Page 1 INTEGRATED SAFEGUARDS DATASHEET APPRAISAL STAGE I. Basic Information Date prepared/updated: 09/14/2010 Report No.: AC5519 1. Basic Project Data Country: Bangladesh Project ID: P118701 Project Name: Employment Generation Program for the Poorest Task Team Leader: Maitreyi Das Estimated Appraisal Date: July 15, 2010 Estimated Board Date: September 30, 2010 Managing Unit: SASSP Lending Instrument: Specific Investment Loan Sector: Public administration- Other social services (100%) Theme: Social safety nets (70%);Improving labor markets (30%) IBRD Amount (US$m.): 0.00 IDA Amount (US$m.): 150.00 GEF Amount (US$m.): 0.00 PCF Amount (US$m.): 0.00 Other financing amounts by source: BORROWER/RECIPIENT 0.00 0.00 Environmental Category: B - Partial Assessment Simplified Processing Simple [] Repeater [] Is this project processed under OP 8.50 (Emergency Recovery) or OP 8.00 (Rapid Response to Crises and Emergencies) Yes [ ] No [ ] 2. Project Objectives The Employment Generation program for the Poorest (EGPP) provides short-term employment to manual workers during the lean season over two phases that add up to 100 days in a year. The first cycle runs from October to December providing 60 days of employment and the second cycle runs from March to May providing 40 days of employment. Wages are meant to be set below the prevailing market wage for unskilled manual workers and this contributes to self-selection of the poorest households into the program. The Project is envisaged as a programmatic investment loan to the Government of Bangladesh's existing safety net program of the same name. Support to the EGPP is envisaged as credit from the International Development Association (IDA) through a programmatic Specific Investment Loan (SIL). Disbursements will be linked to a set of outcome indicators. This mechanism will foster a number of innovations, in addition to rewarding efficiency. In the wake of the announcement of the Budget of 2010-11, there has been a great deal of discussion about lacking implementation of development programs as an important constraint to poverty reduction. In response IDA will support an operational support component that will assist with the design and implementation of the EGGP, ensuring results in this project and building the implementation capacity of the government as it engages in other programs. Page 2 The project development objective is to provide short-term employment on community projects to enable households to better cope with vulnerability, while strengthening Program implementation capacity of the government. The PDO will be achieved by 1) ensuring that the program benefits are targeted to the poorest areas and households; 2) improving governance through better transparency and accountability; and 3) improving capacity for monitoring and evaluation. Overall, if the same level of allocation to the program is maintained as for the FY10-11 and there is the same level of interest in the program, it is expected that the program will reach 2 million individuals and create 200 million person days of employment over the three years of the project. IDA will finance up to 70 percent of wage costs to a maximum of 144.75 million USD over the three year period (FY11-13). Disbursements are linked to results achieved. There is also a provision for retroactive financing for FY 10 during which period the IDA preparation team and the GOB's Technical Team had come to agreements on changes that have already been made to the Program. In addition, 5.25 million USD will be earmarked for technical and operational support through a separate window (Component 2 below). This technical support will go towards capacity enhancement to enable the GOB to achieve the results that were agreed upon. In the upcoming financial year, about 35 percent of the overall cost of the GOB's EGPP is expected to come from IDA financing. 3. Project Description The project has two components - a Main Program Component (MPC) and on Operational Support Component (OSC). The MPC can be viewed as a component that reimburses the GOB for results, while the OSC can be seen as a financing instrument for the inputs needed to achieve the results indicated in the MPC. Component 1: The Main Program Component (MPC) (US$ 144.75 million) would support expansion and reform of the existing program through three Focus Areas: Focus Area 1: Rigorous Targeting. Reaching the poorest is the cornerstone of the EGPP. This includes both the poorest areas and the poorest households. There is a three- fold targeting methodology in the program. - Geographical or area based targeting based on the poverty map, where the bulk of resources go to the poorest Upazilas; - Household targeting: o Filter 1: The first filter that will ensure the participation of the poorest is the setting of wages. The current wage of Tk. 120 per day is below the prevailing market wage in most areas, ensuring that only the poorest enrol for the program. The program will ensure that wages are set below the prevailing market wage so that the program is not attractive to the non-poor households. Page 3 o Filter 2: The second filter is a proxy for household poverty -individuals from those households where the head is a manual laborer and the household has les s than ½ acre of land will be eligible; - Gender targeting where 33 percent of the beneficiaries are intended to be women during