FEDERAL GOVERNMENT OF NIGERIA
ADOLESCENT GIRLS INITIATIVE
FOR
LEARNING AND EMPOWERMENT PROGRAM
ENVIRONMENTAL AND SOCIAL MANAGEMENT
FRAMEWORK (ESMF)
DRAFT FINAL REPORT
i
December 2019
Draft Final Report
Environmental and Social Management Framework (ESMF) for the Adolescent Girls
Initiative for Learning and Empowerment Program
Federal Ministry of Education
Nigeria
ii
Contents
Abbreviations viii
EXECUTIVE SUMMARY ................................................................................................................ ix
Chapter One: Introduction ..................................................................................................... 21
1.1 Background Information ................................................................................................... 21
1.2 Assessment of the Education Sector................................................................................. 22
Adolescent Girls Initiative for Learning and Empowerment Program .............................................. 22
1.3.1 Project Development Objectives ........................................................................................ 22
1.3.2 Project Components ........................................................................................................... 22
1.3.3 Project Target Beneficiaries .............................................................................................. 24
Adolescent girls especially from disadvantaged and poor families .................................................. 24
Secondary schools across the participating states ........................................................................... 24
Female teachers ................................................................................................................................ 24
Federal and State Ministries of Education ........................................................................................ 24
State Universal Basic Education Board (SUBEB) ............................................................................... 24
Families of participating Girls and the host communities ................................................................ 24
The project also targets inclusiveness of vulnerable and special needs students ........................... 24
1.4 Objectives of the Environmental and Social Management Framework ........................... 24
1.5 Rationale for the Environmental and Social Management Framework ........................... 25
1.6 Scope of Work for Preparation of the ESMF ..................................................................... 25
1.7 Analysis of ESS and Regulations ........................................................................................ 26
1.8 Approach and Methodology ............................................................................................. 26
1.8.1 Literature Review ................................................................................................................ 26
1.8.2 Environmental and Social Baseline Data Analysis............................................................... 26
1.8.3 Identification of potential Environmental & Social Impacts and Mitigation Measures........... 27
1.8.4 Stakeholder Consultations .................................................................................................. 27
Chapter two: policy legal and institutional FRAMEWORK APPLICABLE TO THE PROJECT .......... 28
2.1 Introduction ...................................................................................................................... 28
2.2 Policy, Regulatory and Institutional Framework on Environment .................................... 28
2.2.1 National Policy on Environment (Revised 2016)................................................................. 28
2.2.2 The Federal Ministry of Environment ................................................................................. 28
2.2.3 National Legal Instruments on the Environment ................................................................ 29
2.2.4 State Legislation on Environment ..................................................................................... 30
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2.2.5 State Waste Management Authorities ............................................................................. 31
2.4 Policy, Regulatory and Institutional Framework on Gender and Child Protection ........... 31
2.4.1 National Gender Policy (2007) ............................................................................................ 31
2.4.2 Federal Ministry of Women Affairs and Social Development (FMWASD) .......................... 31
2.4.3 The Convention on the Elimination of All Forms of Discrimination against Women
(CEDAW) (1984) .................................................................................................................................. 31
2.4.4 Child Rights Act (2003) ........................................................................................................ 32
2.5 Policy, Regulatory and Institutional Framework on Occupational Health and Safety ...... 32
2.5.1 Labor Act, Chapter 198, Laws of the Federation of Nigeria (LFN) 2004 ............................. 32
2.5.2 Factories Act, 1990.............................................................................................................. 32
2.5.3 Factories Act, Cap F1, LFN 2004 .......................................................................................... 32
2.5.4 Worker’s Compensation Act (2010) .................................................................................... 33
2.5.5 Federal Ministry of Labor & Employment........................................................................... 33
2.6 World Bank Environmental and Social Framework .......................................................... 33
2.7 Environmental and Social Standards (ESS) ....................................................................... 33
2.8 Comparison between Nigeria EIA Guidelines and World Bank ESF .................................. 36
ESS 2 Labor and Working Condition ................................................................................................. 36
2.9 Assessment of the Policy and Regulatory Framework for Environmental & Social Concerns
41
chpater three: Education sector overview................................................................................... 46
3.8.1 Educational Delivery System ............................................................................................... 46
3.8.2 Baseline Description of the Project Locations .................................................................... 46
Chapter three: Social Assessment ....................................................... Error! Bookmark not defined.
Conflict/fragility challenges .............................................................................................................. 52
Internally displaced adolescent girls ................................................................................................. 52
Social norms around access to Girls education ................................................................................ 52
Disability-Inclusion ............................................................................................................................ 53
3.7 Gender Consideration ....................................................................................................... 54
3.7.1 Gender Mainstreaming and Vulnerability Statistics (from recent studies) ............................... 54
Chapter four: project environmental and social risks and impacts.............................................. 56
4.1 Introduction ...................................................................................................................... 56
4.3 Potential Project Risks....................................................................................................... 56
4.4 Negative Environmental Impacts and Mitigation Measures ............................................ 58
4.5 Negative Social Impacts and Mitigation Measures ........................................................... 60
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4.6 Environmental and Social Management Plan ................................................................... 64
4.7 Labor Influx ....................................................................................................................... 74
4.8 Gender Based Violence ..................................................................................................... 74
4.8.1 Introduction and Statistics .................................................................................................. 74
4.8.2 Manifestations of GBV ............................................................................................................... 75
4.8.3 National Legal and policy framework on GBV .................................................................... 75
4.8.4 GBV Risks in the Adolescent Girls Initiative for Learning and Empowerment Program ..... 76
4.9 Monitoring Plan ................................................................................................................ 77
4.10 Monitoring Procedure....................................................................................................... 78
CHAPTER FIVE: Environmental and Social screening of subprojects ........................................... 79
5.1 Introduction ...................................................................................................................... 79
5.2 Environmental and Social Screening Procedures.............................................................. 79
5.4 Development of Terms of Reference for ESMP/ESIA ....................................................... 81
5.5 Integrating Environmental and Social Mitigation Measures in Project Design and Tender
Documents ........................................................................................................................................ 81
CHAPTER SIX: ESMF implementation arrangements ................................................................ 82
6.1 Introduction ...................................................................................................................... 82
6.2 Institutional Roles and Responsibilities for Implementing the ESMF ............................... 82
6.3 Capacity Assessment of Institutions to Implement the ESMF .......................................... 83
6.4 Training Plan...................................................................................................................... 84
6.5 Disclosure of Documents .................................................................................................. 84
6.6 Estimated ESMF/ESMP Implementation Budget .............................................................. 85
Chapter seven: stakeholder consultation .................................................................................. 87
7.1 Introduction ...................................................................................................................... 87
7.2 Summary of Consultations ................................................................................................ 88
7.3 Pictures of Stakeholders Consultations ............................................................................ 94
95
Chapter eight: grievance redress mechanism ............................................................................. 96
8.1 Introduction ...................................................................................................................... 96
8.2 Grievance Redress Committees ........................................................................................ 96
8.3 Expectations When Grievances Arise ............................................................................... 97
8.4 Typical Grievance Redress Process .................................................................................. 98
8.5 GBV-GRM ........................................................................................................................ 100
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CHAPTER nine: LABOR MANAGEMENT PROCEDURES ................................................................ 101
9.1 Introduction .............................................................................................................................. 101
9.2 Characterization of labor requirements ......................................................................... 101
9.3 Labor Risk Identification and Analysis............................................................................. 101
9.4 Grievance Redress Procedures for Workers ................................................................... 106
9.5 Roles and Responsibilities for Managing the LMP .......................................................... 107
CHAPTER ten: summary and recommendation ...................................................................... 109
Annex 1: Consultation Attendance Sheets .............................................................................. 110
Annex 2: Environmental Health and Safety Guidelines............................................................ 113
ANNEX 3: Occupational Health and Safety Plan ...................................................................... 118
ANNEX 4 generic Workers Campsite Management Plan ............................................................ 120
ANNEX 5 ENVIRONMENTAL AND SOCIAL SCREENING CHECKLIST ................................... 122
ANNEX 6 ENVIRONMENTAL AND SOCIAL MONITORING CHECKLIST ........................................... 124
ANNEX 7: GENERIC WASTE MANAGEMENT PLAN ........................................................... 126
ANNEX 8: CONTRACTOR’S CODE OF CONDUCT ON GENDER BASED VIOLENCE (GBV) AND SEXUAL
EXPLOITATION & ABUSE (SEA) .................................................................................................. 129
MANAGER’S CODE OF CONDUCT ON GENDER BASED VIOLENCE (GBV) AND SEXUAL EXPLOITATION &
ABUSE (SEA) 130
EMPLOYEE’S CODE OF CONDUCT on Gender Based Violence (GBV) and Sexual Exploitation & Abuse
(SEA) 132
LIST OF TABLES
Table 1: Environmental and Social Standard Applicable to the Project ..................................................... 34
Table 2: Comparison Between the Nigerian EIA Law and the World Bank ESF ............ Error! Bookmark not
defined.
Table 3: Assessment of the Government’s Policy and Regulatory Framework to address the E&S Risks of
the Project................................................................................................................................................... 42
Table 4: Average Monthly Temperature Chart .............................................. Error! Bookmark not defined.
Table 5: Gender Vulnerability Statistics ...................................................................................................... 54
Table 6: Baseline Descriptive Pictures of Project Locations ....................................................................... 49
Table 7: Gender Equality Index in Education in Nigeria................................. Error! Bookmark not defined.
Table 8: Environmental and Social Management Matrix Table .................................................................. 64
Table 9: Roles and Responsibilities for ESMF Implementation .................................................................. 82
Table 10: Training Plan for ESMF Implementation ..................................................................................... 84
Table 11: Budget for ESMF/ESMP Implementation .................................................................................... 85
Table 12: Summary of Enlarged Consultations with Stakeholders in Kano ................................................ 88
Table 13: Meeting With Rep of Women Affairs and Mothers Association................................................. 89
Table 14: Consultations in Secondary Schools............................................................................................ 90
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Table 15: Consultations with Stakeholders in Ekiti State............................................................................ 91
Table 16: Consultation in Schools in Ekiti State .......................................................................................... 92
Table 17: Consultations with Female Students in Ekiti State...................................................................... 92
Table 18: Stakeholders Workshop Key Discussions .................................................................................... 93
Table 19: Typical Steps in a Grievance Redress Process ............................................................................. 98
Table 20: Labor Risk Identification and Analysis ....................................................................................... 101
LIST OF FIGURES
Figure 1: Map of Nigeria Showing International and National Geographical Boundaries and the 36 states
....................................................................................................................... Error! Bookmark not defined.
Figure 2: Annual Rainfall for 2016................................................................. Error! Bookmark not defined.
Figure 3: Day and Night Temperature for January 2016 ............................... Error! Bookmark not defined.
Figure 4: Education Indices for girls across the various Geo-political Regions in Nigeria ... Error! Bookmark
not defined.
Figure 5: Environmental and Social Screening Process .............................................................................. 80
Figure 6:Flow Chart for Grievance Redress Procedure ............................................................................... 99
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ABBREVIATIONS
CCT Conditional Cash Transfers
EECD Early Childhood and Care Development
EIA Environmental Impact Assessment
ESCP Environmental and Social Commitment Plan
ESF Environmental and Social Framework
ESIAs Environmental and Social Impact Assessments
ESMF Environmental and Social Management Framework
ESMP Environmental and Social Management Plan
ESS Environmental and Social Standards
GBV Gender Based Violence
GDP Gross Domestic Project
GRM Grievance Redress Mechanism
IDP Internally Displaced Person
ILO International Labor Organization
JSS Junior Secondary School
LGA Local Government Area
LMP Labor Management Plan
NESREA National Environmental Standards and Regulations Enforcement Agency
OHS Occupational Health and Safety
PCU Project Coordinating Unit
PDO Project Development Objective
PIU Project Implementation Unit
PMP Project Management Plan
PMU Project Management Unit
PPE Personnel Protective Equipment
PTA Parents Teachers Association
RAP Resettlement Action Plan
RPF Resettlement Policy Framework
SBMC School Based Management Committee
SEA Sexual Exploitation and Abuse
SEP Stakeholders Engagement Plan
SME State Ministry of Education
SSS Senior Secondary School
STD Sexually Transmitted Disease
STI Sexually Transmitted Infection
SUBEB State Universal Basic Education Board
ToR Terms of Reference
WB World Bank
WHO World Health Organization
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EXECUTIVE SUMMARY
ES1. Background/ Project description
The Federal Government is requesting the support of the World Bank to implement the Adolescent Girls
Initiative for Learning and Empowerment (AGILE) Program that aims to address the critical binding
constraints adolescent girls face in enrolment, retention, completing secondary school education and
empowerment with life skills that are relevant and marketable, in participating states across the country.
The project development objective is to improve completion of quality secondary education and
comprehensive life-skills training for adolescent girls. The project will be implemented across different
States with uneven institutional capacity and weak legislation enforcement, which may pose social and
environmental risks in terms of the ability to comply with the requirements of the Nigerian Environmental
Guidelines and the World Bank Environmental and Social Framework (ESF). Furthermore, the project will
be implemented within complex and varied fragility/conflict contexts potentially posing significant risks
to beneficiaries and communities in support of girls education. Thus, this Environmental and Social
Management Framework (ESMF) has been prepared as part of project preparatory activities to ensure
compliance with the ESF, prior to Board appraisal, since the locations and site-specific activities for the
renovation of schools are unknown at this moment.
Objective of the ESMF
The objective of the Environmental and Social Management Framework (ESMF) is to enhance the quality
and sustainability of the project, and to ensure that the project follows the World Bank’s Environmental
and Social Framework (ESF) requirements as well as the Federal Government of Nigeria’s environmental
policy, laws and regulations. The ESMF has identified the environmental and social risks and impacts of
the project, and developed guidelines for assessing, monitoring and mitigating such impacts using the
mitigation hierarchy, from activities funded under the project. It also provides guidelines and procedures
to be followed in undertaking site-specific Environmental and Social Management Plans (ESMPs) during
project implementation phase.
