INTEGRATED SAFEGUARDS DATA SHEET ADDITIONAL FINANCING Report No.: ISDSA1056 Date ISDS Prepared/Updated: 25-Nov-2014 Date ISDS Approved/Disclosed: 26-Nov-2014 I. BASIC INFORMATION 1. Basic Project Data Country: Vietnam Project ID: P148733 Parent P113493 Project ID: Project Name: NMPRP-2 Additional Financing (P148733) Parent Project Second Northern Mountains Poverty Reduction Project (P113493) Name: Task Team Lan Thi Thu Nguyen Leader: Estimated 27-Oct-2014 Estimated 14-Jan-2015 Appraisal Date: Board Date: Managing Unit: GFADR Lending Investment Project Financing Instrument: Sector(s): Agricultural extension and research (80%), Animal production (20%) Theme(s): Rural services and infrastructure (80%), Rural markets (20%) Is this project processed under OP 8.50 (Emergency Recovery) or OP No 8.00 (Rapid Response to Crises and Emergencies)? Financing (In USD Million) Total Project Cost: 110.00 Total Bank Financing: 100.00 Financing Gap: 0.00 Financing Source Amount BORROWER/RECIPIENT 10.00 International Development Association (IDA) 100.00 Total 110.00 Environmental B - Partial Assessment Category: Is this a No Repeater project? 2. Project Development Objective(s) Page 1 of 12 A. Original Project Development Objectives – Parent The development objective for the proposed project is to Enhance the living standards of the project beneficiaries by improving: (i) their access to productive infrastructures; (ii) the productive and institutional capacity of local governments and communities; and (iii) market linkages and business innovations. The key outcome indicators to assess achievement of the PDO are as follows: # At least 60% of the project beneficiaries report satisfaction on the selection, design, and implementation of project activities. # The project beneficiaries report an improvement in on- and off- farm income of at least 10% over the life of the project. B. Current Project Development Objectives – Parent C. Proposed Project Development Objectives – Additional Financing (AF) The AF focuses on institutionalizing and mainstreaming the socio-economic development planning approach in the broader planning and budget allocation processes in the project area. The PDO will, therefore, be revised to capture this important element of the AF. Project Development Objective for the AF is revised to read: The Project Development Objective (PDO) is to enhance the living standards of the Project Beneficiaries by improving: (i) their access to productive infrastructure; (ii) the productive and institutional capacity of local governments and communities; (iii) commune integrated investment planning and (iv) market linkages and business innovations. 3. Project Description The proposed AF will support deepening the project impacts and scaling up the existing project modalities to additional Communes and Districts and would contribute to their long term sustainability. The AF will give a stronger focus on supporting sustainable livelihoods of the farmers and further devolving fund and decision making power to commune level. The following summarizes the key elements and main activities of each component. Component 1: District Economic Development (about 30% of total allocated provincial project funds, equivalent to US$28.8 million). The objective of this component is to provide investment support to the District Socio-Economic Development Plans, focusing on productive and economic infrastructure for increased agriculture productivity, direct local employment and income generation, and facilitation of business innovation. This component supports specific efforts to link the supply side, namely the market and business institutions, with the poor. Component 2: Commune Development Budget (about 58% of total allocated provincial project budget, equivalent to US$55.68 million). This component will provide block grants to communes to finance small-scale sub-projects at the village level for productive infrastructure and livelihood improvement activities that are identified through participatory planning processes. Livelihood support will assist the poor with strengthening the operations of Common Interest Groups (CIGs), develop necessary skills and the further development of market linkages and ensure that women participate in and benefit from the project through targeted support to village level women’s groups. Component 3: Capacity Building and Communication (about 6% of the total project provincial allocation budget and CPO’s component, equivalent to US$6.76million). Under the AF, this Page 2 of 12 component will mostly focus on the farmers and other beneficiaries to help sustain their capacity for implementing project activities during the AF period and beyond. This component will continue to help improve the capacity of project implementation agencies at all levels, especially of the local governments and the communities to plan, manage, implement, supervise, and maintain productive infrastructure and livelihood improvement programs, communication and information sharing and learning. This component will also support the scaling up and institutionalization of the participatory local development planning through the Socio-Economic Development Plan (SEDP) planning process from Communes upward and include additional activities on “Institutional Development” to help deepen the policy dialogue between the project provinces and the GoV on poverty reduction. Component 4: Project Management (about 6% of total allocated provincial project budget and CPO’s component, equivalent to US$8.76 million). This component is to ensure effective and efficient project management through facilitation of various implementation, monitoring and evaluation (M&E), reporting, coordination, and quality enhancement efforts. 