the course of the project period. Focus Area 2: Improved governance through clearer rules and enhanced transparency Clarity and accessibility of rules and procedures: Program rules are currently quite generic and many field level functionaries are unaware of the changes to rules and procedures. The project therefore proposes a set of results that require changes to the program document and for the revised rules and procedures to be publicly available at the lowest levels. Information and public disclosure: Community notice boards will be mandated under the project. PICs and Union Committees would also be required to make selection criteria and beneficiary lists publicly available. Adherence to this provision would be monitored through spot checks and process assessments conducted under Focus Area 3 of the project. Provision of non-wage costs: The current EGPP does not have provision for costs associated with the purchase of materials, hardware or skilled labor. During the project period, guidelines will be issued to earmark up to 30 percent of the cost of each subproject under EGPP for use to purchase materials and skilled labor, in keeping with global practice. For most infrastructure projects at least 10 percent of the cost would be mandated for materials and other non-wage costs. Finally, while IDA will reimburse only wage costs, the inclusion of non-wage costs in the GOB's program will be an important result which will be linked to disbursement. Better system for payment of wages: Currently workers on EGPP are paid through cash transactions on a weekly basis by the PIC. If payments are made directly to workers it would significantly reduce the fiduciary risk on the one hand and empower the poorest on the other. The project will finance the sequenced roll out of wage payments through formal channels like banking and innovative pilots as well. Enhanced capacity at the field level for better monitoring: Current capacity for monitoring the EGPP is very limited and this creates conditions for potential malpractice. IDA support to the EGPP therefore provides for field level supervisors in the poorest 334 Upazilas. Moreover, upazila level PIOs and the new field level supervisors will be provided with transport in the form of a motorcycle for each of the poorest 334 upazilas. The financing for staff and transport costs will be through the Operational Support Window. In addition, while not a disbursement indicator, there is also provision for training of the field supervisors and PIOs. Grievance redress: The project will also support the development of an enhanced grievance redress system. The first point of acceptance of complaints is proposed to be the Upazila. However, complaints can be accepted at any of the three levels -Upazila, Page 4 District or the Ministry. At the Upazila level, the Upazila Nirbahi Officer (UNO) will be the Grievance Redress Officer (GRO). At the district level, the Deputy Commissioner (DC) will serve as the GRO. The Deputy Project Director (DPD) in the office of the Project Director will act as the GRO at the central level. Focus Area 3: Better Capacity for Monitoring and Evaluation The project would support the development of a set of standardized summary indicators and monitoring reports and would provide financing for critical staffing at the central and local levels and investments in ICT. Streamlined data collection and flow: The project will support the redesign of existing monitoring forms and reports to facilitate monitoring on inputs, outputs, intermediate outcomes and compliance with program guidelines. Data on a set of streamlined indicators will be collected at the sub-project level. In order to ensure that the data collected is available for use in real-time decision-making, a number of institutional and technical enhancements would be made under focus area three of the project. The project would provide ICT (in the form of computers and data entry clerks) at the upazila or district level, as well as modems so that information can be transferred electronically from the local level directly to the center. Additional support and training would also be provided to the monitoring cell in the Project Director's Office. Resources would also be provided to allow for greater supervision at the project level. Monitoring of project implementation at the local level would be strengthened by providing for contractual hires of staff and access to transport to support the PIOs and Tag Officers at the upazila level (discussed in Focus Area 2 above). Independent assessments: The independent assessments would aim to provide information on program implementation, the effectiveness of targeting and the impact of the program on household net incomes and coping strategies in response to shocks. Assessments would include both external spot checks and an impact assessment based on surveys of beneficiary and non-beneficiary households. External spot checks would be conducted in a random sample of approximately three percent of union parishads each program cycle. The spot checks would examine whether program implementation guidelines are followed and whether program benefits reach the intended beneficiaries. Impact evaluation: In order to assess the impact of the program for participants, the World Bank would also partner with a reputable local survey firm to undertake baseline and follow-up