ES 2. Policy, Legal and Institutional Framework
Administrative Framework - In Nigeria, the power of regulation of all environmental matters is vested in
the Federal Ministry of Environment (FMENV). There are State Ministries of Environment in all States,
Environmental Protection Agencies/Waste Management Authorities in some states, all charged with a
responsibility to protect public health and safety, and to restore and enhance environmental quality.
Since the proposed program is domiciled in the education sector, the Federal and State Ministries of
Education are critical institutions in this project as they will be the key implementing institutions. In
addition, the project centers around adolescent girls, thus, the Federal and State Ministries of Women
Affairs are also key collaborators in the project as they provide a framework for Girl child protection.
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Relevant Policies, Regulations & Acts - Environmental protection in the country is guided by the National
Policy on Environment (revised 2016) which aims to achieve sustainable development in Nigeria. With
respect to the proposed development project, the Environmental Impact Assessment (EIA) Act No. 86 of
1992 is one of the most relevant pieces of legislation in Nigeria. The Act makes environmental assessment
mandatory for such development project, prescribes the procedures for conducting and reporting EIA
studies, and ensures that such projects be screened for their potential impacts.
Other relevant legislation applicable to the project (some of which is not directly relevant to social and
environmental impacts but are relevant to the project) includes:
• National Policy on Education 2004
• Workmen Compensation Act 2010
• National Gender Policy 2010
• Land Use Act (1978)
• National Environmental Standards and Regulations Enforcement Agency (NESREA) Act 2007
• Universal Basic Education (UBE) Act 2004
• Child Rights Act (2003)
• National Policy on Inclusive Education in Nigeria (2017)
• National School Health Policy in Nigeria (2006)
Details of the provisions within these legislations applicable to the AGILE Program are provided in chapter
two.
These national frameworks are in tandem with the World Bank Environmental and Social Framework (ESF)
which sets out the Bank’s commitment to sustainable development, through a set of Environmental and
Social Standards (ESS). According to the ESF, the project environmental risk rating is moderate because
the project proposes to support minor civil works (renovation of schools and classrooms) while the social
risk rating is substantial. Where country laws and regulations are inadequate or weak, the ESSs are
provided to strengthen the policy gaps for environmental and social sustainability and risk management
of World Bank funded projects. The 8 applicable standards to this project include:
ESS 1: Assessment and Management of Environmental and Social Risks and Impacts
ESS 2: Labor and Working Conditions
ESS 3: Resource Efficiency and Pollution Prevention
ESS 4: Community Health and Safety
ESS 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement
ESS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
ESS 8: Cultural Heritage
ESS 10: Information Disclosure and Stakeholder Engagement
Details of how these standards apply to the project and how they will be addressed are provided in section
2.7, Table 1.
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ES3. Baseline Description of Project Locations
• The Adolescent Girls Initiative for Learning and Empowerment Program will cut across
participating states in the country which are not all known at this time of project preparation.
However, prevailing deficiencies of the education sector, delivery of quality education and school
environment with focus on secondary schools for adolescent girls are presented below:
• Physical Environment – poor learning environment, dilapidated and abandoned buildings, poor
waste management techniques mostly open dumping and open burning
• Inadequacy of facilities - Dilapidated classrooms, damaged roofs, lack of sufficient laboratories
and workshop spaces. Available infrastructures and facilities are overstretched, in poor condition
and unable to meet the demands of students.
• Hygiene and sanitation facilities - Toilets are inadequate in number and type; traditional pit
latrines are still being used in many schools with limited access to water supply and has
discouraged a lot of adolescent girls from going to school, especially during their monthly
menstrual cycle. Absence of sick-bays/clinics in most schools denies these girls the opportunity
for proper medical attention which also keeps them out of school.
• Funding - Poor funding of the sector leading to low quality of education
• Poverty - Unfortunately, due to poverty some parents in the rural areas are not able to send their
children to school, rather opt for using their children to hawk especially the Girls to make some
money for the family upkeep. In some northern states the girls are put into hawking early, so they
begin to save up for their marriage. Across the country, where financial resources are limited
parents prioritize boy child education over Girls.
• Access to secondary schools- There is also a huge deficit in the number of secondary schools
available for these primary school leavers to transit to, and in most cases access students need to
travel a distance to access the available secondary schools.
• Availability and Quality of teachers - Inadequate number and lack of qualified teachers; teacher
to student ratios are very low and grossly inadequate to deliver quality learning. More-so, there
are only very few female teachers in Girls schools especially in the rural areas.
• Socio-cultural norms: Early marriage and childbearing, high fertility, gender inequality, large
family size, less importance placed on Girl child development as opposed to their male
counterpart. Age of marriage in the North 13 – 15 years, conversely, in the south early pregnancy
is a major impediment to adolescent girl education.
• Insecurity: Adolescent girls are more at-risk of molestation, Gender Based Violence (GBV) and
Sexual Exploitation and Abuse (SEA). The rate of kidnapping in girls’ school has also become
alarming in the northern part of the country, which has further discouraged parents from enrolling
their girl child in school.
• Vulnerability: Girls with disabilities are usually disadvantaged in accessing education facilities as
most schools do not have disable-friendly structures. Girls who have also become internally
displaced (IDPs)due to insurgency are also at a disadvantage from limited/lack of access to
education.
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ES4. Environmental and Social Risks and Impacts
Positive Impacts
The AGILE Program is envisaged to have a wide range of beneficial impacts including:
• Provision of better and more conducive environment for learning from facility renovations and
constructions
• Improved health status in schools due to provision of hygiene and sanitation facilities in schools
• Decrease in gender gap in education as more Girls will have access to school and also reduce travel
distance
• Marketable skills training will equip Girls with means of income generation, reduce financial
dependency and exposure to SEA. They will also be able to assist their families in improving their
economic status, and scale up the availability of semi-skills in the State for employment
• Decrease in the rate of early marriage and early pregnancy since more Girls will be engaged in
school activities thus reducing idle time. The conditional grants will also provide some form of
livelihood support for the Girls thus reducing their dependency for financial support
• Increase in access to good schools nearby will decrease risks of GBV and exposure to sexual
exploitation from school trips
• The project will support in encouraging behavioral attitude towards girl child education especially
at the community level thus increasing the value and importance of the Girl child
• During construction phase, some construction materials will be sourced from local businesses and
stores, some of the locals will also be used as construction workers, food vendors and sellers of
other essential commodities will have more business, which will boost income activities in the
project locations
Risks and Negative Impacts and Mitigation Measures
The environmental and social impacts identified at this stage are preliminary in nature and will need to
be further elaborated in terms of potential (likelihood) for occurrence and severity when the exact
locations and sub-projects are known.
Environmental Risks Mitigation
• Risks associated with construction including • Noise mufflers should be used on noisy equipment
pollution, waste management, occupational • Stockpiles of sand, clay and other materials should be
health and safety risks, community health & properly covered with trampoline-kind of materials
safety risks, and risks associated with labor influx • Vehicles and machinery should be serviced regularly
• Construction and rehabilitation of school to reduce emissions
classrooms / blocks will imply the generation of • Contractors will develop site management plans
debris of various forms such roof tiles, old irons (including waste management plans) prior to
sheets wastes, bricks, stones, cements which will commencement of construction works.
need to be removed and disposed or reused. • Toilets will be placed at a minimum required distance
• Use of and movement of heavy-duty trucks from water facilities in accordance with WHO
transporting materials such as sand or stone to guidelines
Construction sites may obstruct traffic flow and • Emergency Preparedness and Response plans will be
cause injury. prepared as part of the ESMPs and also the
contractors management plans
xii
• Generation of hazardous waste and risks of • Ensure that constructions/renovations/expansions
toxicity from poor handling and disposal of e- are not located on steep slopes, landslide or flood
waste materials generated from procured ICT prone areas. If projects are located in areas prone to
systems these risks, then proper retaining walls and
• Burning of e-waste and debris as a strengthening of slopes should be done to minimize
disposal/management procedure may increase risks
the risk of global warming and climate change • Vegetation clearance should be limited to required
• Removal of Natural Vegetation could disturb the areas (except for clearance of grasses as part of
natural ecosystem, lead to soil erosion and creating a clean environment)
exacerbate climate change • The ESMPs will contain Physical and Cultural
• Excavation may lead to chance find and affect Resources Plan/chance Find Procedure
Physical and Cultural Resources • Contractors will prepare borrow pit management
• Sourcing of construction materials such as sand, plans prior to construction works.
clay, gravels will lead to impacts related to sand • All borrow pits created for the project purpose must
mining and extraction of gravel from borrow pits be reclaimed to as near as its original state as possible
or quarries • The PIU should liaise with public utility providers
• Disruption of traffic and public utilities deliveries including Ministries of Work/LGA to map locations of
public utilities prior to site clearance
Social Risks Mitigation
• Displacement of people (temporary squatters, • Activities that will involve major land acquisition will
IDPs, Military) and restriction of access not be funded by this project. A stand-alone
• Facilities may become over-stretched from over- Resettlement Policy Framework (RPF) has been
enrolment prepared for this project and Site-specific
• Social norm disagreements with the project goals Resettlement Action Plan (RAPs) will be prepared for
and implementation modalities sub-projects
• Social risks arising from grievances on selection of • Participating schools should identify their growth
participants for grants and social norm plans and estimates on capacity of facilities to
disagreements with the project objectives enrolment ratio and the PIUs should comply with this
• The project may face influx of labor to local plan
communities especially where skilled laborers are • Use of local labor should be encouraged and this
not available in some project sites. This could should be done in consultation with the community
lead to Increase in potential spread of STIs/STDs, leaders
HIV/AIDs due to workers on site, increase in • All workers should sign Code of Conducts
GBV/SEA especially for Girls been exposed to • Sensitization of students and workers on Code of
contractors, sexual relations between contractors Conduct, prevention of STIs/STDs/GBV/SEA risks by
and minors and resulting pregnancies, encourage health workers, Women Affairs, relevant NGOs.
presence of sex workers in the project Stakeholders should be encouraged to report
communities, failure to ensure community inadequate practices through the GBV-GRM, and
participation. these reports should be forwarded to the adequate
• Sexual harassment of female employees for all referral service in line with the project GBV action
categories of workers plan.
• Under-aged children may be used by contractors • The PIUs should monitor compliance with the project
as cheap labor Labor Management Procedures
• There could also be incidences of forced labor or • Contractors should be sensitized on the prohibition of
poor terms and conditions of employment use of children as labor and the associated sanctions
• Grievances could also ensue from unfair • Workers Grievance Redress Mechanism (GRM) should
treatment of workers be provided in the ESMPs and all workers should be
• Inadequate resettlement practices for informed of the process
displacements, land acquisitions, livelihoods • The project should comply with the provisions of the
RPF/RAPs, associated grievances should be channeled
and addressed through the project GRM.
xiii
disturbance, acquisition of borrow pits/ staging Transactional agreement for borrow pit/staging
areas/ workers campsite could lead to conflicts area/workers campsite acquisition/lease should be
• Vulnerable Groups and people with disabilities properly documented and adjudged as fair (by the
may be disadvantaged from gaining from the SPIU social safeguards officers)
project • Building designs should be disable friendly and
• There could be general failure to ensure deliberate attempts at supporting vulnerable groups
community buy-in and participation in project should be made by the project
implementation which could hamper project • There should be adequate consultation with
sustainability community and school stakeholders to ensure their
buy-in and participation.
Occupational and public Health Impact and Safety Mitigation
• Site workers will be exposed to risks of accidental • Contractors will prepare Occupational Health and
collisions with moving vehicles, strains, and Safety Plans in line with the ESHG provided in this
ergonomics from repeated movements or from ESMF (annex 3) and site specific ESMPs that will be
lifting and heaving of heavy objects, slips and prepared for the sub-projects
falls. Accidental cuts from tools and machines are • The project workers and contractor will abide by the
also safety risks. Labor Management Procedures provided for this
• Dust and particulate emissions and welding project
works from rehabilitation site may cause • Contractors waste management plans will include
respiratory and eye impairment health concerns handling and management of hazardous waste
for workers and the public • Provision and use Personnel Protective Equipment
• Movement of trucks carrying sand and materials, (PPE) by workers will be enforced
lack of road safety may also cause risk of • First aid will be provided at construction site, staging
accident, injury and death area and mobile
• Some hazardous materials maybe used during • Provision of potable water, toilets and wash water to
this project and contact with such may pose skin the workers
problems or otherwise • The SPIU will assess living conditions of workers’
• Workers may be exposed to insecurity camps and ensure appropriate living conditions in line
• Grievances may arise from unfair treatment of with best practices
workers, poor work conditions and poor labor • Contractors will develop and implement drivers
management practices training plan in conjunction with Road Safety/ State
Traffic Management Agencies
• Caution signs and flagmen will be used at strategic
locations to provide warning and guidance especially
for children crossing
• Construction activities can maximize the holiday
periods (usually in late March – late April, mid-July –
mid September, early December – early January), or
after school hours
• The PIUs and contractors should collaborate to
develop security management plans and liaise with
police/ Military where required.
• Community leaders should also be used to sensitize
their youths to desist from such nefarious activities
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Gender-Based Violence (GBV) Risks
GBV risks in the project is substantial due to the nature of the project which is centered around adolescent
Girls. This could include public harassment including verbal insults, physical abuse, rape, harmful practices
and child trafficking. Specific project GBV exposure may come from the following:
• Having to travel long distances to school exposes the Girls to risks
• Absence of streetlights within schools and around school areas
• Influx of workers to school environment
• Recruitment of male teachers and male staff in the schools
• Lack of awareness on different forms of GBVs and sensitization
• Social norms and beliefs
• Stigmatization of GBV victims
• Conflicts between parents/guardians about the use of funds/conflicting social norms about girls’ access
to education. In such cases, incidents of interpersonal violence (IPV) such as domestic violence may be
exacerbated
• Non-functional referral pathway for GBV victims
A stand-alone GBV assessment is been prepared for the project with defined action plan on mitigating
these risks. The Government will include commitments on GBV in the Environmental and Social
Commitment Plan (ESCP) and ensure that funds are made available timely for implementation of such
action plans. The PIUs will include in the bidding documents (‘pre-qualification’ and ‘employers’
requirements’) key principles and specific requirements to address GBV to reduce and mitigate the risks
of GBV especially during project implementation as explained in section 4.8.4. In addition, female
Guidance Counsellors will be provided in every intervention school, they will also be trained on GBV and
social management procedures. Safe spaces will also be provided for use as their office
Environmental and Social Management Plan (ESMP)
A detailed Environmental and Social Management plan (ESMP) is presented in section 4.6, table 8
consisting of a set of generic mitigation measures to be adopted by contractors and the SPIU during the
implementation and operation of the proposed project to eliminate negative environmental and social
impacts, applying the mitigation hierarchy. The plan also contains monitoring indicators and
responsibilities and budget. Site-specific ESMPs will be prepared when exact project locations and designs
are known.
