Charity Projects and Spark MicroGrants Rwanda: Advancing Citizen Engagement (ACE) Project (P172862) ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) [Final Draft] November 2020 1 | Page ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. Charity Projects will and will cause Spark Microgrants to implement the Advancing Citizen Engagement Project (hereafter the Project), with the involvement of the Ministry of Local Government, Local Administrative Entities Development Agency, and the Ministry of Economy and Finance. The International Bank for Reconstruction and Development and the International Development Association (hereafter the Bank) has agreed to administer project financing, provided by the Japanese Social Development Fund. 2. Charity Projects will and will cause Spark MicroGrants to 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, and the timing for each of these. 3. Charity Projects will and will cause Spark MicroGrants to comply will also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as Environmental and Social Management Plans (ESMP), and Stakeholder Engagement Plans (SEP) as applicable, and the timelines specified in those E&S documents. 4. Charity Projects and Spark MicroGrants are responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry, agency or unit referenced in 1. above, or by communities in target villages. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Bank by Charity Projects and Spark MicroGrants 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 Charity Projects, this ESCP may be revised during Project implementation to reflect adaptive management of the Project to changes and unforeseen circumstances, or in response to the assessment of Project performance conducted under the ESCP itself. In such circumstances, Charity Projects will agree to the changes with the Bank and will cause Spark MicroGrants to 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 Charity Projects. Charity Projects will cause Spark MicroGrants to promptly redisclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, Charity Projects shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. This may include actions such as the development of subproject ESMPs, or additional safeguards training for staff, in response to risks such as gender-based violence, health and safety risks, water and soil quality degradation, or the spread of human and/or animal diseases. 2 | Page RWANDA ADVANCING CITIZEN ENGAGEMENT (ACE) PROJECT (P172862) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN, November 18, 2020 SUMMARY OF MATERIAL MEASURES AND ACTIONS TO MITIGATE THE TIMEFRAME RESPONSIBLE DATE OF PROJECT’S POTENTIAL ENVIRONMENTAL AND SOCIAL RISKS AND IMPACT ENTITY/AUTHORITY COMPLETION MONITORING AND REPORTING A REGULAR REPORTING Quarterly (every 3 Charity Projects and Throughout the Prepare and submit to the Bank and Comic Relief regular monitoring reports on the months) reports submitted Spark Microgrants Project environmental, social, health and safety (ESHS) performance of the Project, including but not to the Bank and Charity Monitoring costs to be implementation limited to; Projects, throughout the covered under the Project - the implementation of the ESCP Project implementation. management - status of preparation and implementation of E&S documents required under the ESCP - Stakeholder engagement activities - Functioning of the grievance mechanism(s), and any grievances since the last reporting period; - Village sub-project risk screening and; - any accidents or incidents since the last reporting period More elaborated aspects of monitoring and reporting are provided in the Project’s ESMF and SEP, and further guidance will be articulated in the site specific ESIAs/ESMPs for ECEP subprojects. B INCIDENTS AND ACCIDENTS Notify the Bank, Charity Spark Microgrants Throughout the Promptly notify the Bank, Charity Projects, and appropriate GoR authorities of any incident or Projects, and appropriate Project accident related to the Project which has, or is likely to have, a significant adverse effect on the GoR authorities within 48 implementation environment, the affected communities, the public or workers. hours after learning of the This includes but is not limited to; incident or accident. • Fatalities • materialization of significant risks on subproject sites A report would be • discovery of serious social harm associated with the project. provided within a • Any allegations that staff, volunteers or operations funded by Charity Projects have timeframe acceptable to resulted in the risk of harm, abuse or exploitation of anyone connected with the the Bank and Charity Project Projects, as requested • Any allegations relating to Spark’s Trustees or other senior staff members who have a significant influence over the culture and operations of Spark • Any allegations related to Spark which is likely to lead to adverse publicity, irrespective of the individual's role 3 | Page • Allegations of harm, abuse or misconduct which have resulted in an internal investigation and/or referral to a relevant authority such as social services, the police or regulatory body • Any serious breach or failure in safeguarding procedures or policies which have created the risk of harm, abuse or exploitation and/or have resulted in a referral to any regulatory body or relevant authority such