4. Project location and salient physical characteristics relevant to the safeguard analysis (if known) The project’s AF phase (from July 2015 – June 2018) continues to be implemented in 6 existing provinces of the poorest Northeast region of Vietnam, including: Lao Cai, Yen Bai, Hoa Binh, Son La, Dien Bien and Lai Chau, with 29 districts and 259 communes; in which 27 districts with 232 communes are under the NMPRP-2; 2 districts (Si Ma Cai and Bac Ha districts, Lao Cai province) with 15 communes are added to replicate sustainable livelihood support approach through the CIGs and 16 poor communes are newly added to participate in the activities under Component 2. Four communes under the current project “graduate” given their good tracked records on poverty reduction over the past four years of project implementation. The communes selected to participate in the project are those of the most difficult to reach communes. The great majority of the project beneficiaries (94 - 100%) are members of diverse ethnic minority groups each with its own culture and language. Success of the project will largely depend on their full access to project activities, and participation in identification, designing, implementation, management, and evaluation of the activities. The ethnic minorities' diversity, isolation, and language differences present challenges. Safeguards Performance under NMPRP-2: Overall the Project implementation is fully compliant with the Bank’s safeguards policies. The safeguards implementation is independently monitored by an independent agency and has been found to be satisfactory. The Project invested in small scale infrastructures in the rural and remote areas with low level of impacts on environment and social. Environmental impacts during construction include dust, noise, wastes, accident risk and disturbance and are mitigated by the ECOP which are included in the civil works contracts to be implemented by the contractors under close supervision of internal and external parties including the communities. An Environment Protection Commitment is prepared for each subproject which is reviewed and approved by the District People’s Committee before commencing the sub-project. The small infrastructures are mainly for upgrading of existing structures with already established alignment. Land acquisition, if any, for this purpose has been limited to very small scale and affected households are compensated for their losses under a Resettlement Plan reviewed and endorsed by the Bank. Ethnic minorities (EMs) in the Project areas are participating in all stages for the Project, eg. participatory planning, implementation, supervision and M&E. The Project’s benefits are culturally acceptable to the EMs and are highly appreciated by them as having tangible impacts on their lives and livelihoods. 5. Environmental and Social Safeguards Specialists Page 3 of 12 Lan Thi Thu Nguyen (GENDR) Dunia Lujan (GENDR) Khang Van Pham (GENDR) 6. Safeguard Policies Triggered? Explanation (Optional) Environmental Assessment OP/ Yes This policy is triggered due to potential sub- BP 4.01 projects’ environmental and social impacts. The NMPRP-2 AF will continue financing small scale productive infrastructures. Although the Project would have positive environmental and social impacts by improving rural road, bridges, small buildings, local irrigation systems and agriculture production, these subprojects may cause negative environmental and social impacts during the construction or implementation phase like dust, noise, affected water quality, land acquisition and human health. To ensure that the potential negative impacts of the Project are properly mitigated, and since the Project includes subprojects that are not yet been identified (due to the CDD nature of the Project) and therefore the impacts cannot be determined in a specific way, the EA instrument will be the Environment and Social Management Framework (ESMF), which lays out screening procedures for the sub-projects and includes the measures to prevent or reduce the negative impacts. The ESMF includes a set of Environmental codes of Practice (ECOP), covering prevention and mitigation measures for the mostly known impacts. Natural Habitats OP/BP 4.04 No The NMPRP-2 AF Project would not invest in any infrastructure in protected areas such as natural reserve, national parks, primary forests or wetland, because of the nature of this kind of project (CDD) and the capacity required. The policy OP/BP 4.04 is not triggered. Forests OP/BP 4.36 No The Project doesn’t affect forests. The Project will not involve any forest restoration, plantation development, changes in