ES5. Environmental Screening Process
All potential sub-project intervention sites will be screened for Environmental and Social (E&S) impacts
prior to approval by the PIU and the Bank. A key objective of environmental screening is to rapidly identify
activities under the proposed project that have little or no environmental or social issues so that they can
move to implementation in accordance with accordance with the Environmental and Social Standards.
The screening will also categorize sub-projects based on inherent environmental and social risks and
determine which site-specific instruments (ESMP/RAP) will need to prepare to manage such risks. A
generic environmental and social checklist is provided in annex 6, while the screening process is depicted
in figure 5.
xv
ES6. ESMF Implementation Arrangement
To ensure that ESF and ESS standards are mainstreamed and effectively managed there will be a dedicated
Project Coordinating Unit (PCU) at the Federal Level and State Project Implementation Units (PIU) at the
State level for the participating States. Within the Federal PCU and each PIU, there shall be dedicated
environmental and social officers. Chapter six defines the roles, responsibilities and institutional
arrangements and capacity building plan for the ESMF implementation.
Disclosure
Copies of this ESMF and other E&S instruments like the RPF, SEP, ESMPs that would be prepared for the
Project will be made available to the public by the Federal Ministry of Education, as approved by the
Federal Ministry of Environment. In line with the Nigeria EIA public notice and review procedures as well
as the World Bank Disclosure Policy. Specifically, the publication will be launched for 21 days:
In 2 National Newspapers and Local newspapers in the participating states
Radio announcements
Designated centers at the Federal and State levels including Federal Ministry of Education, Federal
Ministry of Environment
Websites of Federal Ministry of Education, Environment and other relevant MDAs
World Bank external website
ESMF/ESMP Budget
S/No Activity Description Estimate US Estimate
($) Naira(N)
1. Capacity Building Training workshops: 30,000 10,800,000
Average of N1,500,000 per state (cost of hiring expert
consultants, venue, refreshment, logistics, training
materials etc.)
Training for building E&S capacity of SPIU-1 day
Training for MDAs monitoring compliance to
mitigation – 1 day
Training for all contractors on HSE, CoC, GRM, C-
ESMP – 2 days
2. Awareness creation Meetings, Workshops and Stakeholder Engagement 19,444 7,000,000
and Sensitization Meetings:
Average of N1,000,000 per state
Sensitization and awareness programs on health
campaigns on STIs/STDs, stakeholder engagement
meetings in schools, communities, at state level,
mobilizing community-based associations for monitoring
3. ESMP Mitigation Implementation of Mitigation measures for E&S 40,061 14,421,960
Costs Risks:
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Average of N2,060,280 per state spread across all
schools in various locations for environmental and
social mitigations
4. Monitoring & Monitoring of implementation of mitigation 116,666 42,000,000
Compliance for E&S measures by SPIU/MDAs including site visits,
logistics
Hiring of consultants/ experts to prepare
ESMPs/RAPs in the 7 states
Disclosure of E&S Instruments for the project
Average of N6,000,000 per state
5. GRM Establishing and operationalizing GRM, GRCs 38,888 14,000,000
Implementation Cost incentives:
Purchase and manage complaint boxes, training of
GRCs, stipend for GRC members for monitoring
and reporting activities, designated phone access,
project monitoring of grievance log/compliant
boxes (twice weekly) etc.
Average of N2,000,000 per state for all sites
6. GBV Prevention and GBV Assessment and implementation of GBV To be captured in stand-alone
Management Action Plan: GBV assessment
Hire GBV expert to map referral services and
sensitize stakeholders especially participating
schools, capacity building for school Guidance and
Counselors on GBV and survivor centered approach
7. Sub-Total 245,059.9 88,221,564
8. Contingency 10% of Sub-total 24,505.99 8,822,156.4
Grand Total 269,565.89 97,043,720
The indicative budget for implementing the ESMF/ESMP is Two Hundred and Sixty-Nine Thousand Five
Hundred and Sixty-Five Dollars ($269,565) equivalent estimate of Ninety-Seven Million Forty-Three
Thousand, Seven Hundred and Twenty naira only (N97,043,720), for estimated 7 states participation
across all participating schools. It includes cost of mitigation and management, capacity building and
strengthening for safeguards, GRM and GBV prevention and management. The details are presented in
the table below:
ES7. Summary of Stakeholders Consultations and concerns
Consultations were held with identified stakeholders including:
• Federal Ministry of Education
• Federal Ministry of Health
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• Federal Ministry of Women Affairs and Social Development
• State Ministries of Education
• State Universal Basic Education Board (SUBEB)
• State Ministry of Women Affairs
• NIPEP (Federal and State)
• School Management/ Principals
• Students
• School Basic Management Committee (SBMC)
• High Level Women Advocate (HILWA)
• Mothers Association
• Parents Teachers Association (PTA)
Key consultations held are categorised below:
• Consultations with stakeholders in Kano, 23-25 October
• Consultations with stakeholders in Ekiti, 30 October–1 November
• Presentation of the ESMF to stakeholders from Federal Ministry of Education and the Bank’s task
team on November 5th at the World Bank Office during the project mission
• Enlarged stakeholder consultation held on 20th November to discuss the identified project risks
and mitigation, institutional responsibilities for implementing the ESMF and general E&S
procedures
Key Findings
Stakeholders at various levels were largely in support of the project as it will help improve the standard
of living and quality of life of adolescent Girls. Key concerns raised by stakeholders included: selection
criteria for the participating schools and the beneficiaries of the grants; importance of advocacy and sensitisation
campaigns especially amongst religious and traditional leaders; risks to GBV for students; ensuring skills provided to
students are relevant to the immediate community and security of students should be ensured, such as through a
perimeter fence. Details of consultations are presented in chapter seven of the report.
ES8. Grievance Redress Mechanism
A Grievance Redress Mechanism (GRM) will be implemented to ensure that all complaints from local
communities are dealt with appropriately, with corrective actions being implemented, and the
complainant being informed of the outcome. It will be applied to all complaints from affected parties. The
SPIU will maintain a Complaints Database, which will contain all the information on complaints or
grievances received from the communities or other stakeholders. This would include: the type of
complaint, location, time, actions to address these complaints, and final outcome. The mechanism for
implementing the GRM will include:
• Setting up Grievance Redress Committees (GRCs) at the community/school level, State/SPIU level,
Federal level and court redress system as a final option
• Complaints boxes located within the school and the community
xviii
• Grievance Log to document grievances received and how they were resolved
• Dedicated phone numbers for access to reporting grievances
The project shall ensure that all complaints are listened to in a fair and honest manner and the best course
of action identified. Chapter eight defines the GRM framework and procedures to be adopted by the
project.
ES9. Labor Management Procedures
The project has developed Labor Management Procedures (LMP) which identifies labor requirements and
sets out the procedures for addressing labor conditions and risks associated with the proposed project
Labor influx is likely to aggravate GBV/SEA issues. Contractors must prepare and sign all levels of CoCs
requested and present a C-ESMP that specifically addresses the aforementioned. The submission and
acceptance of the C-ESMP is a mandatory process, essential prior to the commencement of any form of
civil works. The SPIU is responsible for monitoring compliance to the E&S requirements. Further, given
that teachers will be recruited for targeted training and support, they should be included in the various
categories of direct and indirect staff and workers that fall under the objectives of the LMP.
The LMP is enshrined within the context of the World Bank ESS 2: Labor and Working Conditions. The
risks and impact associated with workers as well as community health and safety, and the risk associated
with labor impact are moderate due to the nature of minimal construction activities which are well
understood and expected to have limited impacts as they can largely be avoided, minimized or managed
through procedures set out in the LMP including:
• Adequate documentation of terms and conditions of employment
• Safe work environment, fair pay and rights of association and collective bargaining
• Non-discrimination and equal opportunity
• Prohibition of child labor and forced labor
• Training of all workers on Code of Conduct
• Compliance with National and international occupational health and safety standards
The LMP also requires every employer, including contractors, to have a Formal Grievance Procedure to lodge
complaints and receive responses, which should be known and explained to the employees by the contractor
and the SPIUs.
ES10. Summary and Recommendation
This ESMF has provided a general view of the environmental and social conditions under which the Project
will be implemented. This ESMF addresses the Project’s need to monitor and mitigate negative
environmental and social risks and impacts of the project and promote sustainability. This report is necessary
xix
at this point of project preparation to inform decision making on project design and modalities for
implementation in such a way as to minimize identified risks and negative impacts.
It has been reiterated throughout the report that the project should be designed and implemented in a
manner that is disability-friendly and to ensure that vulnerable groups are not placed at more disadvantage
as a result of this project.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
CHAPTER ONE: INTRODUCTION
1.1 Background Information
The Federal Government of Nigeria (FGN) has realized the importance of education for individual, social
and political development. Education plays a key role in national development and is an essential path of
a nation’s well-being, the FGN has placed high priority on capacity development as a critical means of
achieving poverty reduction and has responded to this with policy and sector reforms across the entire
education sector and has made significant strides in improving school enrolments to achieve better
educational goals. The United Nations’ International Conference on Population and Development
encouraged governments’ world-wide to ensure access to all to education beyond the primary level. Girl-
child education has been identified as the backbone of the advanced societies of the world and has huge
impact in the Nigerian society and any other society for that matter. Constraints to Girls education differ
from one geo-political region to the other but generally include the following:
• Government Policies and Institutional Capacity: Policies on Girl child education are not unified
across the country and uneven capacity and weak enforcement remain a challenge
• Socio-cultural norms: early marriage and childbearing, high fertility, gender inequality, large
family size, less importance placed on Girl child development as opposed to their male
counterpart
• Inclusion: among adolescent girls there exist varied vulnerabilities – for instance, displaced girls,
girls living with disabilities, pregnant girls etc. are more vulnerable than others
• Economic Barriers: Cost of schooling, demand for child labor, low financial inclusion among
women
• Insecurity: Adolescent girls are more at-risk of molestation, Gender Based Violence (GBV) and
Sexual Exploitation and Abuse (SEA). Insurgency and displacement have also placed affected Girls
at a disadvantage from receiving quality education.
• Access: Secondary schools are not easily accessible, and Girls may have to travel long distances to
get to school
• Quality: poor learning environment, low quality teaching, low relevant skills (like digital skills, life
and livelihood skills).
For Nigeria, a targeted and sustained effort to build human capital, including by ensuring girls from
disadvantaged groups enroll and stay in school, will be key to lowering its high fertility and child mortality
rates – catalyzing a demographic transition. The reduction in fertility rate will free up resources, allowing
the country to increase its investment in the human capital of future generations—providing the basis for
sustained economic development. The Government of Nigeria has made strong commitments to increase
investments in the human capital development with a strong focus on girls. The ERGP through its investing
in people pillar has placed investments in girls as front and center to form the foundation of Nigeria’s
growth. Some states have now declared free compulsory education (Primary to senior secondary), and
the Federal Government has a dedicated National Policy on Gender in Basic Education (2007).
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
1.2 Assessment of the Education Sector
Adolescent Girls Initiative for Learning and Empowerment Program
In Nigeria boys have had less bottlenecks than girls in accessing formal education due to certain
constraints peculiar to the girl child, especially as a result of cultural and social norms that promote gender
discrimination and place less emphasis on Girl education and empowerment, early marriage and early
pregnancy, weak enforcement of Girl child education policies, poverty and inability to cater for school
needs, use of Girls for hawking and other forms of child labor, lack of access to secondary schools amongst
others as described in section 3.8.1
The Federal Government is requesting the support of the World Bank to implement the Adolescent Girls
Initiative for Learning and Empowerment Program that aims to address the critical binding constraints
adolescent girls face in enrolment, retention, completing secondary school education and empowerment
with life skills that are relevant and marketable, in participating states across the country. The project cost
is estimated at $500m. The approach will consist of interventions aimed at keeping girls in school and
provide opportunities for them to, acquire critical life skills and market relevant skills not currently offered
in schools.
1.3.1 Project Development Objectives
To improve completion of quality secondary education and comprehensive life-skills training for
adolescent girls. The approach will consist of interventions aimed at keeping girls in school and provide
opportunities for them to, acquire critical life skills and market relevant skills not currently offered in
schools, the project is structured around four components.
1.3.2 Project Components
COMPONENT/ ACTIVITIES
Component 1: Safe accessible learning spaces
1.1 Subcomponent 1.1: Create new learning spaces
(Expansion of JSS + SSS + teacher package)
1.2 Subcomponent 1.2: Improve learning conditions
(School improvement grants: Rehabilitation of JSS/SSS and school materials)
Component 2: Enabling Families, communities and schools to support girls’ education2
2.1 Subcomponent 2.1. Providing financial support package to families
2.2 Subcomponent 2.2. Community engagement, promoting social and behavioral change
2.3 Subcomponent 2.3 Empowering girls with life skills and digital skills
Subcomponent 2.3.a Life-skills training through safe spaces in schools
Subcomponent 2.2.b. Pilot innovative approach in the delivery of digital skills to
adolescent girls in senior secondary schools
Component 3: Project management, system strengthening, and learning
3.1 Project management
3.2 System strengthening (All line ministries)
3.3 Learning
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
1.3.2.1 Component 1: Safe Accessible Learning Spaces
Aims to improve completion of quality secondary education for adolescent girls by addressing critical
demand and supply constraints
Subcomponent 1.1: Create new learning spaces
(Expansion of JSS + SSS + teacher package)
The component will address access gaps by constructing new schools and renovating or expanding existing
schools through Ministry of Education. To improve quality, the component will provide continuous
professional development for teachers through colleges of education.