surveys of program participants and non-participants in a representative sample of upazilas. Program outcomes, including targeting performance, leakage rates, and the net income gains to participating households, will be identified using several analytical techniques. Qualitative assessments: To complement the quantitative work, beneficiary and non- beneficiary assessments would be conducted. This work would examine how well the program is working, including perceptions of targeting, of leakages/corruption, the quality of works produced under the EGPP, the value of the infrastructure projects (both Page 5 to participants and to non-participants), and impacts of the program on internal and external migration as well as on social empowerment. The independent assessments under this focus area would not be funded out of the project OSW. Trust fund and external resources from development partners are currently being sought to finance both the spot checks and the evaluation work. II. Operational Support Component (OSC) Component 2: The Operational Support Component (OSC) (US$ 5.25 million) would provide direct support to the MOFDM for implementation support and capacity strengthening to deliver the EGPP with enhanced efficiency through better targeting, a better benefit delivery mechanism, greater transparency and improved monitoring. Specifically it will: i. Strengthen reporting and monitoring of the EGPP operations ii. Provide training to staff engaged in EGPP to enhance their capacity in targeting beneficiaries and delivering benefits Expected outputs: - Services of financial management and procurement personnel availed. - Services of Field Supervisors are availed. - Digitalized reporting, monitoring and supervision system is established. - Transport facility for the Field Supervisors provided. - Systematic targeting methodology is established. - Training is provided for beneficiary targeting and enrolment process. - A team of Government officials will have received exposure to global best practices. - The Ministry's overall capacity to deliver quality social protection projects is improved. 4. Project Location and salient physical characteristics relevant to the safeguard analysis In terms of coverage, EGPP will be implemented nation-wide targeting the poorest upazilas (sub-districts) of Bangladesh. Currently, the following allocation system is in place: i) 40% of the budget to the 81 upazilas with extreme poverty rates of 40% and higher; ii) 40% of the budget to the 254 upazilas with extreme poverty rates of 21-39%, and iii) 20% of the budget to the 146 upazilas with extreme poverty rates of 20% and below. The exact locations of the sub-project will be identified by the Union Parishad Project Implementation Committee (UP-PIC) during the selection of projects in consultation with community and ward members during EGPP implementation. 5. Environmental and Social Safeguards Specialists Mr Shakil Ahmed Ferdausi (SASDI) Mr Fabio Pittaluga (LCSSO) Ms Sabah Moyeen (SASDS) Page 6 6. Safeguard Policies Triggered Yes No Environmental Assessment (OP/BP 4.01) X Natural Habitats (OP/BP 4.04) X Forests (OP/BP 4.36) X Pest Management (OP 4.09) X Physical Cultural Resources (OP/BP 4.11) X Indigenous Peoples (OP/BP 4.10) X Involuntary Resettlement (OP/BP 4.12) X Safety of Dams (OP/BP 4.37) X Projects on International Waterways (OP/BP 7.50) X Projects in Disputed Areas (OP/BP 7.60) X II. Key Safeguard Policy Issues and Their Management A. Summary of Key Safeguard Issues 1. Describe any safeguard issues and impacts associated with the proposed project. Identify and describe any potential large scale, significant and/or irreversible impacts: The project does not envisage any large scale, significant or irreversible environmental impact due to the small scale interventions and community managed projects. The project was reviewed and screened during preparation and designated as environmental Category B which is appropriate and consistent with the provisions of OP/BP 4.01, as the project is a community-driven development operation, involving local level, demand-driven small infrastructure and income generation sub-projects. The project will support mainly the earthworks which will help the agriculture productivity, better rural communication, protection during natural disaster etc. Despite the use of the term #earthworks#, the vast majority of EGPP sub-projects are extremely small in scale, and will be implemented by poor manual laborers. The subprojects include: i) canal excavating/re-excavating, ii) earth dam construction/re-construction, iii) rural road construction/re-construction, iii) drain construction/re-construction to address water logging, iv) land filling of community institutions like schools, graveyard, prayer ground etc., v) earthen shelter for animals to project against cyclone, vi)excavation of public ponds/fish firms, vii) organic fertilizer production for agriculture application, viii) further development (height increase) of market/helipad, and ix) water reservoirs construction for rainwater conservation/drinking water. IDA will finance the wage cost of the sub-projects. The project is expected to bring specific environmental benefits through improved localized drainage systems, introducing organic soil fertilizer, water conservation, increased vegetation cover, and orientation of government and project