as social services or the police. Sufficient detail regarding the incident or accident will be provided, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor, community, or supervising entity, as appropriate. Subsequently, as per the Bank’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE The staff are already in Spark Microgrants Throughout Establish and maintain an organizational structure with qualified staff and resources to support place and be ready to Project management of E&S risks. Maintain Spark Microgrants’ three key staff (the M&E Specialist, support in the Funding from the Project implementation the Project Director and the Country Director) to take prime responsibility for ESSs implementation when the management compliance. Spark Microgrants will train up existing staff to handle the ESSs risks project commences management responsibilities as well. Recruit one (1) position in the RELM team specifically for GRM/ESSs compliance. SPARK Microgrants shall also recruit a short-term consultant to Additional environmental train and assist Spark team and communities on environmental and social management during and social risks project identification, environmental screening and preparation of ESSs instruments. management staff and systems are in place before project effectiveness (by December 31, 2020) and will be maintained throughout Project implementation. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT Disclose the ESMF by Charity Projects and Prior to project Disclose the ESMF prior to project appraisal, and redisclose the updated version prior to November 20, 2020 Spark Microgrants appraisal negotiations Redisclose the updated Prior to ESMF by December 30, Financing from the negotiations 2020 Project management Consistent with the Project’s ESMF, screen any proposed sub-project, and, thereafter, draft, All village subprojects will Throughout the adopt, and implement the sub-project ESMP as required, in a manner acceptable to the Bank. be screened and project The subproject that require ESIAs to be prepared will not be funded under this project. categorized prior to being implementation approved for financing. 4 | Page ESMPs for CDD subprojects will be prepared as needed, prior to sub-projects approval for financing. The approved ESMPs will be implemented and monitored throughout the project implementation 1.3 MANAGEMENT TOOLS AND INSTRUMENTS Prior to subproject Charity Projects and Throughout the Consistent with the Project’s ESSs, there will be development and implementation of approval for financing by Spark Microgrants project management tools and instruments based on the particularity of each site considering existing Spark Microgrants. implementation environmental and social features. Once prepared, the tools and instruments/plans will be Financing from the cleared prior to subproject approval for financing, throughout Project implementation. Project management Accordingly, the following tools will be developed/implemented: • Grievance Redress Mechanism; • GBV Action Plan • OHS management Site specific ESMPs will be reviewed and approved by both national regulatory authority (RDB) and the Bank. 1.4 CAPACITY SUPPORT (TRAINING) By January 31st 2021 Spark Microgrants 90 days after Undertake a comprehensive training needs assessment and develop a timebound training plan project for Project staff. Financing from the effectiveness Project management Throughout the Provide training on an ongoing basis for project implementation team on E&S risks and Once per year (first round: project impacts management, including meaningful stakeholders engagement, inclusion, grievance by February 28th 2021) implementation redress mechanism, monitoring and reporting ,and other relevant areas related to this project as per the training plan. 1.5 PROJECT IMPLEMENTATION MANUAL By December 31, 2020 Charity Projects and Before project Prepare project implementation manual, including ESSs management Spark Microgrants effectiveness Financing from the Project management 1.6 SUB-GRANTEES AGREEMENT Before the commencement Spark Microgrants, Throughout the Spark Microgrants to prepare and sign agreements with subgratees and provide support for of the subproject activities Subgrantees project implementation. implementation Financing from the Project management 5 | Page 1.7 TECHNICAL ASSISTANCE/CAPACITY BUILDING Obtain prior ToRs review Spark Microgrants Throughout Key activities under Components 1 (Village and Local Government Capacity Building), 3 and clearance by the Bank Project (National Framework for Participatory Village Planning) and 4 Project Management, M&E, throughout the Project implementation. and Knowledge Dissemination) of the Project shall be undertaken pursuant to terms of implementation reference (ToR) acceptable to the Bank and duly incorporate and take into consideration the requirements of the WB’s ESSs and the GoR’s environmental and social policies and legal frameworks. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Spark Microgrants 90 Days after The Labor Management Procedures (LMP) will be prepared by Spark Microgrant, consulted The LMP will be prepared, Financing from the project upon and disclosed, adopted and implemented. consulted upon and Project management effectiveness disclosed within 90 days The LMP will comply with the Rwanda Labor laws and ESS2, include Occupational Health after project effectiveness and Safety (OHS) guidelines, clarification of the minimum age and the project’s commitment against child labor and forced labor, commitment to non-discrimination and inclusion of a worker’s GRM in the LMP for Sparks Microgrants project staff, and community workers on subprojects, which will be included in the relevant terms of reference for staff and consultants contrcated for the ACE Project. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Grievance mechanism Charity Projects and Throughout the Establish, maintain, and operate a grievance mechanism for Project workers, as described in the operational prior to Spark Microgrants project LMP and consistent with ESS2. engaging Project staff and Financing from the implementation maintained throughout Project management Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the Charity Projects and Throughout the Consistent with the Project’s ESMF and ESS3, and GoR’s requirements, resource efficiency preparation and Spark Microgrants project and pollution prevention and management measures will be covered under the ESMPs to be implementation of the implementation prepared under action 1.2 above, as and when required for selected village CDD subprojects. ESMPs ESS 4: COMMUNITY HEALTH AND SAFETY [ 4.1 TRAFFIC AND ROAD SAFETY Same timeframe as for the Charity Projects and Throughout the project Consistent with the Project’s ESMF and ESS4, and GoR’s requirements, a dopt and preparation and implementation of Spark Microgrants implementation implement measures and actions to assess and manage traffic and road safety risks as the ESMPs required in the ESMPs for CDD subprojects to be developed under action 1.2 above. 6 | Page 4.2 COMMUNITY HEALTH AND SAFETY Same timeframe as for the Charity Projects and Throughout the project Consistent with the Project’s ESMF and ESS4, and GoR’s requirements, prepare, preparation and implementation of Spark Microgrants implementation adopt, and implement measures and action to assess and manage specific risks and the ESMPs impacts to the community arising from Project activities including, behavior of Project workers, or risks of disease transmission, and include these measures in the ESMPs as required under activity 1.2 above, in a manner acceptable to the Bank. 4.3 GBV AND SEA RISKS DURING PROJECT IMPLEMENTATION Same timeframe as for the Charity Projects and Throughout the project Prepare, adopt, and implement a stand-alone Gender-Based Violence Action preparation and implementation of Spark Microgrants implementation Plan (GBV Action Plan), to assess and manage the risks of gender-based the ESMPs violence (GBV) and sexual exploitation and abuse (SEA). ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT N/A as the project will not fund microgrant activities requiring land acquisition, restrictions on land use or involuntary resettlement. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS: Same timeframe as for the preparation Charity Projects and Throughout the Consistent with the Project’s ESMF and ESS6, and GoR’s requirements, adopt and and implementation of the ESMPs Spark Microgrants project implement measures and actions to assess and manage threats to biodiversity as required implementation in the ESMPs to be developed under action 1.2 above. ESS7 N/A as there are no local communities as defined by ESS7 present in the potential project areas. ESS 8: CULTURAL HERITAGE 8.1 CULTURAL HERITAGE RISKS AND IMPACTS: Same timeframe as for the preparation Charity Projects and Throughout the Consistent with the Project’s ESMF and ESS8, and GoR’s requirements, adopt and and implementation of the ESMPs Spark Microgrants project implement measures and actions, including chance finds procedure, to assess and implementation manage threats to cultural heritage sites or values as required in the ESMPs to be developed under action 1.2 above. ESS 9: FINANCIAL INTERMEDIARIES N/A as Spark MicroGrants is an international non-government organization. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND At mid-term review Charity Projects and At mid-term IMPLEMENTATION Spark Microgrants review Update, adopt, and implement Stakeholder Engagement Plan (SEP). 7 | Page 10.2 PROJECT GRIEVANCE MECHANISM: Prepare, adopt, maintain and operate a Within 60 days after project Charity Projects and Throughout the grievance mechanism, as described in the SEP. effectiveness . Spark Microgrants project implementation CAPACITY SUPPORT (TRAINING) CS1 Provide training for village-based FCAP Leadership Committees, CBFs, and SEDOs on Within 90 days of project start Spark Microgrants 90 days after GRM mechanism and overall E&S risks assessment and management approach. project Provide specific training for CBFs on subproject E&S risk screening tools. effectiveness CS2 Conduct a comprehensive training needs assessment and develop a training strategy Prior to project start. plan, on ESMF implementation and E&S RIM responsibilities. Spark Microgrants CS3 Provide training for project staff on ESMF implementation and E&S RIM Within 90 days of the project start. Spark Microgrants Throughout the responsibilities and tools, specifically including; project - GRM implementation - Stakeholder management - Village subproject E&S risk screening - Incident reporting - E&S monitoring and reporting 8 | Page