Subcomponent 1.2: Improve learning conditions
(School improvement grants: Rehabilitation of JSS/SSS and school materials)
School grants will be provided to improve learning environment as well as address the school’s needs
1.3.2.2 Component 2: Enabling Families, Communities and Schools to Support Girl’s Education
Subcomponent 2.1. Providing financial support package to families
This component aims to provide financial support package to families to incentivize girls transition to and
attendance of secondary school. This will be implemented by state ministries of education in partnership
with private sector.
Subcomponent 2.2. Community engagement, Promoting Social and behavioral change
This component will support behavior and social norms change on the value of girls’ education and
empowerment through media and by engaging traditional and religious leaders to serve as advocates.
Traditional and religious leaders will be engaged via the Network of Traditional and Religious Leaders on
Keeping Girls in School (KGIS Network). The component will support the formation of Mothers association
and boys’ clubs to support and monitor school attendance of teachers and students and feed into the
School Based Management Committee (SBMC) accountability framework.
Subcomponent 2.3 Empowering girls with life skills and market relevant skills
This component aims to empower and prepare adolescent girls to successfully navigate the different
stages of life by equipping them with life skills (negotiation skills, conflict resolution, self-esteem
leadership skills, financial literacy and adolescent health and nutrition) etc. It will also provide market-
relevant skills training and a graduation grant upon senior secondary school completion. It will be
implemented through collaborations with NGOs and private sector.
1.3.2.3 Component 3: Project Management, System Strengthening, and Learning
Subcomponent 3.1 Project management
This component is aimed at project implementation and coordination arrangements, monitoring and
evaluation at the Federal and State levels
Subcomponent 3.2 System strengthening (All line ministries)
This component aims to provide technical support to Federal and state governments in institutional
strengthening, policy review and improve their capacity at the federal, state and local government levels
Support will be provided to ensure effective project implementation and coordination, monitoring and
evaluation and efficiency in service delivery.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Subcomponent 3.3 Learning
Impact evaluations, studies, pilot programs will be supported to facilitate learning that will enable scale
up to other phases of the MPA. Learning will be facilitated from multi-dimensional approaches and allow
lessons to be more easily applied to other operations.
1.3.3 Project Target Beneficiaries
The project will be beneficial to the entire country including the education sector and other
development sectors such as Health. The primary project beneficiaries are disadvantaged- at risk
adolescent girls between 10–20 years old in participating states, indirect project beneficiaries will
include boys and communities at large. Specific beneficiaries will include:
• Adolescent girls especially from disadvantaged and poor families
• Secondary schools across the participating states
• Female teachers
• Federal and State Ministries of Education
• State Universal Basic Education Board (SUBEB)
• Families of participating Girls and the host communities
• The project also targets inclusiveness of vulnerable and special needs students
The project will be implemented across different States with uneven institutional capacity and weak
legislation enforcement, which may pose social and environmental risks in terms of the ability to comply
with the requirements of the Nigerian Environmental Guidelines and the World Bank Environmental and
Social Framework (ESF). Thus, this Environmental and Social Management Framework (ESMF) has been
prepared as part of project preparatory activities to ensure compliance with the ESF.
1.4 Objectives of the Environmental and Social Management Framework
The objective of the Environmental and Social Management Framework (ESMF) is to enhance the quality
and sustainability of the project, and to ensure that the project follows the World Bank’s Environmental
and Social Framework (ESF) requirements as well as the Federal Government of Nigeria’s environmental
policy, laws and regulations. The ESMF will identify the environmental and social risks and impacts of the
project, and develop guidelines for assessing, monitoring and mitigating such impacts, from activities
funded under the project using the mitigation hierarchy. Specific objectives of the ESMF include:
• To ensure the program is carried out in accordance and compliance to Nigerian laws, institutional
and regulatory frameworks and the World Bank Environmental Social Standards (ESS);
• To provide a structure/strategy for the integration of social and environmental consideration at
all stages of the program planning, design, execution and operation of various sub-projects;
• Determine the training, capacity building and technical assistance scope needed to successfully
implement the provisions of the ESMF;
• To establish clear directives and methodologies for site specific instruments including
Environmental and Social Impact Assessments (ESIAs) and Environmental and Social Management
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Plans (ESMPs) that might be required prior to the implementation of specific sub-projects.
1.5 Rationale for the Environmental and Social Management Framework
The proposed project activities are expected to have moderate environmental and substantial social risks,
which can be readily mitigated through appropriate measures. However, locations and site-specific
activities are not known in detail at this moment. Therefore, the ESMF is the required instrument to be
prepared prior to Board appraisal, which will provide a framework for addressing potential risks and
impacts of the proposed project, inform design and decision making, provides guidelines and procedures
to be followed in undertaking site specific Environmental and Social Management Plans (ESMPs) during
project implementation phase.
The ESMF subsequently establishes a unified process for addressing all environmental and social standard
issues throughout the different sub-project implementation at project effectiveness. The effective
implementation of this ESMF will ensure that both substantive concerns of the required World Bank
Environmental and Social Framework and national environmental laws are satisfactorily addressed.
1.6 Scope of Work for Preparation of the ESMF
The scope of work for preparing the ESMF include to:
• Assess the likely environmental and social risks associated with each component and potential
subproject, based on a detailed description of the project, its components and the design of
specific activities
• Consider and apply relevant World Bank Environmental and Social standards (ESS) proportionate
to their risk level in the project
• Compile a summary of key legislative, regulatory and administrative framework, within which the
project will operate, provide an overview of the above legislation in relation to the World Bank
ESS, and make recommendations to address the gaps with respect to the project
• Conduct field visits to schools in participating states to assess social and environmental site
conditions, practices and verify potential risks and impacts
• Establish a clear understanding of the institutional requirements, roles and responsibilities for
adopting and implementing the ESMF
• Develop a screening and assessment methodology for potential subprojects, that will include
environmental and social performance criteria, allow an environmental / social risk classification
and the identification of appropriate safeguards instruments
• identify the required resources and technical assistance to maintain the Client’s capacity for the
Program duration and beyond. Develop a process (including timeline, budget, organizational
requirements, required trainer profiles and expertise) for building and enhancing the capacity of
the institutions responsible for implementing the ESMF
• Develop a Grievance Redress Procedure for the project
• Develop Labor Management Procedures and Occupational Health and Safety measures
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Provide Environmental, Social, Health and Safety (ESHS) Guidelines in accordance with the WB
requirements.
• Additional stand-alone instruments that will be prepared and disclosed along with the ESMF are:
i) Labor Management Procedure (LMP); ii) Stakeholder Engagement Plan (SEP); iii) Resettlement
Policy Framework (RPF); iv) GBV Assessment/ Action Plan and v) Environmental & Social
Commitment Plan (ESCP). These documents shall be prepared and disclosed locally in line with
national extant laws and disclosure procedures, and at World Bank website before project
implementation.
1.7 Analysis of ESS and Regulations
Environmental and social risks and impacts related to the proposed project will be managed as per the
requirements of the applicable environmental regulations in Nigeria and the World Bank Environmental
and Social Standards. The relevance of the ESS to the Adolescent Girls Initiative for Learning and
Empowerment Program has been assessed in this ESMF. The ESS also requires compliance to all relevant
local, national and international policies and legal requirements.
1.8 Approach and Methodology
The preparation of this ESMF followed a step wise approach that was based on the terms of reference for
the consultancy (annex 1) and entailed the following tasks:
1.8.1 Literature Review
Extensive research work, review of relevant policy documents on education at the Federal and state levels
including National policy on education, National Gender Policy on education, National Inclusive policy on
Education, Special Needs Policy on Education, and other project preparatory documents including the
Concept Project Information Document, Project Concept Note and documentations from stakeholder
preparatory workshops.
1.8.2 Environmental and Social Baseline Data Analysis
This included field visits to two proposed participating states in different Geo-Political regions: Kano state
from 23rd – 25th October, and Ekiti State from 30th October – 1st November 2019. During the visit
consultations were held with representatives of the State Ministry of Education, Environment, Finance,
NIPEP, Women Affairs, SUBEB, Mothers Association, School Basic Management Committee (SBMC) where
relevant state policies were discussed and modalities for implementation of the project. Site visits were
also conducted to secondary schools including Girls boarding and day schools, and co-education schools
as well. (Detailed consultations reports are contained in chapter 7 while attendance sheets are presented
in annex 2 respectively).
Baseline information included environmental and social information relevant to all project components,
drawing on existing information from similar Bank projects in Nigeria. The description of the baseline
environment was based on the following data:
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Physical environment: the school environment including infrastructure, size, hygiene and
sanitation facilities, waste management practices, security structures
• Social environment: legislations, cultural practices and norms, gender concerns and
contemporary issues such as GBV/SEA, population, GDP, inflation, income and employment
matters, labor management, security etc.
1.8.3 Identification of potential Environmental & Social Impacts and Mitigation Measures
The potential impacts were identified through a review of the proposed project components the
anticipated changes that could result in light of the socio-environmental conditions (project-environment
interactions). The ESMF presents mitigation measures to either eliminate or minimize adverse
environmental and social impacts of specific actions, projects or programs while also enhancing positive
effects using the mitigation hierarchy.
1.8.4 Stakeholder Consultations
Consultations with stakeholders at various levels, Federal, State and Local Government, school
management, teachers, Girls in school and out of school, formal and informal associations, similar donor
funded projects, formed an integral part of executing the assignment (details of consultations are
presented in chapter 7). These consultations were useful in articulating stakeholders’ perception and
concerns about the project and how these concerns can be addressed.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
CHAPTER TWO: POLICY LEGAL AND INSTITUTIONAL FRAMEWORK
APPLICABLE TO THE PROJECT
2.1 Introduction
This chapter seeks to provide an overview of Nigerian national environmental legislations and policies
linking these with other institutional framework policies (, gender, social inclusion), and identifying World
Bank Environmental and Social Standards that apply to this project. The chapter further assesses the
adequacy of legal and institutional entities in the implementation of this ESMF.
2.2 Policy, Regulatory and Institutional Framework on Environment
2.2.1 National Policy on Environment (Revised 2016)
The National Policy on the Environment aims to achieve sustainable development in Nigeria. The policy
identifies key sectors requiring integration of environmental concerns and sustainability with
development and presents their specific guidelines, and in particular to:
• Securing quality of environment adequate for good health and well-being;
• Promoting sustainable use of natural resources and the restoration and maintenance of the
biological diversity of ecosystems;
• Promoting an understanding of the essential linkages between the environment, social and
economic development issues;
• Encouraging individual and community participation in environmental improvement initiatives;
• Raising public awareness and engendering a national culture of environmental preservation; and
Building partnership among all stakeholders, including government at all levels, international
institutions and governments, non-governmental agencies and communities on environmental
matters.
2.2.2 The Federal Ministry of Environment
The Ministry of Environment is the highest policy making body responsible for addressing environmental
issues in Nigeria. The act establishing the Ministry places on it the responsibility of ensuring that all
development and industry activities, operations and emissions are within limits prescribed in National
Guidelines and Standards and comply with relevant regulations for environmental protection
management in Nigeria as these may be released by the Ministry. To fulfill this mandate, a number of
regulations/instruments are available (See section on National Legal Instruments); however, the main
instruments in ensuring that environmental and social issues are mainstreamed into development
projects is the Environmental Impact Assessment (EIA) Act No. 86 of 1992.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
With this Act, the FMEnv prohibits public and private sectors from embarking on major projects or
activities without due consideration, at an early stage, of environmental and social impacts that may arise
from the project implementation. The act makes an EIA mandatory for all new major public or private
sector projects, including large-scale agricultural projects, and prescribes the procedures for conducting
and reporting EIA studies.
2.2.3 National Legal Instruments on the Environment
2.2.3.1 Environmental Impact Assessment Act No. 86, 1992 (FMEnv)
This Act provides guidelines for activities of development projects for which EIA is mandatory in Nigeria.
The Act also stipulates the minimum content of an EIA as well as a schedule of projects, which require
mandatory EIAs. According to these guidelines:
I. Category I projects will require a full Environmental Impact Assessment (EIA).
II. Category II projects may require only a partial EIA, which will focus on mitigation and
Environmental planning measures, unless the project is located near an environmentally sensitive
area--in which case a full EIA is required.
III. Category III projects are considered to have “essentially beneficial impacts” on the environment,
for which the Federal Ministry of the Environment will prepare an Environmental Impact
Statement.
2.2.3.2 National Environmental Standards and Regulations Enforcement Agency (NESREA)
NESREA was established by NESREA Act No 25 of 2007 as a parastatal of the FMEnv. NESREA is charged
with the responsibility of enforcing all environmental laws, guidelines, policies, standards and regulations
in Nigeria. The Agency also has the responsibility to enforce compliance with provisions of international
agreements, protocols, conventions and treaties on the environment to which Nigeria is signatory. It has
also amended its established Act of 2007 for a new NESREA Act 2018 to strengthen limiting gaps and
enable effective operations.
2.2.3.3 Other Applicable National Legal and Regulatory Instruments on the Environment
REGULATION DESCRIPTION
The National Guidelines and The regulations provide guidelines for management of pollution control
Standards for Environmental measures.
Pollution Control in Nigeria 1991
The Management of Solid and Regulates the collections, treatment and disposal of solid and
Hazardous Wastes. Regulations hazardous wastes from municipal and industrial sources.
