REPUBLIC OF RWANDA MINISTRY OF LOCAL GOVERNMENT LOCAL ADMINISTRATIVE ENTITIES DEVELOPMENT AGENCY (LODA) SOCIAL PROTECTION TRANSFORMATION PROJECT (SPTP) P177492 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) NEGOTATED April 2022 1 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Republic of Rwanda will implement Social Protection Transformation Project (SPTP) (P177492) (the Project) with the involvement of the Ministry of Local Government (MINALOC) and Local Administrative Entities Development Agency (LODA). The World Bank Group, hereinafter referred to as Bank, has agreed to provide financing for the Project. 2. The Republic of Rwanda shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the World Bank. The ESCP is a part of the Financing Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreement(s). 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Government of Rwanda shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted and implemented under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESS, and in form and substance, and in a manner acceptable to the World Bank. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the World Bank. 4. As agreed by the World Bank and the Government of Rwanda, this ESCP will be revised from time to time if necessary, during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to Project performance. In such circumstances, the Government of Rwanda through the Local Administrative Entities Development Agency (LODA) and the World Bank agree to update the ESCP to reflect these changes through an exchange of letters signed between the World Bank and the Government of Rwanda, Director General of the Local Administrative Entities Development Agency (LODA). The Government of Rwanda shall promptly disclose the updated ESCP. 2 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Social Protection Transformation Project (P177492) Material Measures and Actions Timeframe Responsible Entity MONITORING AND REPORTING A Regular Reporting: Quarterly report, throughout Project LODA Prepare and submit to the Bank regular monitoring reports on the environmental, social, health and safety (ESHS) implementation performance of the Project, including but not limited to the implementation of the ESCP, status of preparation and implementation of E&S documents required under the ESCP, stakeholder engagement activities and functioning of the grievance mechanism(s). The safeguards team at the District level will be reporting the status of safeguards implementation on monthly basis Monthly District safeguards through the main subprojects’ monthly progress reports submitted to LODA -SPIU. team B Incidents and Accidents: Notify the Bank within 48 hours of LODA Promptly notify the Bank of any incident or accident related to the Project which has, or is likely to have, a significant becoming aware of the incident or accident adverse effect on the environment, the affected communities, the public or workers including fatalities or impact on physical and cultural resources. A detailed investigation report and Action Provide sufficient details regarding the incident or accident, root cause analysis (RCA) and immediate measures taken on such incidents or accidents shall taken or that are planned to be taken to address it, and any information provided by the supervising entity, as be provided to the Bank within 7 days appropriate. An incident register shall be maintained at all work sites, throughout the duration of the project. Subsequently, Bank prepare a report on the incident or accident and propose any measures to prevent its recurrence as required by the Bank and national laws and regulations. C Contractors’ Monthly Reports: Social Protection Transformation Project does not intend to use contractors. It intends to use community work Not applicable approach D Notifications Relating to Dispute Avoidance and Adjudication Board (DAAB) Compliance Review of Contractor Compliance with Sexual Exploitation and Abuse (SEA), and/or Sexual Harassment (SH) Prevention and Response Obligations: Social Protection Transformation Project does not intend to use contractors. It intends to use community work Not applicable approach ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 Organizational structure: Establish and maintain an organizational structure with qualified staff and resources to support management of E&S Not later than two months after project LODA risks including both an environmental, health and safety risk management specialist, and a social risk management effectiveness specialist, responsible for managing all environmental and social safeguards responsibilities. These SPIU specialists will supervise and oversee the overall implementation of environmental and social risk management instruments and The organizational structure will be LODA ensure project compliance with National and World Bank standards on Environment and Social Framework at SPIU, maintained throughout Project District and Sector level. implementation. There will also be designated safeguards staff (Environment and Social) at District level to coordinate the Districts to designate the existing ES Districts and implementation of environmental and social risk management instruments for subprojects at the district level, and Officers and ensure the ES Officers Sectors. designated safeguard staff at Sector level (Environment and Social) who will support the district technical supervisor dedicate time to the deliverables of the in the monitoring and supervision of the safeguards implementation. Among other responsibilities, this team at the project. districts and sector levels will spearhead environmental, health, social, security and safety risk management in the Project at their respective level. 