staffs in environmental issues and better practices. However, environmentally benign projects do have the capacity for inflicting environmental damage if not properly designed or inadequately followed up with training and awareness activities. Page 7 Sub-projects are expected to be very small and intended to provide employment to poor people for brief spells of time (60 days and then 40 days in the year); hence no major social issues including significant land acquisition and displacement are expected. However, in case any sub- projects require small land acquisition or encounter encroachers and squatters who would be displaced due to project works, the project has hence triggered safeguards policy on involuntary resettlement (OP4.12). Additionally, given the nation-wide approach that the project is based on, it is probable that the project will touch upon areas with indigenous people (IPs), thereby triggering safeguards policy Indigenous Peoples (OP 4.10). 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: The communities in the project area are likely to be benefited under the project with the improved access to small-scale infrastructure at local levels and increased income generating activities. The adverse environmental impacts of the project are likely to be minimal, owing to the small-scale nature of community-implemented subprojects. The localized and temporary environmental impacts can be managed through the proper implementation of the Environmental Management Framework (EMF). No long term and indirect adverse environmental and social impacts are anticipated due to project activities. Nonetheless, actual impacts would depend on the project activities actually selected, i.e. the subproject types or scheme types. The Social Management Framework (SMF) will have provisions for screening of any potential indirect or long- term adverse impacts and taking necessary mitigation measures to ensure minimal impacts. A Social Management Framework (SMF) will be put together which will include a Resettlement Policy Framework and Indigenous Peoples Planning Framework. Additionally, it will contain check-lists to demonstrate whether project activities at specific sites will trigger the necessity of producing SIAs and RAPs in keeping with the approach adopted for this project. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. The project builds on an existing GOB Project, also called EGPP. One of the objectives of the World Bank support is to bring the technical expertise so that the project can garner to generate far-reaching reforms in the design and implementation of one of the country's largest safety net programs. In particular, it has taken note of the vulnerability of safety nets programs to poor governance and to potential leakage of funds. At the broader aspects, no alternative analysis was carried out on environmental and social safeguard perspective. However, while identifying the subprojects, alternative options will be considered from environmental and social perspective. The implementing agency will use the screening procedures outlined in the SMF to identify, assess, evaluate, mitigate and monitor social impacts of each sub projects. The SMF will indicate all actions needed and processes required for implementing the safeguards approach for the project. This will include: Page 8 - Resettlement Policy Framework, and an Indigenous Peoples Framework indicating the key principles to follow during implementation - A check-list to identify possible impacts related to either land acquisition, resettlement or the presence of IPs in the project areas - Guidance on how to implement the approach described above in line with the nature and scale of impacts - A detailed process for audits and Third Party monitoring, including Terms of Reference for the latter agency - The Terms of Reference for the "mobile M&E" team 4. Describe measures taken by the borrower to address safeguard policy issues. Provide an assessment of borrower capacity to plan and implement the measures described. The activities to be supported by the EGPP cannot be precisely identified ahead of time and according environmental assessment was not possible at this stage. An Environmental Management Framework (EMF) has been developed for the project. The implementation experiences of Social Investment Program Project (SIPP) and Local Governance Support Project (LGSP) have been reviewed and the findings are used in preparing the EMF of the EGPP. A simplified approach has been adopted in the EMF to ensure integration of environmental issues with these small scale sub-projects identified and implemented at grass-root level. All the subprojects will necessarily be screened based on the requirements of the EMF prior to sanctioning. The EMF prescribes the environmental management parameters to be included in the project monitoring and evaluation plan, and environmental audits to periodically evaluate the adequacy of the EMF and to modify it as required. It is recommended to conduct a supplemental study to explore options for project-supported activities that would enhance the capacity of the local communities for adaptation and living intelligently with disasters. The implementing agency and other stakeholders of the project have limited or no experience on environmental assessment and management. However, considering the project's objective to