1991
National Air Quality Standard The World Health Organization (WHO) air quality standards were
Decree No. 59 of 1991 adopted by the then Federal Ministry of Environment (FMEnv) in 1991
as the national standards. These standards define the levels of air
pollutants that should not be exceeded in order to protect public
health
Urban and Regional Planning Includes planned development of urban areas (to include and manage
Decree No 88 of 1992 waste sites)
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Harmful Wastes (Special Criminal Provides the legal framework for the effective control of the disposal of
Provisions etc.) Decree No. 42 toxic and hazardous waste into any environment within the confines of
1988 Nigeria: It deals with the quality of water to be discharged into the
environment, sets standards and discharge measures for a wide range
of parameters in water discharged from various industries. It also sets
out the minimum/maximum limits for parameters in drinking water
National Environmental National Environmental (Sanitation and Wastes Control) Regulations,
(Sanitation and Wastes Control) 2009
Regulations, 2009 The purpose of this Regulation is to provide the legal framework for the
adoption of sustainable and environment friendly practices in
environmental sanitation and waste management to minimize
pollution.
National Environmental (Noise The objective of the provisions of this Regulation is to ensure
Standards and Control) tranquility of the human environment or surrounding and their
Regulations, 2009. psychological well-being by regulating noise levels.
National Environmental (Surface The purpose of this Regulation is to restore, enhance and preserve the
and Groundwater Quality physical, chemical and biological integrity of the nation’s surface
Control) Regulations, 2010 waters, and to maintain existing water uses.
National Environmental The purpose of this Regulation is to prevent and minimize pollution
(Construction Sector) from construction, decommissioning and demolition activities to the
Regulations, 2010. S. I. No. 19. Nigerian Environment.
2.2.4 State Legislation on Environment
The State Ministries of Environment and Environmental Protection Agencies are created to back up the
mandates of Federal Ministry of Environment at State levels towards the objective of protecting public
health and safety, and to restore and enhance environmental quality and efficient implementation of
environmental programs, Therefore, the state Ministries of Environment/EPA give direction to all issues
concerning the environment, monitor and control pollution and the disposal of solid, gaseous and liquid
wastes generated by various facilities in the states. Some of their functions include:
• Liaising with the Federal Ministry of Environment, to achieve a healthy or better management of
the environment via development of National Policy on Environment
• Co-operating with FMENV and other National Directorates/Agencies in the performance of
environmental functions including environmental education/awareness to the citizenry
• Responsibility for monitoring waste management standards,
• Responsibility for general environmental matters in the State, and
• Monitoring the implementation of EIA studies and other environmental studies for all
development projects in the State. Generally, State laws on environment are still in the evolving
stages. Specifically, for EA, the States rely on that of the Federal Government, the EIA Act 86.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
2.2.5 State Waste Management Authorities
State waste management authorities have been established across several states in the Country with the
following mandate:
• Collection of waste based on the assigned jurisdiction and coverage
• Disposal of waste and in some states recycling of waste
• Management of disposal sites, waste vehicles etc.
• Awareness and sensitization on waste management matters
The capacities of these agencies vary from one state to the other.
2.3 Policy, Regulatory and Institutional Framework on Gender and Child Protection
2.3.1 National Gender Policy (2007)
The National Gender Policy, 2007. Has an overall goal to promote the welfare and rights of Nigerian
women and children in all aspects of life: political, social and economic. The goal includes the elimination
of cultural/religious gender-based biases and harmful cultural and religious practices which rise to
inequalities in gender-role relations in the Nigerian society, by ensuring: ensure equal access to women,
boys and girls to both formal and informal education; ensure that women have access to critical resources
and invest in their human capital as a means of reducing extreme. The policy seeks to plan, coordinate,
implement, monitor and evaluate the development of women in the county. In concrete terms, the
National Gender Policy in Nigeria focus on:
• Contribution towards women’s empowerment and the eradication of unequal gender power
relations in the workplace and economy, in trade unions and in broader society;
• Encouragement of the participation, support and co-operation of men in taking shared
responsibility for the elimination of sexism and redefining of oppressive gender roles;
• Increase the participation of women in leadership and decision-making;
• Ensure that through labor legislation and collective bargaining, the particular circumstances of
women are considered and that measures are promoted to eliminate discrimination on the basis
of gender;
• Ensure that there is a gender perspective in all sectors of development.
2.3.2 Federal Ministry of Women Affairs and Social Development (FMWASD)
The FMWASD was established by Decree No. 30 of 1989. The broad mandate of the Ministry is to advise
the government on gender and children issues and issues affecting persons with disabilities and the
elderlies. The Ministry also initiates policy guidelines and leads the process of ensuring gender equality
and mainstreaming at both the national and international levels.
2.3.3 The Convention on the Elimination of All Forms of Discrimination against Women
(CEDAW) (1984)
Discourages the discrimination against women by any distinction, exclusion or restriction made on the
basis of sex which has the effect or purpose of impairing or nullifying the recognition, enjoyment or
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
exercise by women, irrespective of their marital status, on a basis of equality of men and women, of
human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field.
2.3.4 Child Rights Act (2003)
The act gives full protection to privacy, honor, reputation, health and prevention from indecent and
inhuman treatment through sexual exploitation, drug abuse, child labor, torture, maltreatment and
neglect to a Nigerian Child. It also declares that every child has a right to life, to be allowed to survive and
develop. It also codifies the rights of children in Nigeria (a person below the age of 18 years), consolidates
all laws relating to children into a single law and specifies the duties and obligations of government,
parents and other authorities, organizations and bodies. More particularly, the Act gives full protection to
privacy, honor, reputation, health and prevention from indecent and inhuman treatment through sexual
exploitation, drug abuse, child labor, torture, maltreatment and neglect to a Nigerian Child.
OCCUPATIONAL HEALTH AND SAFETY FRAMEWORK
2.4 Policy, Regulatory and Institutional Framework on Occupational Health and Safety
2.4.1 Labor Act, Chapter 198, Laws of the Federation of Nigeria (LFN) 2004
The Act covers general provisions including:
• Protection of wages
• Contracts of employment and terms and conditions of employment
• Fair treatment and equal opportunities of project workers.
• Hours of work and overtime
• Employment of women
• Labor health matters
• Prohibition of forced labor
• Labor complaints
2.4.2 Factories Act, 1990
The Factories decree 1990 is a landmark in legislation in occupational health in Nigeria. It provides a
substantial revision of the colonial legislation, Factories Act 1958, in which the definition of a factory was
changed from an enterprise with 10 or more workers to a premise with one or more workers thereby
providing oversight for the numerous small-scale enterprises that engage the majority of the workforce
in Nigeria. It stipulates the enforcement of compliance on factories, industries and organizations that
employ labor on the protection of the right of workers to friendly environment, health and safety.
2.4.3 Factories Act, Cap F1, LFN 2004
• Provides a legal framework for the regulation of safety standards for the operation of factories in
Nigeria; and
• Sets out minimum standards for clean and conducive working environments
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
2.4.4 Worker’s Compensation Act (2010)
The Act provides compensation to employees who suffer from occupational diseases or sustain injuries
arising from accidents at workplace or in the course of employment. Payment of compensation (to the
worker or to his dependents in case of death) by the employer is rooted in the accepted principle that the
employer has a duty of care to protect the health, welfare and safety of workers at work.
2.4.5 Federal Ministry of Labor & Employment
The Nigeria Ministry of Labor and Employment is the country’s designated authority for labor-related
matters. The ministry has the authority and capacity to ensure appropriate labor management in the
country. The Ministry is structured into six Zonal labor offices, nine departments consisting of six
professional and three service departments. It operates 36 State Labor Offices and the FCT, 23 District
Labor Offices, Labor Desk Office, Geneva, Switzerland. Recently nine (9) Labor Desk were approved for
nine ministries, department and agencies.
WORLD BANK ENVIRONMENTAL AND SOCIAL FRAMEWORK
2.5 World Bank Environmental and Social Framework
The World Bank Environmental and Social Framework sets out the World Bank’s commitment to
sustainable development, through a Bank Policy and a set of Environmental and Social Standards that are
designed to support this project, with the aim of ending extreme poverty and promoting shared
prosperity. According to the ESF, the applicable Environmental and Social Standards (ESS) to the project
has been discussed in 2.7 below.
2.6 Environmental and Social Standards (ESS)
The ESSs set out the requirements relating to the identification and assessment of environmental and
social risks and impacts associated with projects supported by the Bank through Investment Project
Financing. Where country laws and regulations are inadequate or weak, the ESSs are provided to
strengthen the policy gaps for environmental and social sustainability and risk management of World Bank
funded projects. The application of these standards, by focusing on the identification and management of
environmental and social risks, will support the project in a sustainable manner for the benefit of the
environment and their citizens. According to the ESF, the project environmental risk rating is moderate
because the project proposes to support minor civil works (renovation of schools and classrooms) while
the social risk rating is substantial. There are 8 applicable standards to the proposed project which include:
ESS 1: Assessment and Management of Environmental and Social Risks and Impacts;
ESS 2: Labor and Working Conditions;
ESS 3: Resource Efficiency and Pollution Prevention;
ESS 4: Community Health and Safety;
ESS 5: Land Acquisition, Restrictions on Land Use and Involuntary Resettlement;
ESS 6: Biodiversity Conservation and Sustainable Management of Living Natural Resources
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
ESS 8: Cultural Heritage
ESS 10: Information Disclosure and Stakeholder Engagement
The applicability of these standards to the project is discussed in table 1 below:
Table 1: Environmental and Social Standard Applicable to the Project
Applicable Reason for Application of Standard to the How it will be addressed by the project
Standard Project
ESS 1: Proposed project activities under component 1 This standard requires environmental
Assessment and will include minor infrastructure works in the assessment (EA) of projects/investments
Management of selected schools to include rehabilitation of proposed for Bank financing to help ensure
Environmental existing classrooms, construction of new that they are environmentally sound and
and Social Risks classrooms, replacement of roofs, windows, sustainable, and thus improve decision
and Impacts provision of hygiene & sanitation facilities. Skills making.
centers may also be established with modern
equipment, procurement of laboratory Given that the exact project locations are not
equipment, chemicals, electronic equipment. fully known at this stage, this ESMF, an
Environmental concerns associated with such Environmental and Social Commitment Plan
construction works include waste generation, (ESCP) outlining Government’s commitment,
debris from rehabilitation activities, community and the Stakeholder Engagement Plan (SEP)
health and safety, occupational health and safety will be prepared prior to board appraisal. A
of workers, noise, dust emissions etc. However, stand-alone GBV assessment may also be
these impacts are limited, site specific and can be required for the project.
mitigated.
Site-specific Environmental and Social
The project also poses some social risks as Management Plans (ESMPS) and other
explained in chapter 5 including risks associated required site-specific plans like waste
with labor influx, grievances, social conflicts and management plan, OHS plan etc. will be
exclusion of vulnerable groups from prepared when project locations are known.
operationalizing the project.
ESS 2: Labor and The project will make use of various categories of Labor Management Procedures (LMP)
Working workers, direct and indirect workers who may consistent with ESS2 and National Labor Laws
Conditions face unfavorable terms and conditions of for all categories of workers has been
employment, discrimination, child labor, forced integrated in the ESMF in chapter 9 and a
labor, grievances and unsafe working conditions. stand-alone LMP has been prepared. A
generic OHS plan is also presented in annex 4,
while specific OHS Plans will be prepared as
part of the site-specific ESMPs.
ESS 3: Resource Proposed construction may lead to air, water and This ESMF identifies environmentally friendly
Efficiency and land pollution from emissions, waste generation, options to project activities in the mitigation
Pollution use of resources etc. if not properly managed. measures in section 4.6 of this ESMF.
Prevention; Inefficient use of resources like water and Site specific ESMPs and contractors waste
energy, use of environmentally un-friendly management plans to be prepared will
techniques during construction and operation include mitigation measures to minimize and
could also pose risks. Increased use of fuel-wood manage the risks and impacts associated with
for cooking from increased student’s enrolment resource efficiency and pollution
leading to deforestation and climate change, if management.
there is no switch to environmentally friendly
cook stoves.
ESS 4: Community Schools and project communities may be Site-specific ESMPs will assess this risk and
Health and Safety exposed to risks from project activities during provide mitigation measures.
pre-construction, construction, operation phases
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
including accidents/incidents, pollution, increase A stand-alone GBV assessment and action
in spread of diseases, GBV/SEA, borrow pits etc. plan may also be required for the project.
There is also a risk that project construction may An Environmental, Health & Safety Guidelines
be on erosion/flood prone areas. (EHSG) applicable to the project is presented
in annex 3 in line with the World Bank
guidelines.
ESS 5: Land The project is not planning to finance activities This standard will be addressed in the stand-
Acquisition, that will involve land acquisition, restrictions on alone Resettlement Policy Framework (RPF)
Restrictions on land use, or involuntary resettlement. However, been prepared alongside this ESMF.
Land Use and risks may come from possibility of temporary
Involuntary squatters like IDPs, Military in abandoned schools Site-specific Resettlement Action Plans (RAPs)
Resettlement selected for renovation, expansion of school will be prepared as required when project
facilities, repair of staff quarters may affect locations are known based on screening of
people using the facilities temporarily, erection such sites.
of perimeter fence may affect people crops,
illegal structures or easement. However, these
impacts are expected to be limited and site
specific.
ESS6: Biodiversity Potential environmental risks and impacts The ESMF will provide guidance on screening
Conservation and associated with this ESS will be limited. Potential and mitigation measures to ensure that
Sustainable risks could arise if there are rivers, floodplains, project activities do not alter or cause
Management of wetlands and other fragile ecological systems destruction of any critical or sensitive natural
Living Natural near the selected schools. Vegetation clearing habitats.
Resources could disturb flora and fauna. Increased demand Site specific ESMPs will contain mitigation
for fuel-wood for cooking from increased measures to address these risks
students’ enrolment will lead to more logging
and deforestation if there is no switch to
environmentally friendly cook stoves. Primary
suppliers could source furnishing materials from
reserved areas.
ESS8: Cultural Project activities are not envisaged to pose risks Physical and Cultural Resource Plan (PCR)/
Heritage to cultural heritage since they will occur within Chance Find Procedures will be contained in
the confines of schools. However, excavation and the site-specific ESMPs.
other project activities may lead to encounter of
physical and cultural resources.