3 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Social Protection Transformation Project (P177492) Material Measures and Actions Timeframe Responsible Entity 1.2 Environment and Social Management Framework (ESMF): Prepare an Environmental and Social Management Framework (ESMF) to make it consistent with ESS1 and other Prior to effectiveness of the Project LODA relevant ESSs, as well as WBG General EHS Guidelines; Public disclosure and implementation Implement throughout the project period. 1.3 Environmental and Social Assessment: Under SPTP, unless it is required by the Bank, LODA might not need to conduct and implement the full Environmental ESMPs will be implemented throughout the LODA and Social Impact Assessment (ESIAs) for subprojects, since Rwanda Development Board (RDB), in charge of Project lifespan. issuing ESIA certificates, classified SPTP in projects that do not need ESIA certificates, and a related letter from RDB has been issued. LODA will, however, develop simplified ESA reports (proportional to the level of risks and impacts) for each subproject with the aim of identifying and assessing site-specific E&S risks and impacts, with proposed mitigation and monitoring plan of those impacts to serve as inputs to the ESMPs for subprojects in accordance with the Project ESMF, the ESSs and in a manner acceptable to the Bank. The WB team will review samples of ESMPs selected based on the level of risks and impacts of the subproject 1.4 Management tools and instruments: LODA Screen Project components and activities for E&S risks and impacts in accordance with the Environmental and Social Once prepared and cleared, tools and Management Framework (ESMF), Stakeholder Engagement Plan (SEP), Resettlement Policy Framework (RPF) and instruments apply throughout Project Labour Management Procedures (LMP) prepared for the Project, and, site specific instruments such as implementation. Environmental and Social Management Plans (ESMPs), Resettlement Action Plans (RAP), Labor Management Plans (LMP), Stakeholder Engagement Plans (SEP), will be prepared, and implemented in compliance with the ESIA / ESMP (selected based on the level requirements of the applicable Environmental and Social Standards. of risks and impacts of the subproject) shall be submitted to the Bank for approval before launching the bidding process for the respective Project component. 1.5 Management of Contractors: Since SPTP will adopt the community approach, LODA will not have contractors to deal with Not applicable. 4 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Social Protection Transformation Project (P177492) Material Measures and Actions Timeframe Responsible Entity 1.6 Permits, Approvals and Authorizations: LODA The Project design must avoid traversing ecological sensitive ecosystems National parks, Forests reserves, Parks, Monitor compliance with this obligation Protected wetlands, and buffer zone around water bodies. Given the nature of the project (SPTP), no projects will be throughout Project implementation. located in protected areas or at critical habitats such as Wetlands, LODA will not need special permits. The roads to be maintained are community roads (unclassified roads) and are not in the mandate of RTDA. If any needed permits related to water abstraction, removal of vegetation, use of borrow pits and disposal sites for construction debris is required, the project will verify appropriate legal steps followed. Unless it is required by the Bank, LODA might not need to conduct and implement the full Environmental and Social Impact Assessment (ESIAs) for subprojects, since Rwanda Development Board (RDB), in charge of issuing ESIA certificates, classified SPTP in projects that do not need ESIA certificates, and a related letter from RDB has been issued (reference 1.3 above) 1.7 Third Party Monitoring: LODA is responsible to monitor and report on implementation of the ESCP. If needed, and in consultation with the When and if required. LODA Bank, a third party will be mobilized to finalize and verify the monitoring of the environmental and social risks and impacts of the Project. The Monitoring report will be sent as part of the project Implementation Progress report. ESS 2: LABOR AND WORKING CONDITIONS 2.1 Labour Management Procedures: Prepare, disclose, and implement the Labor Management Procedures (LMP) consistently with the requirements of Prior to effectiveness, approval and LODA ESS2, including Occupational Health and Safety (OHS) measures, grievance mechanism and incorporation of GBV maintained throughout Project risk mitigation measures into the bidding documents implementation Activities to be implemented by Implementing Entities will be implemented in line with the requirements of ESS2 Project Consultants/contracted/sub-contracted staff (contracted workers, community workers and primary supply LODA workers) will be managed in accordance with Contract terms and conditions provided they are consistent with ESS2. Constitute a worker’s GRM prior to Districts Contract terms and conditions shall be assessed for their compliance with the Project labor management procedures commencement of project works and ESS2. The Project shall establish a workers’ GRM, including with elected workers’ representatives. Overall Project labor management procedures will be integrated in the Project Implementation Manual. 