forest use, management or protection forest. OP/BP 4.36 is, therefore, not triggered. Pest Management OP 4.09 Yes Agriculture livelihood will benefit poor households from increasing income through application of good practices of cultivation and raising. However, agriculture livelihood may involve potential use of pesticides and fertilizers Page 4 of 12 and subsequently would cause pollution to health, air, water and soil. Hence OP 4.09 on Pest Management is triggered. The ECOP does not only include a set of guidelines on sustainable use of pesticide and fertilizers but also prohibits the use of certain pesticides specified under the Vietnam environmental regulation which was developed based on the World Health Organization's Recommended Classification of Pesticides by Hazard and Guidelines to Classification 2009. Physical Cultural Resources OP/ No Sub-projects are of very small scale and are BP 4.11 mostly upgrades of the existing structures without impacting physical cultural resources. In addition, sub-projects are selected based on a list of screening criteria which excludes those areas having potential impacts on cultural heritage. Thus OP/BP 4.11 Physical Cultural Resources don’t be triggered. Indigenous Peoples OP/BP 4.10 Yes The majority of the beneficiaries of the parent project and the AF are ethnic minorities. The Project as a whole was considered to be an Ethnic Minority Development Plan and therefore there was no need for a stand-alone instrument regarding ethnic minority issues. The following technical points were, however, incorporated in the design of the project: (i) documentation of EM’s broad community support to the project; (ii) consultation with the EMs was carried out at an early stage of project design and throughout the planning process, implementation and monitoring and evaluation; (iii) capacity building for EMs to ensure that they would meaningfully participate in and benefit from the project activities; and (iv) public information campaigns taking into account the EM’s language barriers. Involuntary Resettlement OP/BP Yes Component 1 finances the construction of small 4.12 scale village and commune infrastructure which requires the acquisition of residential or productive land, at marginal level though. The parent project has an approved Resettlement Policy Framework (RPF) which is applicable to the AF. The RPF is updated to include new districts and communes as well as latest GoV’s relevant policies. Page 5 of 12 Safety of Dams OP/BP 4.37 No The NMPRP-2 AF does not involve any activities relating to dam. Projects on International No The NMPRP-2 AF does not work in International Waterways OP/BP 7.50 Waterways. Projects in Disputed Areas OP/BP No The NMPRP-2 AF is not located in any disputed 7.60 areas. 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: OP/BP 4.01 (Environmental Assessment) – The construction, rehabilitation and maintenance works of rural roads, bridges, erosion protection and small buildings, will improve the quality of life and the safety of the community members. However during the construction, there will be in small-scale, some negative environmental impacts such as dust generation, increase noise levels, and inadequate wastes disposal affecting human health, water quality and soil quality. The social factor may be also affected due to land acquisition and loss of assets. The construction of sanitary water points in some villages including shallow wells and piped water systems will improve the health, sanitation and hygiene of the communities, although this activity could affect land for placing these elements. The construction, rehabilitation and improving the irrigation systems, not only will enhance the farmers life due to increased productivity, but also will help to reduce the expansion of upland agriculture that would degrade the catchment. The negative impacts are limited to using a small land size due to the location of the works. OP 4.09 (Pest Management) – The agricultural livelihood activities under sub-components 1.2; 2.2 and 2.3 may increase the use of pesticides and fertilizers. The increase in the use and improper handling may cause negative impacts on human health in the communes, may affect soil quality and water quality. OP/BP 4.12 (Involuntary Resettlement) – This policy was triggered due to potential land acquisition and remains applicable under the AF. The project will invest in upgrading small-scale rural infrastructures (e.g. access roads, irrigation, water supply and market) and therefore some level of land acquisition is anticipated. However, no major resettlement is foreseen and only limited land acquisition will be entailed. Experience from the NMPRP-2 confirmed that each of these small infrastructure improvements would have a low-intensive impact. OP/BP 4.10 (Indigenous Peoples) – Since the overwhelming majority of project beneficiaries are ethnic minorities (94-100%), this policy was triggered and remains applicable under the AF. However, a stand-alone Ethnic Minority Development Plan (EMDP) was not required as the entire project was considered as an EMDP. The AF will follow the same approach. 2. Describe any potential indirect and/or long term impacts due to anticipated future activities in the project area: None is expected. 3. Describe any project alternatives (if relevant) considered to help avoid or minimize adverse impacts. Page 6 of 12 To avoid or minimize the adverse impacts in this project, the ESMF considers some conditions that the subproject has meet to be selected. The conditions are: • The project would not invest subprojects in protected areas, whether there is involvement of unexploded ordnance (UXO), and potential impacts on cultural heritage. • The project would not invest in subprojects that are listed in Appendix II and III of Decree 29/2011/ND-CP, in order to ensure that the sub projects won't cause significant impacts. • The project would not invest in subprojects that are listed in Annex 3 and Annex 4 of ESMF. • The project prohibits use of pesticides banned by MARD and/or World Health Organization's Recommended Classification of Pesticides by Hazard and Guidelines to Classification 2009, listed in Annex 2 ESMF. The NMPRP-2 AF project will continue to support the rehabilitation of small rural roads including provision of adequate cross-drainage, soil compaction, gutters, surface, signing, new embankments, bridges and erosion protection. Roads will be constructed in locations where there are existing tracks, so no natural habitats or cultural/historical/burial sites will be disturbed. Land acquisition is also minimized. 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. OP/BP 4.01 (Environmental Assessment): In order to avoid and mitigate the potential impacts, an ESMF was prepared for the Parent Project in accordance with the World Bank policy requirements and National Law on Environmental Protection. The NMPRP 2- AF includes new districts and communes in 6 provinces and triggers OP 4.09 (Pest Management), so the original ESMF has been updated. The ESMF includes the environmental measures and environmental safeguards instruments that the borrower has taken to avoid or mitigate the impacts described in II.A.1, as below: • Measures for impacts due to civil works in Component 1 and 2: The ESMF elaborated for the AF includes an ECOP to address construction-related impacts, which are mostly temporary and similar in different locations, it contains guidelines on good practices in managing construction activities, The ECOP for AF includes: environmental codes applicable to most construction activities to address environmental issues like dust generation, noise impacts on communities/sensitive areas (schools/houses), soil erosion, spoil/waste disposal, pollution of water sources; degradation of water quality and health and safety, it also includes some measures in case to find Physical Cultural Resources. • If the construction will be done by sub- contractors, the ECOP will be included in the bidding documents binding the construction contractors to implement and comply with. • In case the construction will be done by the community, the ECOP should be known by the community. • In addition, the borrower has to elaborate an Environmental Protection Commitment (EPC) to address environmental and social impacts, based on the Government requirements (Article 30th, Chapter 4 of the Decree 29/2011/ND-CP and Circular 26/2011/TT-BTNMT dated July 18, 2011). OP 4.09 (Pest Management): ECOP for agricultural livelihood activities includes a set of guidelines on sustainable use of pesticides and fertilizers, including training in pest management Page 7 of 12 carried out by provincial DARD and District Agriculture Unit, the list of pesticides stores certified by the responsible agency (i.e. DARD), the guidance on proper storage and handling of pesticides and fertilizers, proper disposal of pesticide bottles and containers and an awareness raising and communication program for local people on pest management and pesticide and fertilizer handling, storage and disposal. OP/BP 4.10 (Indigenous Peoples): An iterated process of free, prior and informed consultations has demonstrated broad support for the project. During the project preparation, a large number of consultations had been carried out with the ethnic minority communities to better understand their needs and priorities. All the communes and villages under the project had organized public meetings several times to discuss about the project activities and to develop their village development plans to be supported by the project. Since the preparation of the parent project in 2009 and throughout the project implementation and preparation of the AF, several hundreds of commune meetings and thousands of village meetings had been organized with meaningful participation of EMs and women participating. As a CDD project, NMPRP-2 employs a participatory approach in which project activities are prioritized and selected by the local people through community meetings which are facilitated by well-trained Commune Facilitators, most of them are ethnic minorities themselves, coming from those communities. In compliance with the OP4.10, social assessment has been carried out to carefully review the social aspects of current project implementation and to inform the technical changes of the AF. The assessments and surveys include (i) the Livelihood Study which looked at the current livelihoods options of the ethnic minorities and their recommendation for improvements in the AF; and (ii) the Mid-Term Review and light survey which looked all project’s performance indicators including largely beneficiaries’ satisfaction on various aspects of participation, voice and decision making, gender and economic benefit. The design changes coming out from those assessments include (i) further devolution of decision making power to the commune center; (ii) support for institutionalization of the participatory planning approach at the commune level; (iii) further support to sanitation and nutrition activities given the very low indicators in these areas among the ethnic minorities; and (iii) focusing the project training activities on skill and agriculture extensions training for the ethnic minorities/ CIGs. The AF maintains the well-established communications strategy and materials that apply different and literacy appropriate media forms, community facilitation and women well- represented commune development boards, among others. The MTR and light survey of the NMPRP-2 showed that over 88% of beneficiaries reported decreased time, labor and cost of transportation which is attributable to the established rural roads invested under the project. Improved irrigation systems have helped to increase the irrigated areas to around 25%, turning the one-crop production land into two-crop land, helping to increase the overall rice outputs and reduce food insecurity among the ethnic minorities in the project areas. There are also reported impacts of reduced distance and time in water fetching, and increase amount of water for villagers. These in turn bring positive effects on health, sanitation and well- being of the project beneficiaries. M&E data shows that of all surveyed farmers’ groups (CIGs), around 78% of groups reported an increase in asset value, of which 39% reported a 200% increase in asset value (compared to the capital investment at the beginning of the first production cycle). The surveyed households expressed their satisfaction with the project’s investments as having tangible use value. OP/BP 4.12 (Involuntary Resettlement): The Government has updated the project’s Resettlement Page 8 of 12 Policy Framework (RPF) which, in accordance with OP 4.12 on Involuntary Resettlement, addresses issues relating to acquisition of land and/or other assets under the project. The final updated RPF will be approved by the Ministry of Planning and Investment and adopted by the project provinces for implementation at negotiation. The RPF presents the principles and objectives, eligibility criteria of displaced persons, modes of compensation and rehabilitation, participation features and grievance procedures that will guide the compensation and potential resettlement of affected persons. Prior to approval by local Government of the annual subproject investment plans, the provinces would review subproject designs, screening for social impacts and prepare an annual resettlement plan if subprojects involve acquisition of land and/or other assets of affected people, based on guidance stipulated in RPF. Voluntary land donation would be allowed under very specific guidelines/limitations, to be outlined in the PIM, and would be monitored closely. The Project Implementation Manual would include due diligent procedures concerning project activities involving voluntary land donations to ensure that (i) there are no legacy issues; (ii) such donations meet the Bank's criteria for voluntary land donations; i.e. that they indeed are voluntary, made without coercion and with a choice to say no; and (iii) that in cases where land donations do not meet the Bank's criteria measures are in place to fill such gaps. Given the small scale of infrastructure sub-projects under the parent project (at the averaged value of around USD80,000 – 140,000 per subproject) and of rehabilitation nature on existing alignments, impact on land and other assets was minimal. By end of June 2014, 15 annual Resettlement Plans were developed for compensation for 1,006 affected households with the total payment value of VND8,022,554,000 (USD378,000 or USD375/household on average). While the scale of subprojects under the AF remains the same as in the parent project, it is expected that the AF will even have lower impact, given that the proportion of overall funding for infrastructure investments has been reduced. Independent monitoring of safeguards implementation, capacity building for project staff at all level and information transparency were maintained throughout project implementation. The same arrangements and mechanism will apply under the AF. Borrower Capacity: Central Project Office had a considerable experience on safeguards through implementation of the parent project. A staff at CPO in charge of environmental and social safeguards will continue the task of managing and supervising safeguards implementation. There is also an experienced technical assistant team including social and environmental staff who is charged with monitoring and supervising the safeguards implementation in the field. Each participating PPMU has also appointed a position for safeguard implementation in their respective province. An independent agency was hired to monitor compliance throughout project implementation. Training will be further provided to project staff for implementing/supervising the ECOPs and RPs. 