ESS 10: There are different categories of stakeholders A Stakeholder Engagement Plan (SEP) is been
Information associated with the project with varying degree prepared as a stand-alone document which
Disclosure and of influence. These stakeholders will need to be will be disclosed prior to board appraisal
Stakeholder identified, engaged effectively in order to
Engagement improve environmental and social sustainability
of the project, enhance acceptance, and make
significant contribution to successful project
design and implementation.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
2.7 Comparison between Nigeria EIA Guidelines and World Bank ESF
The Environmental Impact Assessment Act No. 86 of 1992 requires that development projects be
screened for their potential impact. Based on the screening, a full, partial, or no Environmental impact
assessment may be required. The World Bank ESF though similar in certain aspects, gaps still exist. Some
of the gaps include emerging issues on climate change, Gender Based Violence (GBV), identification and
early consultation with stakeholders; Community Health and Safety etc.
Table 2A: Gaps between the Environmental Impact Assessment (EIA) Act 86, 1992 and the Environmental and
Social Framework (ESF)
Context ESF Environmental Impact GAPs
Assessment (EIA) Act
86, 1992
Risk High, Substantial, Categories I, II &III Criteria for screening differ but
Classification Moderate Risk and low similar
ESS1 Assessment and Environmental Impact EIA regulatory framework aligns well
Management of Assessment Act, No. with the basic ESF Principles.
Environmental and Social 86 1992 (EIA). However, ESF has additional
Risks and Impacts requirements on assessment of
associated facilities, climate change
issues, gender, more extensive
consultation, more intensive
assessment of health issues etc.
ESS 2 Labor and Working Labor Act, Chapter Gaps include emerging issues on
Condition 198, Laws of the contractor’s requirement in the
Federation of Nigeria bidding documents. separate
(LFN) 2004, on requirements for direct workers,
promoting fair contracted workers, primary supply
treatment and equal workers, and community workers.
opportunities of The ESF places responsibility on the
project workers. proponent (borrower) to take
Child Labor Act. 2019 responsibility for ensuring
prohibit child labor or requirements for managing the 4
their engagement categories implemented. While the
under certain Labor Act. places responsibility only
conditions for direct workers (permanent or
casual) employed within or outside
the community.
The child labor Act. 2019 essentially
satisfy requirements of ILO on child
labor and consistent with ESS 2
ESS3 Resource Efficiency Environmental Impact Requirements for pollution
and Pollution Prevention Assessment (Act 86, prevention and waste management
and Management 1992) to avoid or are similar, but the ESF contain
minimize waste additional requirements for
generation and ensure improving efficient consumption of
effective management energy, water and raw materials, as
to avoid, minimis or well as other resources
mitigate adverse
impacts on human
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Context ESF Environmental Impact GAPs
Assessment (EIA) Act
86, 1992
health and the
environment.
National
Environmental
Regulations has
requirements for
pollution prevention,
discharge permits, etc.
ESS4 Community Health Nil Other frameworks such as the
and Safety Petroleum Act, Cap P10,
LFN 2004, Quarantine Act, Cap Q2,
LFN 204 provide for issues on ESS4
Community Health and Safety,
however, these issues are not
adequately covered in the EIA Act
86, 1992, and not often
comprehensively assessed because
the fragmentation of requirements
into various laws
ESS 5 Land Acquisition, Nil Chapter 202 of Nigeria Land Use
Restrictions on Land Use Act, 1990 is the legal basis for land
and Involuntary acquisition and resettlement in
Resettlement Nigeria. However, the issues on
Land Acquisition, Restrictions on
Land Use and Involuntary
Resettlement are not adequately
covered in the EIA ACT 86, 1992
ESS 6 Biodiversity Nil Although provided for in the
Conservation and Endangered Species Act, Cap E9,
Sustainable Management LFN 2004. Gaps exist in the EIA Act
of Living Natural Resources 86, 1992 on issues on biodiversity
and climate change.
ESS 7 Indigenous Nil The provision for Indigenous
Peoples/Sub-Saharan Peoples/Sub-Saharan African
African Historically Historically Underserved Traditional
Underserved Traditional Local Communities are not provided
Local Communities for in the EIA Act 86, 1992.
ESS8 Cultural Heritage Nil The issue on Cultural Heritage is not
provided for in the EIA. However,
the FGN established the National
Endowment for The Arts Act to
foster understanding amongst
cultural organizations in order to
strengthen cultural ties. National
Commission for Museums and
Monuments has responsibility of
physical cultural properties
ESS9 Financial Nil The EIA Act 86, 1992, did not
Intermediaries provide for Financial Intermediaries.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Context ESF Environmental Impact GAPs
Assessment (EIA) Act
86, 1992
ESS10 Stakeholder EIA Act, No. 86 1992 Gaps include guidelines on the; the
Engagement and requires consultation identification of stakeholders and
Information Disclosure of affected people, focused groups including the
State or Local preparation of stakeholders’
Government of the engagement plans and Grievance
proposed activity, Redress Mechanisms, and
contains requirements entrenches stakeholder
for public disclosure of engagement throughout the life
reports cycle of the project
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Table 2B: Gap Analysis: Land Use Act Vs World Bank ESS5
Type of GAP between National Legislation and ESS5
National Legislation ESS5
property
COMPENSATION
Compensations in kind are recommended. ESS5 prefer compensation in kind, while LUA favors
Land Use Act (LUA) 1978 - Assistance should be provided for the cash
alternative land can be allocated by restoration of productivity and achieving
ESS5 recognizes payment for land, while the LUA Act
Lands the issuing authority for the same production levels (at least equivalent to the
does not (because it is owned by Government for
purpose based upon the rights held land replaced). The cash compensation is
common public good)
upon such land. possible if the affected lands account for less
than 20% of the household’s land.
Buildings Compensations in kind are recommended. LUA Compensation valuation is based on depreciated
Land Use Act 1978 -Cash
(houses, Compensation should be based on the present unexhausted value, while ESS5 is based on
compensation for improvements
annexes and value of depreciation, as well as all transaction replacement value
based upon market value.
other affected costs (taxes, permits, etc.).
property)
Land Use Act 1978 - the holder and Harmonized compensation rates for crops does not
For perennial crops, compensation shall
the occupier shall be entitled to consider land restoration and value loss for crops to
consider the production delivery time. For
compensation for the value at the achieve same production levels as required by ESS5
Crops annual crops, the land offered as
date of revocation of their
compensation allows the restoration of
unexhausted improvements which
production.
includes crops and trees
Economic Resettlement program that allows the owner LUA does not consider economic loss due to business
NIL
Impact to gain full trade income flow. relocation or even closure
PAPs should, in addition to the relocation LUA does not have specific provisions to cover
Assistance to
NIL allowance, receive assistance in their assistance (relocation logistics and convenience)
resettled PAPs
resettlement and monitoring thereafter.
Illegal ESS 5 recognizes the right of squatters to assistance
LUA does not have provisions for Relocation assistance and compensation for
occupants/ to relocate
squatters lost of assets (other than land).
Squatters
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Type of GAP between National Legislation and ESS5
National Legislation ESS5
property
Entitled to compensation based on They must be compensated, whatever the type No difference
Tenants the amount of rights they hold upon of legal recognition of their land tenure (formal
land. or informal).
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
The Adolescent Girls Initiative for Learning and Empowerment Program is an Education sector project and
the risks are not envisaged to be high. Based on the ESF, the environmental risk rating is moderate
because the project proposes to support minor civil works under component 1, while the social risk rating
is substantial because the project deals with adolescent Girls (a vulnerable category)and other related
social risks related risks include, conflict/fragility, SEA/GBV and communal conflicts related to social norm
campaigns. However, due to the adaptable nature of the ESF, these ratings will continue to be reviewed
and classified as the project progresses due to, identification of sites, evident changes, increased capacity
of the Government, institutional support structures, unforeseen events and emergencies. Accordingly
reviews and updates will be made to the Environmental and Social Commitment Plan (ESCP), Labor
Management Procedure (LMP), Stakeholder Engagement Plan (SEP) and other necessary instruments.
2.8 Assessment of the Policy and Regulatory Framework for Environmental & Social Concerns
Generally, with regards to environmental and social management issues, legislation is in a continuing
process of development in Nigeria. The ESF promotes the use of country systems in managing
environmental and social risks associated with projects, and when this capacity is judged to the
insufficient, the Bank will agree with the borrower the steps required to strengthen the identified gaps
while the ESS provides support to guide the project. An assessment of the adequacy of the environmental
and social framework to guide the project is provided in Table 3 below including identified gaps and
capacity strengthening options. This section has been guided by the rapid assessment of Nigeria’s capacity
to implement the 10 ESSs undertaken by the World Bank in early 2019 and is also based on the outcome
of review of policy documents and stakeholder consultations.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Table 2: Gaps between the relevant ESF and the EIA including the Assessment of the Government’s Policy and Regulatory
Framework to address the E&S Risks of the Project
E&S Concern Gaps in the National and Sub-National Capacity Strengthening Options Synergy and Support from the ESS
Framework and the ESF
ESS1: Environment Sector • The national policies and guidelines will need to • An ESMF will be prepared early on to:
Assessment and • The EIA Act and guidelines lack detailed emphasize emerging social risks like gender, GBV, identify environmental and social risks
Management of coverage of key ESS issues, particularly workers safety, grievance redress etc. and emerging associated with the project and how they can
Environmental regarding social risks and impacts environmental concerns like climate change be mitigated by planning, design and decision-
and Social Risks • Implementation and enforcement of the laws • These polices need to be effectively domesticated making options
and Impacts and policies is a major challenge due to lack of at the sub-national levels with a lot of awareness define a screening process for sub-projects
adequate skilled manpower to handle ESS provided E&S risks
procedures, limited skillset, manpower and • Trainings on addressing E&S risks and impacts identify capacity strengthening options for
capacity in the FMEnv. will need to be organized at the Federal level and in institutions responsible for managing the E&S
• The capacity of the state’s ministries of the project participating states for the institutions risks.
environment is also limited based on lack of concerned implementing the ESMF, ESCP, Inform design decisions based on E&S risks
awareness of these laws, sub-standard ESMPs, LMP, GRM, GBV Action Plans (as and international best practices
organization, e.g., some do not have EA captured in the training plan table 10) • An Environmental and Social Commitment Plan
departments, limited funding, lack of • The project can promote better synergy between (ESCP) outlining Government’s commitment, and
monitoring tools. the Federal and State Ministries of Woman Affairs Stakeholder Engagement Plan (SEP) will be
and the Gender functions in the Federal and State prepared prior to board appraisal and will be
Ministries of Education/SUBEB through policy reviewed as the project progresses
harmonization and capacity building • A stand-alone GBV assessment may also be
Education Sector • The project can support the review and roll out of required for the project.
• Weak enforcement of the educational policies some of these policies at the state level • Site-specific Environmental and Social
across the states • Support better synergy of these policies in the Management Plans (ESMPs) and other required
• There is also no synergy in the domestication of participating states with respect to geographical site-specific plans like waste management plan,
these policies as different states are guided by peculiarities OHS plan etc. will be prepared when project
varying policies especially with respect to free • Support sensitization and awareness campaigns of locations are known.
education, Girl child education and child these policies and on Girl child education
protection laws. • Promote coordination in the roles of participating
• Lack of Government buy-in and capacity to institutions in the project through capacity building
support some of these policies • Support move to align with international best
• Some states are also in the process of practices
establishing some of these policies that guide • Identify and support existing non-formal structures
Girl child education with defined roles & responsibilities in the project,
• Some sector related policies do not conform incentives, monitoring tools etc. These institutions
with international best practice e.g. ratio of 1: will be key to determine the success of this project
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
40 students for toilet facility against the
international standard of 1:20 Girls
ESS2: Labor and • National legal framework is robust and • The project can create a platform for discussion • The ESCP includes Government’s commitment to
Working implemented well in the formal sector; amongst the FMEnv, Ministry of Labor, State issues relating to labor and working conditions.
Conditions however, casual workers are not given the same Ministries of Environment and Labor management
benefits (such as compensation for injuries, functions for effective coordination of their roles • Labor Management Procedures (LMP) consistent
right to belong to trade unions and bargain with respect to workers safety and protection in the with World Bank ESS2 and National Labor Laws for
collectively, various social security benefit, project, as documented in the institutional roles and all categories of workers have been integrated in the
unequal pay, forced labor, absence of grievance responsibilities for implementation of the ESMF ESMF. In addition, a stand-alone LMP including a
redress mechanism). (table 9), the project Labor Management grievance mechanism for labor disputes has been
• There is no defined labor management Procedures (LMP) and subsequent ESMPs that will developed. A generic OHS plan is also presented in
procedure to guide developmental projects. be prepared. annex 4, while specific OHS Plans will be prepared
• Lack of synergy between FMEnv and Ministry as part of the site-specific ESMPs for the sub-
of Labor limits the efficiency and effectiveness • Assist in capacity building for labor management projects
of labor inspections on projects. based on international best practice (ILO, WB
• Low resources, capacity, standardized tools for standards etc.) and provision of monitoring tools
effective implementation and monitoring of and framework for effective implementation under
OHS standards this project
ESS3: Resource • Existing legal framework to promote • Promote awareness on environmental guidelines to • The ESCP includes Governments commitment to
Efficiency and environmental stewardship, including efficient participating institutions both formal and non- issues relating to resource efficiency and pollution
Pollution energy management, water resources formal under the project in the participating states management.
Prevention and conservation and cleaner production, however through symposiums, Instructional Educational
Management these have not been successfully domesticated (IEC) Materials • This ESMF identifies environmentally friendly
at the sub-national levels and general awareness options to project activities in the mitigation
of these regulations are low. • Strengthen the relevant state functions through re- measures in section 4.6.
• Overlapping mandates amongst ministries of structuring, definition of roles and responsibilities
environment, EPAs, waste management for each player and capacity building for • Site specific ESMPs and contractors waste
institutions, NESREA creates weak cooperation implementing the ESMF (see table 10) and management plans to be prepared will include
and implementation. subsequent ESMPs. mitigation measures to minimize and manage the
• Weak enforcement capacity due to inadequate risks and impacts associated with resource efficiency
human, material resources, low funding • The Project Implementation Units (PIU) will need and pollution management.
• Absence of strong sanctions for defaulters to liaise with relevant agencies to ensure the
project incorporates best practices & technologies
in designs and equipment to be used/supported
under this project
ESS4: • There are general provisions within legal Roles in managing community health and safety risks • Site-specific ESMPs will assess this risk and provide
Community frameworks that protect the public from harm need to be properly defined for formal and non- mitigation measures, and assign responsibilities for
Health and Safety and respond to emergencies including police, formal institutions/groups participating in the project actions during all phases of the project (pre-
NEMA, NSCDC, Traffic Management especially at the community and school levels construction, construction and operational phase
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Agencies, LGAs, NGOs, CBOs, however, their • A stand-alone GBV assessment and action plan may
efforts are usually not coordinated and thus also be required for the project.
results are obtained in silos. • An EHSG applicable to the project is presented in
• Lack of maintenance of public infrastructure annex 3 in line with the World Bank guidelines
(including buildings, water facilities etc.)
during the operation phase of development
projects exacerbate safety risks
• Poor monitoring, evaluation and reporting
framework on community health and safety
ESS5: Land • There is no requirement in the Land Use Act to • The various PIUs will have to synergize with the • A stand-alone Resettlement Policy Framework (RPF)
Acquisition, develop resettlement actions plans, inclusive Ministries/Bureau of Lands in the participating is being developed for the project which sets out
Restrictions on stakeholder consultation, or GRM states to sensitize them on the World Bank guidelines to be adopted by Government concerning
Land Use and • Compensation is limited to crops and Requirements on ESS5 (according to the training issues of Land Acquisition, Restrictions on Land Use
Involuntary improvements on land, often using rates that are plan in the Resettlement Policy Framework) and Involuntary Resettlement in accordance with the
Resettlement out-of-date and not aligned with market value, ESF
and does not factor the interest of land tenants • The Government can leverage on the support of the
• The Land Use Act does not consider restrictions project to update compensation rates to current • Resettlement Action Plans (RAPs) will also be
to access to livelihood sources, vulnerable market rates and this can be adopted state-wide and prepared when project specific locations and designs
groups, other community resources for any developmental purposes are known
• No measures to ensure that the affected people
are offered support for a reasonable transition
period
ESS6: • There are good regulatory frameworks, but with • Promote awareness on regulatory framework in the • The ESMF will provide guidance on screening and
Biodiversity weak implementation and enforcement capacity participating states through symposiums, mitigation measures to ensure that project activities
Conservation and especially at the grassroot levels, Instructional Educational (IEC) Materials do not alter or cause destruction of any critical or
Sustainable • Lack of awareness on such frameworks • Strengthen the relevant state functions through re- sensitive natural habitats.
Management of especially at the sub-national level structuring, definition of roles and responsibilities • Site specific ESMPs will contain mitigation
Living Natural • Duplication of functions amongst various for each player and capacity building for measures to address these risks
Resources MDAs like EPAs, State Ministries of implementing the ESMF and subsequent ESMPs. • The ESF also provides that Primary Suppliers should
Environment, NESREA etc. leads to lack of be audited to ensure compliance with environmental
synergy regulations (this is captured in the mitigation section)
ESS8: Cultural • Environmental policies do not cover the The PIUs will need to liaise with the responsible Physical and Cultural Resource Plan (PCR)/ Chance
Heritage assessments of risks and impacts on cultural ministries for cultural heritage in the State to discuss Find Procedures will be contained in the site-specific
heritage the procedures to adopt in line with the World Bank ESMPs.
• The Federal Ministry of Information and requirements which will be documented in the
Culture focus more on the promotion of ESMPs
festivals as against the protection of community
culture and heritage
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Poor knowledge, skillsets and expertise to
implement ESS8 requirements, including the
preparation of Cultural Heritage Management
Plans
ESS10: Stakeholder consultations are not usually • Stakeholder identification and mapping should A Stakeholder Engagement Plan (SEP) has been
Stakeholder considered as a critical component of be carried out early in the project and updated prepared as a stand-alone document which will be
Engagement and development projects, and stakeholders’ input are during the course of project implementation. disclosed prior to board appraisal.
Information usually not considered in project design which • Stakeholders at various levels should be trained
Disclosure leads to low accountability and unsustainable on the provisions of the Stakeholders
projects after implementation. Engagement Plan (SEP).
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
CHAPTER THREE: EDUCATION SECTOR OVERVIEW
Education is administered by the federal, state and local governments. The Federal Ministry of Education
is responsible for overall policy formation and ensuring quality control but is primarily involved with
tertiary education. School education is largely the responsibility of state (secondary) and local
(elementary) governments. Nigeria’s education system encompasses three different sectors: basic
education (nine years), post-basic/senior secondary education (three years), and tertiary education (four
to six years, depending on the program of study).
3.1 Educational Delivery System
The formal education system is delivered through a number of institutions ranging from Early Childhood
and Care Development (ECCD) classes, mostly attached to primary school settings or provided by partners
in the private sector, through primary and junior secondary schools (under universal basic education
provision), senior secondary schools to universities, colleges of education and polytechnics. Literacy and
non-formal education are provided by various organizations, including Mass Literacy Agency, NGOs and
religious denominations. In general, the quality of education is low based on weak indicators for levels of
learning achievement.
3.2 Baseline Description of the Project Locations
The Adolescent Girls Initiative for Learning and Empowerment Program will cut across participating states
in the country which are not all known for certainty at this time of project preparatory, however, this
section presents description of prevailing deficiencies of the education sector, delivery of quality
education and the school environment with focus on secondary schools. Some information was also
gathered from field visitations made to Ekiti and Kano states, and visits to some schools as mentioned
earlier, and information shared from visits of other teams as part of project preparatory activities. Some
of these challenges include:
• Funding:
Poor funding of the sector leading to low quality of education; annual budgetary allocation of
7.04% in 2018 which is lower than the allocated 7.4% in 2017, and still a far cry from the UN
recommended 26%. Unfortunately, due to poverty some parents in the rural areas are not able
to send their children to school; even when school fees are free, provision of uniforms, books,
bags, transportation, food is a problem. Thus, these parents opt for using their children to hawk
and make some money for the family upkeep.
• Access:
There has been a general increase in physical access to educational provisions for basic and senior
secondary levels and UBE schools (primary and JSS) and increase enrolments. However, current
provisions are inadequate in terms of number of schools available to the school age population.
There is also a huge deficit in the number of secondary schools available for these primary school
leavers to transit to, and in most cases access students need to travel a distance to access the
available secondary schools.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Availability and Quality of teachers:
Inadequate number and lack of qualified teachers; teacher to student ratios are very low and
grossly inadequate to deliver quality learning. There are some challenges relating to teachers’
recruitment, deployment, training, and accountability. There are disparities across urban and
rural schools in teacher deployment, with schools in the rural areas still facing shortage of
teachers. Teacher pay is low and often late, reducing the incentives for teachers to perform and
be accountable for student learning outcomes (SDI-Nigeria, 2013). There are notable similar
support programs across the states addressing some of these issues including (Nigeria Partnership
for Education Project (NIPEP), State Education Program Investment Project (SEPIP), the
Adolescent Girls Initiative for Learning and Empowerment Program can key into and add to the
successes of such projects.
• Physical Environment:
Poor learning environment including untidy environment with uncut grasses especially in Girls
only schools and poor waste management techniques including open dumping and open burning
of waste. While most schools seem to have a defined/planned layout, there are dilapidated and
abandoned buildings that may require demolition, in addition to those in dire need of
rehabilitation. Some school facilities are located in areas prone to erosion which could lead to
building collapse and future hazards.
• Inadequacy of facilities:
- Dilapidated classrooms, damaged roofs, lack of sufficient laboratories and workshop spaces.
Available infrastructures and facilities are overstretched, in poor condition and unable to
meet the demands of students.
- Abandoned buildings are also a major challenge in many schools
- In some schools there are no chairs and tables for students to receive lectures, hence they sit
on the floor.
- Staff rooms and staff quarters are also grossly inadequate.
- Perimeter fence was available in few schools but most of them do not have fence thus
exposing the school to unauthorized access, encroachment and physical danger
- Kitchen facilities make use of firewood as source of fuel thereby causing emissions and public
health hazards
• Hygiene and sanitation facilities:
- Toilets are inadequate in number and type; traditional pit latrines are still been used in many
schools.
- The toilets are usually located in remote and poorly accessible areas in the schools and doors
are always open because the closing handles broke down.
- Cleaning of the toilets floor is problematic due to the lack of soap or detergents
- Water supply is inadequate and many of the toilets did not have any attached water source.
Toilet papers and hand-washing facilities for students and teachers are not provided in many
schools.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
- In some schools, girls are taught to wrap their used sanitary pads in nylons and dump in area
designated for waste burning. While some dump the pads into the toilet for lack of better
options, which leads to blockage and quick fill of the sewage and need for evacuation.
- Evacuation of toilets is usually done by informal sanitation waste collectors with drums on
wheel-barrows and the sewerage is dumped or utilized by the locals as manure
- Schools use boreholes as the main source of water and most schools have only 1 or 2
functional boreholes.
• Basic Amenities:
- Electricity is almost not available in the school and even if available it is often sporadic.
- Most of the schools do not have sick-bays/clinics, untrained medical staff usually
administer medication to students.
• Study Materials, Equipment and Technology:
- Lack of sufficient textbooks for students to use and absence of well-furnished libraries to
cater for the needs of students and teachers
- Use of obsolete and environmentally unfriendly equipment
- ICT classrooms, science laboratories, and skills training workshops are often nonexistent,
or grossly inadequate and/or without any functional equipment.
• Data Availability for Planning:
Across board within the education system, there is weak capacity for the collection, storage and
retrieval of accurate and reliable planning data at all levels of education. Data management
personnel have limited skills for collating, interpreting and analyzing data, and there is a shortage
of IT equipment, software and expertise. Consequently, there is low utilization of existing data
capturing systems.
• Vulnerability:
Vulnerable groups within the population including physically challenged, children with underlying
health conditions like HIV/AIDS, children of nomadic pastorals, are discriminated against. In
addition, most schools do not have ramps or appropriate pathways for people or learners with
physical disabilities.
(The information presented above was obtained largely from consultations and field visits to schools
during the preparation of this ESMF). Baseline description of the project locations are presented in Table
6 below
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Table 3: Baseline Descriptive Pictures of Project Locations
Description and Pictures Description and Pictures Description and Pictures
Plates 2: Firewood use as source of cooking fuel in the boarding
school kitchens Plates 3: Metallic waste within the school premises
Plates 1:Lack of chairs and tables in the classrooms kept for weeks
Exposes the cooks to health hazards due to the fumes. Fire-
The absence of tables and chairs in the classroom, heat and lack of No concrete plans for the disposal of the
wood collection increases menace of deforestation. Felling of
electricity sometimes force students to receive lessons outside the materials
trees exacerbates climate change
classroom
Plates 6: Abandoned out of use female teacher’s
Plates 4: Open dumping of waste within the school premises which is burnt toilet in a day school
periodically through open burning Plates 5: Dilapidated Girls Bathroom in a boarding school
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Plates 7: Traditional pit toilet in use for female students in a boarding
school, no WASH facility nearby Plates 8: Broken fence which poses security challenge to the school
Plates 9: Traditional baking facility using old
smoking technology posing health risk,
environmental pollution and contributing to climate
change
Plates 12: Abandoned building in a school
Plates 11: Use of zinc as classroom partition which emits heat thereby
making the classroom inconducive and exposes the girls to injuries
and tetanus from sharp edges
Plates 10: Hand washing facility for girls within the classroom area
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Plates 14: Female Toilet in an insecure desolate location
Plates 15: Rotting and Falling ceiling in a girl’s
Plates 13: Dilapidated classroom which may have to be demolished hostel,
walls and floors cracked and very old
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
3.3 Social Assessment
The following chapter highlights some of the key social inclusion and social risk issues that can help
determine the potential risks to different stakeholders and the inclusion needs of especially of vulnerable
stakeholders. Major social risks include: conflict/fragility, GBV/SEA, school-based violence,
stigmatization/exclusion from adopting social norms. While important exclusion challenges are related to
displaced populations and people with disabilities, among others. GBV/SEA as well as related school-based
violence will be analysed in a client-led GBV Assessment.
3.3.1 Conflict/fragility challenges
Nigeria continues to face several security challenges in many parts of the country. Widespread conflict in
the North East, the Middle Belt, and the Niger Delta of the country has made it difficult for households to
access basic services and take advantage of economic opportunities. At the root of the security challenges
are faulty governance mechanisms, high levels of poverty and inequality, high unemployment rates
particularly among youth, as well as natural resource degradation and climate change induced stresses.
The nine-year conflict in North-East Nigeria has created a deepening humanitarian crisis. About 2.8 million
children are in need of education-in-emergencies support in three conflict-affected States (Borno, Yobe,
Adamawa). Violence by non-state armed groups and military operations continue to affect millions of
people – and in some cases have targetted the very beneficiary group identified for this project; notably,
in the North-East risks of kidnapping of school girls remains a concern. The conflict combined with the
ongoing military operations and its spill-over into neighboring Cameroon, Chad and Niger have caused the
displacement of over 2.5 million people in the region, of whom 1.9 million are internally displaced in
Nigeria, according to the International Monitoring Organisation (IOM) Displacement Tracking Matrix
(DTM) Round August 2018 . The specific project locations have not been identified however such concerns
may need to be considered
3.3.2 Internally displaced adolescent girls
According to the December 2015 DTM (Displacement Tracking Matrix) report, there are currently over 1.9
million Internally Displaced People (IDPs) in conflict-affected northeast Nigeria (Adamawa, Bauchi, Borno,
Gombe, Taraba and Yobe). The majority of IDPs are in Borno (close to 67 percent), followed by Adamawa
(6 percent) and Yobe (6 percent). Close to 56 percent of IDPs are children, and over 28 percent are five
years old or younger. The number of school-age IDP children by state over the 2014- 2019 period amounts
to between 550,000 and 600,000. The overwhelming majority of IDPs are with host communities, and, in
many instances, IDPs children attend school with host community children. However, there are often
instances where schooling facilities are not available for displaced children, and teaching takes place
either in tents or mobile classrooms. Further, because of their displaced status, completion of education
was disrupted when initially displaced, and this disruption can be a significant challenge for adolescent
children in completing school. Within this context, consideration of IDP-related needs and support for
project design and implementation would be important to enable the ability of IDPs to attend, complete
and access quality learning too.
