMP, Environmental Audit etc.) shall be ▪ Other safeguard tools and instruments shall be prepared once prepared before the start of sub-projects the technical studies are completed and the sub-projects are for which these instruments are required known and after the Preliminary Review of all sub-projects and submitted to the Association for following the Environmental and Social Management approval. Once approved, the Framework (ESMF) prepared for the Project, such as environmental and social plans are Environmental and Social Impact Assessments (ESIA), implemented throughout project Resettlement Action Plans (RAPs) implementation. Social and security assessment Page 6 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY Before the start of the sub-projects, the Subsequently, the Environmental and Social Management Plans specific instruments shall be prepared (ESMPs) of the sub-projects established and adopted shall be and implemented and monitored implemented in a manner acceptable to the Association. throughout the implementation of the Project. At project inception and before the start of activities. 1.4 MANAGEMENT OF SUPPLIERS AND SERVICE PROVIDERS Integrate relevant aspects of the ESCP, including the ESMF, RPF, During the preparation of the bidding Project Coordination Unit (PCU) GRM, SEP, LMP, GBV Plan, into the ESHS specifications of bidding documents and prior to the start of the documents and contracts with contractors and subcontractors. works Prior to the signing of the contract and the start of works. Ensure that contractors and subcontractors comply with the ESHS specifications of their respective contracts, meet deadlines and Application of these measures during the provide quality services and regular reports. entire period of the Project Supervision of contractors and subcontractors throughout Project implementation ESS2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Develop and implement Labor Management Procedures (LMP). The LMP shall be in place prior to project Project Coordination Unit (PCU) appraisal. Contractors and subcontractors Prepare site-specific labor management plans as part of site- specific ESMPs, based on the LMP. Before workers start working for contractors and subcontractors Conduct the analysis of working conditions by integrating the Throughout Project implementation Coronavirus disease (SARS CoV2) context to ensure workers' health and safety throughout the project cycle. 2.2 GRIEVANCE REDRESS MECHANISM FOR PROJECT WORKERS (GRM) GM in place prior to hiring workers Project Coordination Unit (PCU) Contractors and subcontractors Establish a specific GRM for labor complaints and issues to deal Throughout Project implementation Page 7 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY with disputes arising in this context, as described in the Labor Management Procedures and consistent with ESS2. 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Project Coordination Unit (PCU) Implement and include in the bidding documents, Terms of Contractors and subcontractors Reference and contracts of the Project's suppliers/contractors, the occupational health and safety (OHS) clauses specified in the ESMF, Before launching the consultation and any other OHS measures recommended by the specific documents for suppliers / service ESIA/ESMP. providers (integration of OHS measures). In the current context of COVID-19, specific clauses shall be Before the start of the work. annexed in the contracts of the service providers so that no project activity shall cause health risks for the local populations. Ensure that the Project's contractors/suppliers apply these occupational health and safety (OHS) measures. Throughout Project implementation ESS3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE AND HAZARDOUS MATERIALS MANAGEMENT Project Coordination Unit (PCU) Develop and implement the Hazardous Products and Waste Management Plan to avoid or reduce these risks (included in the ESMF) Same timing as the ESMF (before Identify waste management procedures before the start of Project assessment) activities and ensure compliance with the agreements established between these managers and the project contractors Throughout Project implementation Ensure that the Project suppliers/contractors develop and Before the start of the sub-projects implement a Non-Hazardous and Hazardous Waste Management Plan. Before the start of the works 3.2. RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Project Coordination Unit (PCU) Ensure that contractors implement resource efficiency and pollution Before the start of the works prevention and management measures. Page 8 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY Develop and implement a Hazardous Products and Waste Management Plan to avoid or reduce these risks. Throughout Project implementation Implement the resource efficiency and pollution prevention and management measures outlined in the ESIA/ESMP. Ensure that the worksite ESMPs cover requirements and technical measures and those service providers and contractors comply with pollution management standards and measures. Before the start of the works ESS4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY Project Coordination Unit (PCU) Ensure that the Project contractors develop and implement Traffic Before the start of the works Contractors and subcontractors and Road Safety Plans, particularly a traffic plan for construction equipment as required in the ESIA/ESMP Ensure that drivers hired by the Project or the Project’s contractors comply with driving rules, which must be detailed in Traffic and Throughout Project Implementation and Road Safety Plans, particularly a traffic plan for construction construction equipment, a diversion plan that takes into account an alternative route for supply to the site, as required in the Construction Site ESMPs. 4.2 RISKS TO PUBLIC HEALTH AND SAFETY Ensure that these ESIA/EIA requirements for reducing or mitigating Project Coordination Unit (PCU) these risks and impacts are met as well as the effects related to Before the start of the works Contractors and subcontractors the implementation of Project activities on local populations and include these measures in the ESMPs to be developed pursuant to the ESMF, including those associated with the presence of Project workers and labor influx. Ensure that contractors develop and implement OHS Plans and ESMPs that include material measures and actions to manage the Throughout Project Implementation and risks and impacts to local populations associated with the construction implementation of Project activities, including those related to the presence of Project workers and labor influx and the security of the work sites project areas Page 9 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY 4.3 RISKS OF GENDER-BASED VIOLENCE, SEXUAL EXPLOITATION, AND ABUSE, AND SEXUAL HARASSMENT DURING PROJECT IMPLEMENTATION Project Coordination Unit (PCU) Prepare, adopt and Implement the stand-alone response plan for Contractors and subcontractors gender-based violence (GBV), sexual exploitation and abuse Same timing as the ESMF for the (SEA), and sexual harassment (SH), development of the plan (before Project appraisal) Have all project staff, including suppliers and contractors, sign the codes of conduct Prior to starting works Implemented throughout project implementation SECURITY STAFF Ensure, where appropriate, that suppliers or service providers who Before hiring security staff, this plan is require security services for their staff and assets can do so by: then applied throughout the Project ▪ promoting the use of existing security services in the project implementation area; ▪ ensure that a formal agreement, including clauses on Before the start of works and Throughout compliance with the code of conduct, is signed if security implementation of the Project. services are required, ▪ train security staff on safety and health measures at the worksite and SEA/SH issues Prepare, adopt and implement, as necessary, a stand-alone Before the beginning of activities security Management Plan in accordance with the requirements of ESS4 in a manner acceptable to the Bank ESS5: LAND ACQUISITION, LAND USE RESTRICTIONS AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT PLANS Prepare Resettlement Action Plans (RAPs), pursuant to the The final version of each RAP shall be Project Coordination Unit (PCU) provisions of ESS5 and in accordance with the requirements of the submitted to the Bank for review and Resettlement Policy Framework (RPF) prepared for the Project and acceptance and disclosed at the country acceptable to the Association, once the investments to be made level and on the WB website. are known and reviewed RAPs, including the implementation budget and resettlement and Before the start of works on the sub- livelihood assistance to project-affected people (PAPs), shall be projects. Page 10 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY prepared and implemented collaboratively with affected people in a satisfactory manner prior to the start of works. All RAPs must be approved by the Bank and made available at the national level and on the Bank's website. 