create emergency employment generation of the rural poorest segment of people, the capacity building initiative will be limited to the EMF implementation. The project staffs will receive briefing on EMF during their orientation for project implementation. A Social Management Framework has been prepared, that includes a Resettlement Policy Framework and an Indigenous People's Planning Framework. This will be disclosed before Negotiations.. Given the very large number and nature of sub-projects (up to 37000 or more) to be implemented within the project duration, analyzing and clearing each sub-project would be an insurmountable challenge. The Social Management Framework (SMF) approach is suggested to comply with World Bank policies and at the same time consider the practical aspects of their implementation. The implementing agency will use the screening procedures outlined in the SMF to identify, assess, evaluate, mitigate and monitor social impacts of each sub projects. These procedures include the following key points: Page 9 1. No major adverse social impact is expected to ensue from the project activities, and in fact the social impacts are expected to be salutary. Sub-projects are intended to be very small scale and implemented over brief spells to protect the poorest. No private land acquisition is expected to take place under the Program. Since most sub-projects will be carried out in rural settings where squatters are not widely found, no large-scale displacement is expected. Due to very large number and nature of sub-projects (up to 37,000 or more) to be implemented within the project period, the MOFDM will use the screening procedures outlined in the SMF to identify, assess, evaluate, mitigate and monitor social impacts of each sub-project. These procedures include the following key points. a. The Project Implementing Officers (PIOs) will be responsible to screen all of their sub-projects using a check-list to identify possible social impacts related to either land acquisition resettlement or the presence of IPs in the project areas; b. No involuntary land acquisition is anticipated under the project. If small quantities of land are at all required for some sub-projects (though this is unlikely), it may be acquired on a voluntary basis on willing buyer-willing seller terms where permissible. All land transactions will be recorded. A review of sub-projects implemented under the previous EGPP programs shows that private land acquisition has never been triggered; since the nature and scale of the projects will remain the same as before, no land acquisition is anticipated for this project. Therefore, World Bank policy on involuntary resettlement is not likely to be triggered on grounds of private land acquisition. However, in case private land acquisition becomes essential in any given situation, all consultation and compensation will be carried out in accordance with the National Ordinance on Land Acquisitions and Requisition 1982, and World Bank OP 4.12 on Involuntary Resettlement. The RPF provides guidelines to comply with both processes. c. Although no land acquisition or significant displacement of squatters is anticipated under this project (as most projects will take place in rural settings where squatters are not widely found), if the sub-projects trigger land acquisition and /or are expected to impact squatters or economically displace less than fifty families, an Abbreviated Resettlement Plan (RP) will be prepared by the implementing agency using the procedures and guidelines outlined in this SMF. For sub-projects that trigger the displacement of more than fifty families, a brief Social Impact Assessment will also be carried out, based on which a more detailed RP will be produced. The implementing agency may hire specialist consultants to assist the PIO in preparing the RP, which will be cleared by the PD's office. d. For projects that only affect small numbers of squatters on public land (e.g. less than 50 families), PIOs will be responsible to ensure compliance with the Bank policies (incorporated in the Resettlement Policy Framework) including producing the RP and keeping records of actions undertaken. It is expected that the vast majority of sub-projects will fall in this category. The Bank will sponsor an independent verification and validation study by a third party monitoring agency via a random audit based on a sample of projects to ensure that adequate safeguards were in place, in line with the provisions of the SMF. e. In addition to the above, for sub-projects that are expected to economically or physically displace more than 50 families a brief SIA will be carried out based on which Page 10 the RP will be produced. For this batch of projects as well as those involving impacts on Indigenous People a third-Party audit will be undertaken to assess compliance with the requirements. The PIO will be responsible for carrying out implementation of the RPF. The Bank will review the results of the audits and conduct spot-checks on a sample basis. f. During the periods of the employment generation scheme implementation, a "mobile M&E" team will be employed to support capacity building and assist with implementation of safeguards mitigation plans. The M&E team can be staffed with project personnel and/or external consultants as needed. The SMF will indicate all actions needed and processes