THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) THE LEBANESE REPUBLIC KAFALAT S.A.L. BUILDING BEIRUT BUSINESSES BACK & BETTER (B5) FUND PROJECT ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) June 10, 2021 1|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) KAFALAT S.A.L. BUILDING BEIRUT BUSINESSES BACK AND BETTER B5 FUND ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. KAFALAT SAL (hereinafter the Recipient) shall implement the Building Beirut Businesses Back and Better Fund Project (B5 Project), (the Project). The International Bank for Reconstruction and Development and International Development Association (hereinafter the Bank) has agreed to provide financing for the Project. 2. The Recipient shall implement material measures and actions so that the Project is implemented in accordance with the World Bank Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, institutional, staffing, training, monitoring and reporting arrangements, grievance management and the environmental and social assessments and instruments to be prepared or updated, disclosed, consulted, adopted and implemented under the ESCP and the ESSs, all in a manner acceptable to the Bank. 3. The Recipient shall also comply with the provisions of any other E&S instruments required under the Environmental and Social Framework (ESF) and referred to in this ESCP, such as the Environmental and Social Management System (ESMS) with framework approach, the Labor Management Procedures (LMP) and the Stakeholders Engagement Plan (SEP). 4. KAFALAT SAL is responsible for compliance with all requirements of the ESCP and shall monitor the implementation of specific measures and actions conducted by other institutions, including Micro Finance Institutions (MFIs) which are both participating financial intermediaries and beneficiaries and Micro and Small Enterprises (MSEs) which are only beneficiaries. 5. Implementation of the material measures and actions set out in this ESCP shall be monitored and reported to the Bank by KAFALAT SAL as required by the ESCP and the conditions of the Grant Agreement, and the Bank shall monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Bank and KAFALAT SAL, 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, KAFALAT SAL shall agree to the changes with the Bank and shall update the ESCP to reflect such changes. Agreement on changes to the ESCP shall be documented through the exchange of letters signed between the Bank and KAFALAT SAL. KAFALAT SAL shall 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 Recipient shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include environmental, health, and safety impacts, COVID-19 transmission risks, and gender-based violence. 2|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY MONITORING AND REPORTING A REGULAR REPORTING: The Recipient through the Project Management Unit (PMU) shall Starting from the Effective Date, Responsibility: Kafalat SAL, PMU prepare and submit regular monitoring reports to the Bank on reporting every 6 months throughout Environmental & Social Specialist. environmental, social, health and safety (ESHS) performance of the Project implementation. Reports to the Project and sub-projects, including but not limited to the be sent within 15 days after the preparation of the E&S documents required under the ESCP, reporting period ends. stakeholder engagement activities, and functioning of the grievance mechanism, including but not limited to grievance logs from workers and MSEs. FINANCIAL INTERMEDIARIES REPORTS Participating FIs shall be required to Responsibility: Kafalat SAL, PMU KAFALAT SAL shall request FIs to prepare and submit reports on furnish to KAFALAT SAL each progress Environmental & Social Specialist, and ESHS performance of subprojects supported under Part 1 of the report not later than 30 days after each participating financial intermediaries. Project, including the operation of their respective ESMS, quarter starting from the Effective according to the format set forth in the POM. Date. These reports shall be provided to the Bank, at the request of the Bank. 3|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY B INCIDENTS AND ACCIDENTS NOTIFICATION: 1- KAFALAT SAL shall promptly notify the Bank of any incident or Report any incident or accident to the Responsibility: Kafalat SAL, PMU accident related the Project and sub-projects which has, or is Bank within 48 hours after becoming Environmental & Social Specialist, and likely to have, a significant adverse effect on the aware of the occurrence of the incident participating financial intermediaries. environment, the affected communities, the public or or accident. workers including but not limited to: • Occupational Health and Safety Issues • COVID19 pandemic infection • GBV, exploitation, discrimination, unresolved grievances 2- Provide sufficient details regarding the incident or accident, A report would be provided within 10 how it occurred, indicating immediate measures taken or days of the initial notification to the that are planned to address it, and include information Bank, as requested. provided by any contractor and supervising entity, as appropriate. File a closure report within 30 days or 3- Subsequently, as per the Bank request, in addition to the agreed time frame, as per the Bank’s initial notification, a report shall be prepared and submitted request. to the Bank on the incident or accident investigation and propose any measures to prevent its recurrence. Notification/reporting requirements 4- KAFALAT SAL shall request Participating FIs to report any incident or shall be in place throughout the Project accident that occur in subprojects financed under the Project. The implementation. report shall be prepared with the minimum requirements set forth in the POM. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 4|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 1.1 ORGANIZATIONAL STRUCTURE: KAFALAT SAL shall establish and maintain, throughout the Project An environmental and social (E&S) KAFALAT SAL and PMU Coordinator implementation, an organizational structure (PMU) including an specialist was nominated in the environmental and social risks and impacts management function interim, i.e. during the hiring process of with qualified staff and adequate resources to support the E&S specialist prior to carrying out management of environmental, social, health and safety (ESHS) Project activities. E&S specialist shall be risks and impacts of the Project, all with composition, mandate, hired within 30 days of the Effective and resources, and terms of reference satisfactory to the Bank. Date and shall be maintained throughout Project implementation. This organizational structure shall include an environmental and social (E&S) specialist to be nominated in the interim, i.e. during A draft organizational structure has the hiring process of the E&S specialist. been prepared and shall be finalized before commencement of Project KAFALAT SAL shall require that each Participating FI designate a activities by Effective Date. senior representative to assume overall responsibility for coordinating the management of the environmental and social aspects of the subprojects supported under the Project, and an environmental and social specialist responsible for the day-to-day implementation of the ESMS. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT: Update, disclose, consult upon, adopt, and implement the The Bank-cleared ESMS with Responsibility: KAFALAT SAL PMU – Environmental and Social Management System (ESMS) with framework approach was disclosed on Environmental & Social Specialist framework approach, consistent with the requirements of ESS1 June 11th, 2021. and ESS9 and in a manner acceptable to the Bank. KAFALAT SAL shall ensure the implementation of the ESMS which shall be The ESMS with framework approach amended and updated as required during the Project shall be updated where required and implementation if unforeseen changes to risks and impacts or implemented throughout project changes to project design take place in consultation with Project implementation Stakeholders. 5|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 1.3 MANAGEMENT TOOLS AND INSTRUMENTS: KAFALAT SAL shall incorporate the relevant aspects of the ESCP, As required throughout project Responsibility: KAFALAT SAL including the relevant E&S documents and/or plans, and the implementation Labor Management Procedures into the ESHS specifications of PMU Team and Environmental the procurement documents and contracts with contractors, and Social Specialist supervising firms as well as subsidiary and sub-grant agreements Vendors and participating financial with the Microfinance Institutions (MFIs) and Micro and Small intermediaries. Enterprises (MSEs). Thereafter ensure that the contractors, supervising firms, MSEs, and MFIs comply with the ESHS specifications of their respective contracts. 1.4 EXCLUSION: Exclude the following types of activities as ineligible for financing During the assessment process conducted Responsibility: KAFALAT SAL and under the Project: under action 1.2. above and during participating financial intermediaries. implementation. • Activities that may cause long term, permanent and/or irreversible adverse impacts (e.g. loss of major natural habitat). • Activities that may have significant adverse social impacts and may give rise to significant social conflict. • Activities that may affect lands or vulnerable minorities. • Activities, including new constructions or expansions, that may involve, physical and economic displacement or adverse impacts on cultural heritage. • All the other excluded activities set out in the ESMS with framework approach of the Project. ESS 2: LABOR AND WORKING CONDITIONS 6|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 2.1 LABOR MANAGEMENT PROCEDURES: 1. The Project shall be carried out in accordance with the Implement and update LMP Responsibility: Kafalat SAL, PMU applicable requirements of ESS2, in a manner acceptable to the throughout Project implementation Environment & Social Bank, including through, inter alia, implementing adequate Specialist, participating financial occupational health and safety measures (including emergency intermediaries, eligible MSEs, preparedness and response measures), establishing out grievance procured vendors. arrangements for Project workers, and incorporating labor requirements into the ESHS specifications of the procurement documents and contracts with contractors. 2. The Recipient shall implement and update where necessary an LMP incorporating the relevant requirements of ESS2, in a manner acceptable to the Bank, that address the terms and conditions of employment, non-discrimination and equal opportunity for employment, worker’s organizations, restrictions on child and forced labor, occupational health and safety (OHS) measures related to COVID-19 as per the national health requirements in response to the epidemy, and grievance mechanism for Project workers. 3. KAFALAT SAL shall require Participating FIs to prepare and implement an LMP, in the terms according to (1) and (2) above. 