2.2 Grievance Redress Mechanism for Project workers: Grievance mechanism shall be MINALOC and Establish, maintain, and operate a grievance mechanism, as described in the Labour management procedures and operationalized prior to engaging Project LODA consistent with ESS2 and Rwanda Labour law workers and maintained throughout Project implementation. 2.3 Occupational Health and Safety (OHS) Measures: OHS Measures in place as part of the LODA Prepare, adopt, and implement occupational, health and safety (OHS) measures specified in the ESMP, based on ESMP before commencement of Works the general guideline in the ESMF. and enforced throughout Project implementation 5 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Social Protection Transformation Project (P177492) Material Measures and Actions Timeframe Responsible Entity 2.4 Emergency Preparedness and Response: To be approved and included in the ESMP LODA As part of the OHS measures specified in 2.3, include measures on emergency response and preparedness and prior to the bidding process if contractors ensure coordination with measures under 4.6. used, or before commencing construction of the subproject, to be implemented during project implementation ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 Management of waste and hazardous material: LODA Waste and hazardous materials will be managed in accordance with E&S documents such as ESMF/ESMPs Not later than six months from project according to ESS3 requirement. An assessment on the amount of e-waste expected under Component 3 will be effectiveness and throughout Project done during preparation and determine whether an E-Waste Management Plan will be prepared to manage the implementation electronic waste. Any hazardous materials including e-waste generated by the project will be handled and disposed of by licensed operators according to national requirements, and Good International Industry Practice (GIIP). This will be implemented through an MOU with relevant and licensed e-waste management companies. 3.2 Resource Efficiency and pollution prevention and management: LODA Resource efficiency and pollution prevention and management measures shall be covered under the ESMF prepared Prior to commencing subproject works and under 1.2 and ESMPs prepared under 1.3. maintained throughout Project implementation ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 Traffic and Road Safety: To be approved and included in the ESMP LODA Adopt and implement measures and actions to assess and manage traffic and road safety risks in the ESMPs to be prior to the bidding process, and to be developed under action 1.3 and in the site-specific traffic management plans (to be prepared as part of the ESMPs). implemented during project implementation 4.2 Community Health and Safety: To be approved and included in the ESMP Prepare and implement measures and actions in the ESMPs prepared in accordance with the ESMF, in a manner prior to the bidding process, and to be LODA acceptable to the Bank to assess and manage specific risks and impacts to the community arising from Project implemented during project implementation activities including, potential misconduct by Project workers, risks of labor influx, response to emergency situations 4.3 Gender Based Violence (GBV) and Sexual Exploitation and Abuse (SEA) Action Plan: Prepare and Not later than three months after project LODA adopt GBV/SEA/SH Action Plan proportionate to the to the risk in line with the Good Practice note on Gender effectiveness Based Violence in a manner acceptable to the Bank. The measures will include Execution of workers codes of conduct consistent with ESS2; and GBV risk specific sensitization and grievance management consistent with ESS10 and as set forth in GBV/SEA specific provisions to be included in the updated SEP (in particular the GRM and SEP budget). 4.4 GBV and SEA Risks during project implementation: Throughout Project implementation LODA The GBV Risk mitigation measures shall be operationalized, including updating the SEP, prior to starting works, and shall be implemented throughout Project implementation. The project shall implement the Project level GRM as described in the SEP which can respond to GBV (SEA/SH) cases. 