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 of the Project are: - The Ministry of Planning and Investment (MPI) - The Ministry of Finance (MOF) - The Provincial People’s Committees of 6 project provinces - The Provincial Department of Planning and Investment (DPI) of 6 project provinces and other Provincial Departments (DARD, DOF, DOIT, DONRE and Treasury) - Project District People’s Committees and Districts Sections - All project communes - Ethnic minorities in all project villages Page 9 of 12 Community assessments are the first step in both project identification and in local peoples' participation in project activities. Consistent with the Project's participatory framework, key beneficiaries, including women's groups, have participated in the first round of consultations. Inclusion of the smaller minority groups in remote and high-altitude villages is designed into consultation activities by means of outreach activities that have been established. The Project Implementation Manual (PIM) included guidelines and detailed steps for participatory planning which involve everyone in the villages. The revised ESMF and RPF in local language were disclosed to the public through MPI website and in the project sites and in English in the Bank’s InfoShop prior to appraisal. B. Disclosure Requirements Environmental Assessment/Audit/Management Plan/Other Date of receipt by the Bank 11-Oct-2014 Date of submission to InfoShop 16-Oct-2014 For category A projects, date of distributing the Executive Summary of the EA to the Executive Directors "In country" Disclosure Vietnam 16-Oct-2014 Comments: Resettlement Action Plan/Framework/Policy Process Date of receipt by the Bank 11-Oct-2014 Date of submission to InfoShop 16-Oct-2014 "In country" Disclosure Vietnam 16-Oct-2014 Comments: Indigenous Peoples Development Plan/Framework Date of receipt by the Bank 11-Oct-2014 Date of submission to InfoShop 16-Oct-2014 "In country" Disclosure Vietnam 16-Oct-2014 Comments: Since the whole project is designed to benefit IP, given the majority of project beneficiaries being ethnic minorities (94-100%), a stand-alone EMDP was not required. The OP4.10 elements have been incorporated into the project design, however. Pest Management Plan Was the document disclosed prior to appraisal? Yes Date of receipt by the Bank 11-Oct-2014 Date of submission to InfoShop 16-Oct-2014 Page 10 of 12 "In country" Disclosure Vietnam 16-Oct-2014 Comments: In response to OP 4.09, pest management is handled through the use of an Environmental Code of Practice that includes a set of guidelines on sustainable use of pesticides and fertilizers, included in the ESMF. If the project triggers the Pest Management and/or Physical Cultural Resources policies, 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 OP/BP/GP 4.01 - Environment Assessment Does the project require a stand-alone EA (including EMP) Yes [ ] No [ ] NA [ ] report? OP 4.09 - Pest Management Does the EA adequately address the pest management issues? Yes [ ] No [ ] NA [ ] Is a separate PMP required? Yes [ ] No [ ] NA [ ] If yes, has the PMP been reviewed and approved by a Yes [ ] No [ ] NA [ ] safeguards specialist or PM? Are PMP requirements included in project design?If yes, does the project team include a Pest Management Specialist? OP/BP 4.10 - Indigenous Peoples Has a separate Indigenous Peoples Plan/Planning Framework Yes [ ] No [ ] NA [ ] (as appropriate) been prepared in consultation with affected Indigenous Peoples? OP/BP 4.12 - Involuntary Resettlement Has a resettlement plan/abbreviated plan/policy framework/ Yes [ ] No [ ] NA [ ] process framework (as appropriate) been prepared? If yes, then did the Regional unit responsible for safeguards or Yes [ ] No [ ] NA [ ] Practice Manager review the plan? The World Bank Policy on Disclosure of Information Have relevant safeguard policies documents been sent to the Yes [ ] No [ ] NA [ ] World Bank's Infoshop? Have relevant documents been disclosed in-country in a public Yes [ ] No [ ] NA [ ] place in a form and language that are understandable and accessible to project-affected groups and local NGOs? All Safeguard Policies Have satisfactory calendar, budget and clear institutional Yes [ ] No [ ] NA [ ] responsibilities been prepared for the implementation of measures related to safeguard policies? Have costs related to safeguard policy measures been included Yes [ ] No [ ] NA [ ] in the project cost? Page 11 of 12 Does the Monitoring and Evaluation system of the project Yes [ ] No [ ] NA [ ] include the monitoring of safeguard impacts and measures related to safeguard policies? Have satisfactory implementation arrangements been agreed Yes [ ] No [ ] NA [ ] with the borrower and the same been adequately reflected in the project legal documents? III. APPROVALS Task Team Leader: Name: Lan Thi Thu Nguyen Approved By Practice Manager/ Name: Nathan M. Belete (PMGR) Date: 26-Nov-2014 Manager: Page 12 of 12