7|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: Develop and maintain a grievance mechanism for Project workers, The GM, as part of the LMP, shall be Responsibility KAFALAT SAL PMU workers of MSEs and MFIs and primary supply workers as part of operational by Effective Date, and to Environment & Social the LMP. The GM shall have the following: be maintained throughout the project Specialist, and participating financial • Proportionate to the nature and scale of the project and implementation intermediaries. its risks and impacts. • Addresses concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned in a language that they understand, and without any retribution. • Operates in an independent and objective manner and implement the principles of confidentiality and anonymity as warranted (in particular when the grievance concern sexual exploitation and abuse and sexual harassment); • May utilize existing GMs given they possess the above characteristics and may be supplemented with Project specific arrangements. 2.3 OHS MEASURES: Develop and implement Occupational, Health and Safety (OHS) As part of the LMP and ESMS and Responsibility: KAFALAT SAL, PMU measures in line with National legislation and ESS2 as part of the implemented throughout the Project Environment & Social ESMS and LMP, particularly as it relates to COVID19 preventive implementation Specialist, and participating financial measures and OHS risks associated with rehabilitation works. intermediaries. KAFALAT SAL shall promote safety and health in the work environment and shall require from MFIs and MSEs to do the same, in accordance with the requirements of ESS2 and in a manner acceptable to the Bank. 2.4 EMERGENCY PREPAREDNESS AND RESPONSE: As part of the OHS measures specified in 2.3, include measures on As part of the LMP and ESMS and Responsibility: KAFALAT SAL PMU emergency preparedness and response, and ensure coordination implemented throughout the Project Environment & Social with measures under 4.4. implementation Specialist 8|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 2.5 PROJECT WORKERS TRAINING: Implement training of Project Workers designed to heighten As part of the LMP and the ESMS under Responsibility: KAFALAT SAL, PMU awareness of risks and to mitigate impacts on local communities section 1.2 of this ESCP and Environment & Social as defined in ESMS and LMP. implemented throughout the Project Specialist implementation ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 MANAGEMENT OF WASTE AND HAZARDOUS MATERIALS: As Part of the ESMS, develop and implement measures and Prior to initiating any rehabilitation Responsibility: KAFALAT SAL PMU procedures to manage waste and hazardous materials during (light civil works). Environment & Social demolition, construction and operation that is in line with ESS3 Specialist and requirements of the Beirut municipality, in a manner Maintained and managed throughout acceptable to the Bank. KAFALAT SAL shall ensure as per the Project implementation. exclusion list of the ESMS with framework approach that any high polluting activities are not supported under the project. The MSEs that undertake light civil works shall be required to prepare and implement an Environmental and Social Management Plan to be eligible for funding. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY: Develop and implement measures and actions to assess and General guidelines will be outlined in Responsibility: KAFALAT SAL PMU manage traffic and road safety risks. the ESMS Environment & Social Specialist Prior to initiation of the relevant rehabilitation (light civil works) by eligible MSEs 9|Page THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 4.2 COMMUNITY HEALTH AND SAFETY: Relevant aspects of this standard shall be considered, as needed, Guidelines and mitigation measures as Responsibility: KAFALAT SAL PMU under action 1.2 above including, inter alia, measures to: part of the ESMS. To be implemented Environment & Social minimize the potential for community exposure to communicable throughout Project implementation Specialist diseases and COVID-19 infections; ensure that individuals or and to be set by and with MSEs before groups who, because of their particular circumstances, may be they start works. disadvantaged or vulnerable, have access to the development benefits resulting from the Project. 4.3 GBV AND SEA RISKS: Prepare, adopt, and implement a stand-alone Sexual Exploitation Submit the SEA/SH Prevention and Responsibility: KAFALAT SAL PMU and Abuse/Sexual Harassment Prevention and Response Plan Response Plan for the Bank’s approval Environment & Social (SEA/SH), to assess and manage the risks of SEA/SH in accordance within 60 days after the Effective Date Specialist with ESS4 and in a manner acceptable to the Bank. Once approved, the SEA/SH Prevention and Response Plans shall be implemented throughout Project implementation 4.4 EMERGENCY RESPONSE MEASURES: Develop and implement measures to address emergency events Part of the LMP and ESMS. Responsibility: KAFALAT SAL PMU and ensure coordination with measures under 2.4. Measures will Environment & Social be defined in the ESMS and disseminated as part of the SEP. Specialist ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 Currently not relevant to the Project ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: Activities that would have risks and impacts on biodiversity shall be excluded from project activities. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 Currently not relevant to the Project 10 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY ESS 8: CULTURAL HERITAGE 8.1 CHANCE FINDS: Activities that would have risks and impacts on cultural heritage shall be excluded from project activities. Chance find procedures shall be included as part of the ESMS with a framework approach to be followed for construction/rehabilitation related activities. ESS 9: FINANCIAL INTERMEDIARIES 11 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 9.1 ESMS: KAFALAT SAL shall implement, and update as appropriate, the The ESMS with framework approach Responsibility: KAFALAT SAL PMU ESMS with a framework approach to meet the requirements of shall be updated throughout project Environment & Social ESF as per ESS9. This shall include ensuring that there is adequate implementation where required Specialist, and participating financial capacity to maintain it through the appointment of the E&S intermediaries. specialists. Participating FIs shall establish, adopt and implement their respective ESMS KAFALAT SAL and each of the MFIs participating from the project before the selection of any subproject shall assign both a senior management representative to have to be supported under Part 1 of the overall accountability for environmental and social performance Project. and a staff member or consultant as E&S Focal Point to manage the day-to-day implementation of ESMS. The Terms of Reference of the E&S Focal Point, including required technical skills and experience shall be included in the ESMS and Project Operations Manual (POM). KAFALAT SAL shall ensure that the project’s exclusion list, following action 1.4, is adhered to in accordance with the Grant Agreement. During the implementation stage of this project, all candidate MFIs and MSEs receiving grants shall be screened against the project’s exclusion list of the ESMS, categorized and assessed for their E&S risks and impacts prior to receiving any financing under the project. 12 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 9.2 FI ORGANIZATIONAL CAPACITY: Establish an organizational capacity and competency for By Effective Date and Maintained Responsibility: KAFALAT SAL PMU implementing the ESMS with clearly defined roles and throughout Project implementation. Environment & Social responsibilities as per the requirements of ESS9. Specialist, and participating financial intermediaries. KAFALAT SAL shall be presenting an organizational structure to the Bank that identify the specific positions and resources for E&S management. Participating MFIs shall also establish and maintain the organizational capacity and competence to implement ESMS with functions and responsibilities in accordance with ESS9 and in a manner acceptable to the Association. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION SEP was prepared, consulted upon and Responsibility: KAFALAT SAL PMU Update, disclose, consult, adopt and implement the Stakeholder disclosed in June, 2021 Environment & Social Engagement Plan (SEP) consistent with ESS10 in a manner Specialist acceptable to the Bank. The Recipient shall ensure that the SEP is Update SEP as needed throughout amended and updated as required during the Project project implementation. The SEP will implementation following inclusive stakeholder consultations. be implemented throughout the Project 13 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY 10.2 PROJECT GRIEVANCE MECHANISM: A project GM is already established and operational within Throughout project implementation as Responsibility: KAFALAT SAL PMU KAFALAT SAL. Implement, maintain and operate a grievance described in ESMS under section 1.2 Environment & Social mechanism, as described in the SEP. Accessible grievance and in the SEP under section 10.1 Specialist arrangements shall be made publicly available to receive and facilitate resolution of concerns and grievances in relation to the Project, consistent with ESS10, in a manner acceptable to the Bank. Grievance Mechanisms shall also be established within each of the Participating FIs to handle complaints and grievances relating to the project, in accordance with the requirements of ESS10 and in a manner acceptable to the Bank. 10.3 SEA/SH GRIEVANCE MECHANISM Implement, maintain and operate a grievance mechanism for SEA/SH The SEA/SH GM will be established Responsibility: KAFALAT SAL PMU allegations relating to the Project. Accessible grievance arrangements within 60 days of effectiveness and will Environment & Social shall be made publicly available to receive and facilitate resolution of be implemented throughout project Specialist, and participating financial concerns and grievances related to SEA/SH risks. The existing project implementation intermediaries. GM shall include referral pathways in the event of any SEA/SH-related complaint using a survivor-centered approach with focus on confidentiality and anonymity. CAPACITY SUPPORT (TRAINING) 14 | P a g e THE WORLD BANK - ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP): VERSION 2.0 – July 2019 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBILE ENTITY/AUTHORITY CS1 As example, training may be performed by the PMU for the required following items: • Stakeholder mapping and engagement • Specific aspects of social assessment, including GBV SEA/SH risks, impacts and mitigation measures • Training on occupational health and safety including on emergency prevention and preparedness and response arrangements to emergency situations. emergency preparedness and response and OHS measures related to COVID-19 as per the national health requirements • Grievance redress mechanism • MFIs ESMS preparation, implementation, and monitoring 15 | P a g e