4.5 Security Personnel: Given its nature, SPTP might not need a Security Management Plan. Not applicable 6 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Social Protection Transformation Project (P177492) Material Measures and Actions Timeframe Responsible Entity 4.6 Emergency Preparedness and response: To be approved and included in the ESMP LODA Develop and implement measures as part of ESMPs to address emergency events and ensure consistency with prior to the bidding process, and to be measures under 2.4 implemented during project implementation 4.7 Community Sensitization: Prior and throughout Project LODA Raise public awareness of the Project, the risks involved and the Project risk management plan through stakeholder implementation engagements, public hearings, radio talk shows and community meetings in accordance with ESS4 and ESS10. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1. Resettlement Policy Framework: Prior to effectiveness, approval and LODA Revising and updating the existing Resettlement Policy Framework (RPF) and making it consistent with ESS5 and in maintained throughout Project a manner acceptable to the Bank; implementing the RPF implementation 5.2 Resettlement Plans: The required RAPs shall be submitted for LODA SPTP does not intend to implement subprojects that involve resettlement issues. However, for unplanned the Bank’s approval prior to commencing occurrences, before carrying out activities that involve land acquisition and resettlement, LODA will prepare, adopt, Project activities that involve land and implement resettlement action plans (RAPs) in accordance with ESS5 and consistent with the requirements of acquisition and resettlement. the Resettlement Policy Framework (RPF) that has been prepared for the Project. Thereafter adopt and implement the respective RAPs. 5.3. Monitoring and Reporting: Throughout the implementation of the RAP. LODA /SPIU Ensure that monitoring and reporting on land acquisition and resettlement activities as well as on restoration of livelihoods and vulnerable households are carried out separately or are covered in regular reports. 5.4 Grievance Redress Mechanism: GRM to be established prior to LODA /Districts Establish and maintain a Grievance Redress Mechanism (GRM) to address community related complaints in commencement of any Project activities accordance with the RPF, RAP, ESMF and SEP. GRM and maintained throughout Project implementation. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 Biodiversity Risk and Impacts: LODA To be approved and included in the ESMP Screen Project activities (including public works) to avoid any significant loss or degradation of natural habitats and prior to the bidding process, or to avoid damaging any protected areas or critical habitats, in accordance with the Program ESMF and ESS6. The commencing construction of the subproject project will exclude any subprojects that will have major impacts on protected areas or critical habitats. and to be implemented during project implementation ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not applicable in the context of Rwanda ESS 8: CULTURAL HERITAGE 8.1 Chance finds To be included in the ESMP prior to the LODA Chance finds procedure shall be included in the ESMP and ESMF for the Project and implemented in accordance bidding process, and to be implemented with ESS8 and in a manner acceptable to Bank during project implementation ESS 9: FINANCIAL INTERMEDIARIES 9.1 This standard is not currently relevant to the project ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 7 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) – Social Protection Transformation Project (P177492) Material Measures and Actions Timeframe Responsible Entity 10.1 Stakeholder Engagement Plan preparation and Implementation: Before project Appraisal LODA Prepare, disclose, and implement a Stakeholder Engagement Plan (SEP) before project appraisal. The SEP shall be updated as required throughout Project implementation. Throughout Project implementation. 10.2 Project Grievance Redress Mechanism: LODA Adopt, maintain, and operate a grievance redress mechanism consistent with ESS10 and in a manner acceptable to Prior to start of implementation of activities. the Bank. Throughout Project implementation CAPACITY SUPPORT (TRAINING) CS1 PIU will be inducted on: LODA - Introduction to WB ESF (emphasis on pollution prevention and control measures, biodiversity management, During Project implementation. and on chance find procedures) This induction and subsequent capacity - Stakeholder mapping and engagement building shall cascade to the lower-level - Specific aspects of environmental and social assessment and ESMP implementation project implementation units. - Occupational Health and Safety (OHS) - Emergency preparedness and response - Community health and safety - Information on World Bank’s Safeguards Incidents Reporting requirements - Implementation of Labor Management Plans - Resettlement planning, implementation and monitoring, - livelihoods restoration, access to and use of natural resources and assets restriction, - gender and nutrition, climate and gender sensitive approaches - Risk assessment and management. - GBV and SEA/SH CS2 Project workers: Project workers will be trained on occupational health and safety including on emergency prevention and After recruitment LODA preparedness and response arrangements to emergency situations. 8