required for implementing the safeguards approach described above. This will include (i) key principles to follow during implementation; (ii) a check-list to identify possible impacts related to land acquisition, resettlement or the presence of IPs in the project areas; (iii) guidance on how to implement the approach in line with the nature and scale of impacts; (iv) a detailed process for audits. The implementing agencies have been implementing the GOB's EGPP since the last fiscal year. The Bank will provide capacity building by refining their monitoring strategy for the EGPP and would provide support to develop the monitoring capacity of the MoFDM at the upazila level and at the Center. The project will also provide operational support to the Disaster Management and Relief Division, Ministry of Food and Disaster Management in delivering EGPP with enhanced efficiency in terms of better targeting, better benefit delivery mechanism, greater transparency and improved monitoring. The project will also support the development of an enhanced grievance redress system. 5. Identify the key stakeholders and describe the mechanisms for consultation and disclosure on safeguard policies, with an emphasis on potentially affected people. The key stakeholders in the project are those who will benefit from the employment generation schemes, those who may be adversely impacted due to the implementation of the schemes under the project. The EMF and S/RPF have been prepared in consultation with the local communities, NGOs and government officials/agencies. The subproject specific EA (environmental screening and/or assessment) and SIA will also be prepared in consultation with affected communities and the draft will again be consulted with communities and NGOs. EAs and SIA/RAPs will also be published in the website for public information and comments. The communities are expected to directly participate in the identification, review and implementation of the subprojects. B. Disclosure Requirements Date Environmental Assessment/Audit/Management Plan/Other: Was the document disclosed prior to appraisal? No Date of receipt by the Bank 08/08/2010 Date of "in-country" disclosure 08/31/2010 Date of submission to InfoShop 09/02/2010 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors Page 11 Resettlement Action Plan/Framework/Policy Process: Was the document disclosed prior to appraisal? No Date of receipt by the Bank 08/08/2010 Date of "in-country" disclosure 08/31/2010 Date of submission to InfoShop 09/02/2010 Indigenous Peoples Plan/Planning Framework: Was the document disclosed prior to appraisal? No Date of receipt by the Bank 08/08/2010 Date of "in-country" disclosure 08/31/2010 Date of submission to InfoShop 09/02/2010 Pest Management Plan: Was the document disclosed prior to appraisal? Date of receipt by the Bank Date of "in-country" disclosure Date of submission to InfoShop * If the project triggers the Pest Management and/or Physical Cultural Resources, the respective issues are to be addressed and disclosed as part of the Environmental Assessment/Audit/or EMP. If in-country disclosure of any of the above documents is not expected, please explain why: C. Compliance Monitoring Indicators at the Corporate Level (to be filled in when the ISDS is finalized by the project decision meeting) OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) report? Yes If yes, then did the Regional Environment Unit or Sector Manager (SM) review and approve the EA report? Yes Are the cost and the accountabilities for the EMP incorporated in the credit/loan? Yes OP/BP 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework (as appropriate) been prepared in consultation with affected Indigenous Peoples? N/A If yes, then did the Regional unit responsible for safeguards or Sector Manager review the plan? N/A If the whole project is designed to benefit IP, has the design been reviewed and approved by the Regional Social Development Unit or Sector Manager? N/A OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/process framework (as appropriate) been prepared? Yes If yes, then did the Regional unit responsible for safeguards or Sector Manager review the plan? Yes The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the World Bank's Yes Page 12 Infoshop? Have relevant documents been disclosed in-country in a public place in a form and language that are understandable and accessible to project-affected groups and local NGOs? Yes All Safeguard Policies Have satisfactory calendar, budget and clear institutional responsibilities been prepared for the implementation of measures related to safeguard policies? Yes Have costs related to safeguard policy measures been included in the project cost? Does the Monitoring and Evaluation system of the project include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed with the borrower and the same been adequately reflected in the project legal documents? D. Approvals Signed and submitted by: Name Date Task Team Leader: Ms Maitreyi Das 07/12/2010 Environmental Specialist: Mr Shakil Ahmed Ferdausi 07/12/2010 Social Development Specialist Ms Sabah Moyeen 07/12/2010 Additional Environmental and/or Social Development Specialist(s): Mr Fabio Pittaluga 07/12/2010 Approved by: Regional Safeguards Coordinator: Mr Sanjay Srivastava 08/19/2010 Comments: Sector Manager: Ms Mansoora Rashid 07/12/2010 Comments: