SOCIAL ENTREPRENEURSHIP, EMPOWERMENT AND COHESION IN REFUGEE AND HOST COMMUNITIES IN TURKEY PROJECT ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) January 2021 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Directorate General of Development Agencies (DGDA) of The Ministry of Industry and Technology (MoIT) will implement the Social Entrepreneurship Project (the Project), with the involvement of the following Development Agencies (covering selected project provinces): Silkroad (Gaziantep, Kilis, Adiyaman), Cukurova (Adana, Mersin), East Mediterranean (Hatay, Kahramanmaras, Osmaniye), Karacadag (Diyarbakir, Sanliurfa) and Tigris (Mardin), and the Community Implementing Partners (CIPs) which will be selected competitively for the project in order to deliver activities under Component 1. The International Bank for Reconstruction and Development (hereinafter the Bank) has agreed to provide financing for the Project as the administrator of funds under the European Union Commission Facility of Refugees in Turkey. 2. MoIT will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. MoIT will also comply with the provisions of: - Environmental and Social Management Framework (ESMF); - Labor Management Procedure (LMP); and - Stakeholder Engagement Plan (SEP). and the timelines specified in these documents. 4. MoIT is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by agency or unit referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Bank by MoIT as required by the ESCP and the conditions of the legal agreement, and the Bank will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank and MoIT, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, MoIT will agree to the changes with the Bank and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the Bank and the MoIT. The MoIT will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the MoIT shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. 2 MONITORING AND REPORTING A REGULAR REPORTING: Starting 180 days after the Effective Date of MoIT PIU. Data will be collected from Prepare and submit regular monitoring reports on the implementation the Grant Agreement and then semi- Development Agencies and through CIPs of the ESCP, environmental and social management framework, annually (every 6 months) throughout the stakeholder engagement activities, functioning of the grievance Project implementation. mechanisms (GRM). B QUARTERLY MONITORING Quarterly MoIT, Development Agencies and CIPs Maintain and monitor quarterly progress reports on the environmental, social, health and safety (ESHS) performance of the Project, including but not limited to, stakeholder engagement activities and grievances log at all sub-project sites, throughout the duration of the project. Include reporting requirements in bidding documents of CIPs 3 C INCIDENTS AND ACCIDENTS Report details of any significant MoIT, Development Agencies and CIPs Promptly notify the Bank of any incident or accident related to the environmental or social incidents (e.g. Project which has, or is likely to have, a significant adverse effect on the fatalities, lost time incidents, environment, the affected communities, the public or workers including environmental spills, occupational health but not limited to; incidents and accidents encountered during and safety issues, community health and construction works if required by sub-projects, environmental spills, etc. safety issues, community grievances and gender-based violence/harassment related Provide sufficient detail regarding the incident or accident, findings of grievances etc.) within 3 business days. the Root Cause Analysis (RCA), indicating immediate measures or Submit an incident report, including root corrective actions taken or that are planned to be taken to address it, cause analysis, precautions and compensation paid, and any information provided by any contractor compensation measures taken within 30 and supervision consultant, as appropriate. Ensure the incident report is business days. in line with the World Bank’s Environment and Social Incidence Response Toolkit (ESIRT). Subsequently, as per the Bank’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. Specify in the sub-grant manuals and sub-grant agreements that prompt notification of accidents and incidents is mandatory under Project’s ESMF. Ensure that an incident register is kept by the Development Agencies of the MoIT throughout the Project life. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 4 1.1 ORGANIZATIONAL STRUCTURE MoIT Establish and maintain a Project Implementation Unit under MoIT with qualified staff and resources to support management and monitoring of E&S risks by appointing 2 designated technical staff: Establish a PIU, including one • one environmental specialist to implement ESMF, guide environmental and one social specialist preparation and supervise implementation of site specific ESMP based on the terms of reference checklists, satisfactory to the Bank, before the • one social (stakeholder) expert/designated staff for (Grievance Effective Date of the Grant Agreement. Redress Mechanism) GRM and stakeholder engagement Retain duly staffed PIU for the duration of management and monitoring of the labor management the Project. procedures. Share the Terms of Reference for the Environmental and Social Specialists with the WB team for review and comments; Obligate DAs to assign E&S and SE/GRM focal points for management of sub-projects’ E&S risks. This obligation to be included as condition of the subsidiary agreements between MoIT and DA and subgrant agreements with municipalities/utilities. 5 1.2 MANAGEMENT TOOLS AND INSTRUMENTS MoIT and DAs Finalize and disclose and adopt, the Environmental and Social No later than 30 days after the Effective Management Framework (ESMF) for the Project, in form and substance Date of the Grant Agreement and acceptable to the Bank. maintained throughout Project implementation. MoIT and DAs Include detailed environmental and social risk mitigation measures as described, as relevant, in the ESMF/ESMPs, POM, SEP in Sub-grant manuals, and bidding documents of contractors. Before disbursement of grant proceeds for sub-grants and maintained throughout project implementation 1.3 ENVIRONMENTAL AND SOCIAL ASSESSMENT/MANAGEMENT PLANS a. Prepare ESMP Checklists before the sub- MoIT AND INSTRUMENTS/ CONTRACTORS projects, and thereafter implemented a. Assess the environmental and social risks and impacts of throughout the implementation of such proposed Project activities in accordance with ESS1 and the activities. Environmental and Social Management Framework (ESMF) to be prepared, disclosed and adopted for the Project. The ESMF will include a b. Before launching the procurement template for an Environmental and Social Management Plan Checklist process for the relevant sub-project (ESMPs) to be prepared for identified subprojects. Prepare, disclose, activities and thereafter ensure that adopt, and implement for these subprojects such ESMP Checklist contractors comply with the ESHS documents. specifications in their contracts through b. Incorporate the relevant aspects of this ESCP, including ESMP their involvement in the respective Project Checklists, ESS2 requirements, and any other required ESHS measures, activities. into the ESHS specifications of the procurement documents and contracts with contractors. Thereafter ensure that the contractors comply with the ESHS specifications of their respective contracts. ESS 2: LABOR AND WORKING CONDITIONS 6 2.1 LABOR MANAGEMENT PROCEDURES: MoIT will finalize, adopt disclose No later than 30 days after the Effective MoIT the Labor Management Procedures (LMP). LMP will include age Date of the Grant Agreement and verification procedure. maintained throughout the Project implementation 2.2 The Project shall be carried out in accordance with the applicable Throughout project implementation requirements of ESS2, in a manner acceptable to the Bank, including through, inter alia, implementing adequate occupational health and safety measures (including emergency preparedness and response measures and protection measures defined in ESMF and LMP against child labor), and incorporating labor requirements into the ESHS specifications of the procurement documents and contracts with contractors and supervising firms. 2.3 GRIEVANCE MECHANISM FOR PROJECT WORKERS: MoIT will establish No later than 30 days after the Effective MoIT and operationalize a grievance mechanism for Project workers, as Date of the Grant Agreement and described in the LMP and consistent with ESS2. The grievance maintained throughout Project mechanism will be designed in such way as to enable reporting on any implementation. cases of child and forced labour and shall be maintained for the term of the Project. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND Before commencement of any civil works MoIT and DAs MANAGEMENT: as appropriate, throughout Project Resource efficiency, including for water, electricity and pollution implementation prevention and management measures will be covered under ESMF and included in the sub-project specific ESMP as relevant. ESS 4: COMMUNITY HEALTH AND SAFETY 7 4.1 COMMUNITY HEALTH AND SAFETY: Before commencement of any civil works MoIT and DAs Ensure grant recipients to be in line with community health and safety as appropriate, throughout Project measures to be specified in the ESMF document which will be included implementation under the sub-project specific ESMPs to be prepared as relevant. 4.2 Include strict rules of engagement and code of conduct in ESMF and LMP Before commencement of any civil works MoIT and DAs and ensure that any security personnel, if any, engaged in the civil works as appropriate, throughout Project associated with the project will follow them and avoid any escalation. implementation ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 Not Relevant to the Project. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 Not Relevant to the Project ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 Not Relevant to the Project ESS 8: CULTURAL HERITAGE 8.1 Not Relevant to the Project ESS 9: FINANCIAL INTERMEDIARIES 9.1 Not Relevant to the Project ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND No later than 30 days after the Effective MoIT IMPLEMENTATION Date of the Grant Agreement and maintained throughout Project Finalize, disclose, maintain and implement SEP in a manner acceptable implementation to the Bank. 8 10.2 PROJECT GRIEVANCE MECHANISM: MoIT PIU Develop, establish, maintain and operate throughout Project Establish GRM not later than 30 days after implementation a grievance mechanism, as described in the SEP. The the Effective Date of the Grant Agreement grievance mechanism will include a channel to receive and address and implement throughout Project grievances related to sexual exploitation and abuse (SEA) and sexual duration. harassment (SH) Report semi-annually in Project progress Ensure the GRM is maintained throughout Project implementation at reports throughout Project DA and also CIP level. implementation. Throughout Project Ensure timely reporting of grievances for each sub project to MoIT. implementation Semi-annual reports the World Bank will include reporting on grievances received. 10.3 INFORMATION DISCLOSURE Throughout Project implementation MoIT PIU Ensure project information disclosure to stakeholders and Project beneficiaries in the relevant local languages and in a manner accessible and culturally appropriate, considering any specific needs of groups that may be differentially or disproportionately affected by the project or groups of the population with specific information needs. CAPACITY SUPPORT (TRAINING) 9 CS 1 As part of Subcomponent 3A, a Consolidated Training Plan, based on the During Year 1 of Project implementation. MoIT PIU Institutional Capacity Needs Assessment and Action Plan, will be developed and updated annually by MoIT PIU. The training plan will include the training topics, outputs, number and type of participants, duration, dates, required reporting, and budget. It will be adapted throughout the project to suit the emerging needs of staff and consultants engaged on the project. Specific technical trainings, including environmental and social sustainability, community engagement, vulnerable communities, forced displacement would be included as advised by the Bank’s Task Team. CS 2 PIU Staff in MOIT and the selected TDAs shall receive training by the Within 30 days after the Effective Date of MoIT PIU, Development Agencies and CIPs World Bank’s Environmental and Social Specialist’s on the World Bank’s the Grant Agreement. Environmental and Social Standards including on implementation of the Environmental and Social documents defined in this ESCP: • Environmental and Social Management Framework • Labor Management Procedures • Stakeholder Engagement Plan (Stakeholder mapping and engagement) and Citizen/community Engagement Community Implementing Partners (CIPs) selected during implementation will also receive training by MoIT’s Environmental and Social specialists on the environmental and social issues, risks and mitigation measures including community health and safety measures (ie. child labor, COVID 19 Measures and sexual exploitation and Implement on a continuous basis abuse/sexual harassment etc). TDAs together with MoIT PIU’s support throughout Project implementation and will be responsible for the monitoring and supervision of the ESCP update as needed. implementation. 10 11