5.2 GRIEVANCE REDRESS MECHANISM The Grievance Redress Mechanism (GRM) included in the SEP will Same timing as for the preparation of also receive and address complaints related to land the SEP Project Coordination Unit (PCU) It shall be implemented before the start of resettlement activities and shall be updated as necessary during project implementation ESS6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 RISKS AND EFFECTS ON BIODIVERSITY Implement biodiversity management measures in accordance with ESIA/EIAs including ESMPs shall be Project Coordination Unit (PCU) the ESMF and ESMP guidelines. submitted to the Association for Contractors and subcontractors approval before the start of the works Specific E&S studies shall be prepared and submitted to the procurement process Association for approval prior to issuing the consultation documents to suppliers/service providers if necessary according to the results Application of measures throughout the of the E&S screening implementation of the sub-project ESS7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not Applicable ESS8: CULTURAL HERITAGE: APPLICABLE 8.1 CHANCE FINDS PROCEDURE Establish a procedure in the ESMF in case of unexpected Project Coordination Unit (PCU) Before project appraisal discovery of cultural remains, in accordance with national Contractors and subcontractors legislation. Use the ESMF as a guide for adopting and implementing the During preparation and before the Page 11 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY/AUTHORITY unexpected findings procedure and in the ESIA/ESMPs prepared implementation of sub-projects for the Project. ESS9: FINANCIAL INTERMEDIARIES Not Applicable ESS10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 PREPARATION AND IMPLEMENTATION OF THE STAKEHOLDER ENGAGEMENT PLAN SEP to be disclosed prior to project Project Coordination Unit (PCU) Prepare, adopt and disseminate a Stakeholder Engagement Plan appraisal (SEP). Throughout Project implementation Implementing the SEP Update and re-disclose the SEP as required. 10.2 GRIEVANCE REDRESS MECHANISM AT THE PROJECT LEVEL Implement the Grievance Redress Mechanism for the entire Throughout Project implementation Project Coordination Unit (PCU) Project, as described in the SEP. This mechanism shall be adapted to address GBV/SEA/SH-related complaints in a timely (within 72 hours), confidential, ethical, non- discriminatory, and survivor-centered manner. CAPACITY BUILDING (TRAINING) Type of training to be offered Timing of training sessions Target groups Page 12 RC1 TRAINING ON ENVIRONMENTAL AND SOCIAL STANDARDS APPLICABLE TO THE PROJECT Before the start of the Project or Any worker involved in the Project • ESS1: Environmental and Social Assessment, immediately after effectiveness. Specialists in Environmental Safeguards • ESS2: Labor and Working conditions, Safeguards in Social Safeguarding • ESS3: Resource efficiency and pollution prevention and Throughout Project implementation Operational coordinator of the Project management Contractors/Control Missions • ESS4: Community Health and Safety DEEC/DRECC involved • ESS5: Land Acquisition, Land Use Restrictions, and Involuntary Resettlement • ESS6: Biodiversity conservation and sustainable management of living natural resources • ESS8: Cultural Heritage • ESS10: Stakeholder engagement and information. RC2 TRAINING ON HEALTH AND SAFETY AT WORK Training of Project workers, including contractors, on occupational Before the start of sub-projects works Any worker involved in the Project health and safety, including emergency prevention, preparedness Specialists in Environmental Safeguards and response. Safeguards in Social Safeguarding Throughout Project implementation Operational coordinator of the Project Contractors/ Control Missions DEEC/DRECC involved RC3 LABOR AND WORKING CONDITIONS Any worker involved in the Project ▪ Conditions of employment under national labor legislation Specialists in Environmental Safeguards Before the start of sub-projects works ▪ Codes of conduct for suppliers, service providers, and Safeguards in Social Safeguarding subcontractors Operational coordinator of the Project ▪ Rules on child labor and the minimum age for child Contractors/ Control Missions employment. DEEC/DRECC involved ▪ Codes of conduct for suppliers/suppliers and subcontractors, ▪ Workers’ obligations and rights. Page 13 RC4 GRM/VGB/EAS/HS Any worker involved in the Project Throughout Project implementation ▪ Procedures for recording and handling complaints, archiving Specialists in Environmental Safeguards ▪ Procedures for recording, referencing, and monitoring Safeguards in Social Safeguarding GBV/SEA/SH grievances Operational coordinator of the Project ▪ Grievance resolution procedure Contractors/ Control Missions ▪ Documenting and handling grievances DEEC/DRECC involved ▪ Use of the procedure by the various stakeholders Badiène Gox of the project intervention ▪ Raising public awareness areas ▪ Awareness, prevention, and mitigation of GBV/SEA/SH risks. Page 14