3.3.3 Social norms around access to Girls education
Discrimination against women and girls is often perpetuated by practices defended by some community
members on the basis of tradition, culture, religion or superstition. Under such social norms, a woman’s
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
role in the family and community is primarily understood as a wife and mother and little value is placed
on her education or her long-term economic independence. This societal expectation puts pressure on
families, to marry off their girls as soon as they reach puberty especially in the north where age of marriage
is placed at 13-15 years. Conversely, in the south girls are more at-risk of Gender Based Violence (GBV)
and Sexual Exploitation and Abuse (SEA) which has led to an alarming rate of early pregnancy amongst
adolescent Girls thus are unable to concentrate on receiving education. According to OXFAM, in Nigeria,
one in four women aged 15-49 has undergone FGM/C, and 48 percent of women aged 20-49 were married
before the age of 18 1.
Some of the drivers of educational exclusion for adolescnet girls are culturally sensitive topics (e.g., child
marriage) and as such, discussion of these issues in some parts of the country is very limited, even amongst
women. A key aspect of the project aims to use behavioral campaigns to change social norms about girls
access to, and completion of, education. Social risks may include, for example, the further isolation or
violent targeting of school girls or those in favor of girls accessing education within the context of
attending these campaigns or endorsing the campaign messages. In this sense, stakeholder engagement
should thoroughly assess the ideal language, pace and targeting of the campaigns to ensure they don’t
exacerbate existing exclusion, stigmatization or violence against girls, female teachers, parents or others
within the community that either attend schools or wish to encourage the attendance of girls in school.
Furthermore, managing how to have safe and robust discussions with those that may be initially
unsupportive of the proposed social norms, without isolating them from their families or communities,
will be critical.
3.3.4 Disability-Inclusion
About 25 million Nigerians had at least one disability, while 3.6 million of these had very significant
difficulties in functioning (The World Report on Disability, 2011). Moreover, given the disparity between
boys and girls in school attendance in Nigeria, young disabled girls tend to be even more excluded than
their male counterparts. Children with disabilities worldwide face cultural, economic and social barriers
from within and outside the education system that directly or indirectly impact their ability to get a high-
quality education. Exclusion of children with disabilities from education has an adverse economic impact
at the family, community, and country level. The schooling deficit experienced by children with disabilities
can become the most challenging impediment to earning an income and long-run financial health as
adults. To this end, it is important that the project design and implementation take into cognizance the
demand and supply side barriers to inclusive education so as not to exacerbate inequality and limit the
ability of persons with disability from attending, completing and accessing quality learning. There are also
other vulnerable and/or disadvantaged groups including female-headed households, child-headed
households, orphans and vulnerable children which should be considered in the design and
implementation of the project. As such, the project should ensure that new and updated school
infrastructure allows for unimpeded access to all including persons with disabilities. School infrastructure
should also consider the design of latrines and hand washing systems taking into account important issues
1
https://policy-practice.oxfam.org.uk/publications/breaking-a-culture-of-silence-social-norms-that-perpetuate-violence-against-wom-620458
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
such as menstrual health, privacy requirements for adolescent girls and water-borne diseases which will
require prevention measures.
3.3.5 Gender Consideration
Gender is a critical factor that affects every aspect of our lives from the distribution of resources, wealth,
work, decision-making, political power as well as access to rights and privileges within the society. Gender
and Education are interwoven and intimately linked as women and men have distinct relationships with,
dependencies on, and expertise regarding their environments. In global gender inequality rankings,
Nigeria is behind its peers and continues to rank at the bottom. In order to close the gender gap in Nigeria,
adolescence is a critical window to intervene, as decision adolescent girls make or are made for them at
this age (for example about their education, marriage, and fertility) have far-reaching and lasting impacts
on their own, their children’s and their future wellbeing
3.3.6 Gender Mainstreaming and Vulnerability Statistics (from recent studies)
Gender Mainstreaming looks at the experience and interests of women and men and using them during
decision-making process. Gender Mainstreaming can stimulate economic growth, raise productivity,
reduce poverty and ensure community support. Nigeria ranks 118 out of 134 countries on the Gender
Equality Index. 2 Women’s disadvantaged position and lack of decision-making power in the social,
economic and political spheres is reflected in policies, laws and resource allocation that thwart progress
towards gender equality in the country. More than 70 percent of women live below the poverty line, and
maternal mortality ratio is among the highest in the world at 576 per 100,000. 3 More than half of people
living with HIV (3.2 million) are women (55 percent).4 Girl enrolment in school lags behind boys, and
represents one third to one quarter of classroom participants depending the state; and two-thirds of the
10.5 million out-of-school children, are girls. 5 Some gender vulnerability statistics conducted by FAO is
shown in table 5 below.
Table 4: Gender Vulnerability Statistics
S/No Parameters Rating
1 Men are more educated than their female counterpart High
2 Men claim monopoly and ownership of farm proceeds Moderate
3. Women have poor access to assets, household and inputs decisions Low
4. Household decisions are mostly taken by men High
5. High rural unemployment exists with women High
6. Fewer female extension agents High
7. Low remuneration for all forms of women’ work High
8. Less respect for women in the society Moderate
6
British Council Nigeria. Gender in Nigeria report 2012; UNDP Human Development Report 2016. See:
http://hdr.undp.org/en/content/gender-inequality-index-gii.
6
British Council Nigeria. Gender in Nigeria report 2012; UNDP Human Development Report 2016. See:
http://hdr.undp.org/en/content/gender-inequality-index-gii.
6
British Council Nigeria. Gender in Nigeria report 2012; UNDP Human Development Report 2016. See:
http://hdr.undp.org/en/content/gender-inequality-index-gii.
6
British Council Nigeria. Gender in Nigeria report 2012; UNDP Human Development Report 2016. See:
http://hdr.undp.org/en/content/gender-inequality-index-gii.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
9. Discrimination against women’s appointment High
10. Less access to credit by women reduces agricultural productivity High
11. Women are prone to GBV High
12. Women are mostly Sexually Harassed High
13. Women are more stereotyped in relation to work Moderate
14. Men have more access to information, training, technologies than females High
Source: FAO and ECOWAS Commission/CGA 2016
Key
The ratings are based on the interaction between the probability of occurrence and the impact significance of
the parameter on women (probability x impact significance).
High – means it is a very common occurrence and puts women at a high disadvantage
Moderate – means it still occurs considerably in some spheres with significant impacts on women
Low – means while it may not be very common, the impacts on women are not as grave as with the other
categories
It is also important to state that these are not World Bank ratings and is unrelated to the overall risk rating for
this project as earlier mentioned.
Gender development indicators based on FAO gender country assessment is presented below, the assessment
involved a comprehensive desk review and a gap analysis, and field work that included focus group discussions,
key stakeholder interviews and observations.
Gender Development Indicator
S/No Parameter
1. Life Expectancy at Birth Female (years) % 55.6
2. Life Expectancy at Birth Male (years) % 53.4
3. Adult Literacy Rate Female (15 and above) % 65.3
4. Adult Literacy Rate Male (15 and above) % 79.9
5. Sex Ratio Males per 1,000 Female 1,026
6. Gender Empowerment Measures % 66.2
7. Combined gross enrolment ratio for primary, secondary and tertiary schools 53.8
Male %
8. Employment Ratio Men to Women in Urban Areas % 42.37
9. Employment Ratio Men to Women in Rural Areas 63.58%
Source: FAO, Nigeria Country Gender Assessment (2018)
A more detailed GBV assessment is being conducted that will highlight relevant statistics given the project
interventions.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
CHAPTER FOUR: PROJECT ENVIRONMENTAL AND SOCIAL RISKS AND
IMPACTS
4.1 Introduction
The environmental and social risks classification for this proposed project is moderate for environmental
and substantial for social as discussed previously in section 2.7. This ESMF highlights areas of interventions
which are likely to generate risks associated with the proposed project. The environmental risks are linked
to the activities under component 1 which proposes minor civil works. The total number of classrooms to
be renovated/ rehabilitated/ constructed with its locations are yet to be determined.
4.3 Potential Project Risks
The potential risks are presented according to the project components.
Component Activities Potential Risks
Component 1: Renovation/ construction of • Risks associated with construction including pollution,
Safe Accessible facilities in schools waste management, occupational health and safety
Learning Spaces Provision of hygiene and risks, community health & safety risks, and risks
sanitation facilities associated with labor influx
• Inefficient use of resources like water and energy
• Displacement of people (temporary squatters, IDPs,
Military) and restriction of access
• Disturbance of biodiversity
• Risks of affecting physical and cultural resources
• Increased security risks exposure for Girls in school like
kidnapping, GBV/SEA
• Risks from lack of maintenance and sustainability of
interventions due to lack of political will and/or lack of
funds
• Facilities may become over-stretched from over-
enrolment
• Facilities may not be disability-friendly thus placing
vulnerable groups at a disadvantage
Procurement of laboratory Generation of hazardous waste, e-waste
equipment, chemicals, Risks of toxicity
electronic equipment
Over-stretching of facilities to cater for the project like the
Continuous professional
Colleges of Education which are not aimed at receiving
development for teachers
direct intervention from the project
through colleges of
education.
Component 2: Provision of financial support • Social risks from political influence and grievances from
Enabling package to families to selection of participating families
Families, incentivize Girls transition to • Absence of sustainability plan after the project
Communities and and attendance of secondary intervention closes
Schools to school • Social norm disagreements with the project goals and
implementation modalities
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Support Girl’s Provision of market-relevant • Social risks arising from grievances on selection of
Education skills training and a participants for grants and social norm disagreements
graduation grant with the project objectives
Media sensitization and • Unacceptability of the project due to cultural/religious
campaigns on the value of beliefs or lack of trust for Government interventions.
girls’ education • Male counterparts may feel aggrieved as non-direct
beneficiaries
Provision of school grants to Risks of funds not reaching the intended targets, fund
schools and other identified mismanagement and lack of accountability; this may result
relevant groups in community tensions due to allocated funds for
beneficiaries not reaching them
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
4.4 Negative Environmental Impacts and Mitigation Measures
Impacts Impact Mitigation Measures
Rating
Pollution and Contamination: Moderate • Stockpiles of sand, clay and other materials should be properly covered
• Increase in fugitive dusts and vehicular emissions and machines with tarpaulin -kind of materials
during civil works will cause air pollution in the project area and • Cement should be stored in a safe ventilated room.
surrounding environment. However, this will be short term, • Vehicles and machinery should be serviced regularly to reduce emissions
moderate and localized • Contractors will develop site management plans (including waste
• Soil/gravel brought for any filling/beautification purposes and management plans) prior to commencement of construction works.
soil removed during site preparation if not properly stored and • Toilets will be placed at a minimum required distance from water facilities
is exposed to the natural elements can be washed off to nearby in accordance with WHO guidelines
streams, rivers and low-lying areas causing sedimentation and • Emergency Preparedness and Response plans will be prepared as part of
contamination. the ESMPs and the contractors management plans
• Improper placements of toilets facilities and boreholes can
cause contamination to groundwater and surface water sources
Increase in soil erosion/ soil contamination Low Ensure that constructions/renovations/expansions are not located on steep
• Removal of vegetation cover will lead to soil erosion which may slopes, landslide or flood prone areas. If projects are located in areas prone to
lead to sedimentation in rivers and waterbodies and exacerbate these risks, then proper retaining walls and strengthening of slopes should be
flooding. done to minimize risks
• Leakages from construction equipment may contaminate the
soil surface
Vegetation Clearance Low • Vegetation clearance should be limited to required areas (except for
• Removal of Natural Vegetation could disturb the natural clearance of grasses as part of creating a clean environment)
ecosystem and exacerbate climate change • Project proponent should ensure that no construction/ expansions are
• located close to wetland or on reservation of surface water bodies
•
Excavation may lead to chance find and affect Physical and Cultural Low • The ESMPs will contain PCR Plans/chance Find Procedure
Resources (PCR)
Sanitation and Waste Management Problems Moderate • Contractors will develop waste management plans, campsite management
• Construction and rehabilitation of school classrooms / blocks plan etc. prior to commencement of construction works
will imply the generation of debris of various forms such roof • A generic contractors campsite management plan is provided in annex 5.
tiles, old irons sheets wastes, bricks, stones, cements which will • Provision of potable water, toilets and wash water to the workers
need to be removed and disposed or reused. • Waste recycling will be encouraged in these schools and school
management should partner with associations that provide recycling
functions with the help pf the PIUs.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Waste generation from workers camps including human feces • Modern Incinerators should be provided for schools as part of project
which can become breeding sites for water-borne diseases and intervention
their leachate pollute surface water sources. • The project should support the capacity of the sanitation departments at
• Presently most schools litter their wastes and cannot properly the LGAs in the participating locations for management of school sanitation
manage them. Civil works will lead to increase in waste burden wastes
on the school management. • Wealth to Waste management can be tied to the planned entrepreneurship
• Increase in solid waste and sanitation waste during operation programs
phase could lead to diseases and pollution
Sourcing of Construction Materials Moderate • Contractors will prepare borrow pit management plans prior to
• Sourcing of construction materials such as sand, clay, gravels will construction works.
lead to impacts related to sand mining and extraction of gravel • All borrow pits created for the project purpose must be reclaimed to as
from borrow pits or quarries. Incidents and injuries could be near as its original state as possible
associated with poorly managed borrow pits and quarries. •
• Un-reclaimed borrow pits could become drowning sites,
accident prone locations, gully erosion, accidents/incidents for
residents and sites for breeding mosquitoes and other vector-
borne diseases
•
Efficient Resource Utilization • Contractors should provide their own source of water without dependency
Competition for resources like water on school water supply or community. In the event this situation is not
viable then contractors must not create conflicts between
students/teachers and their workers
Occupational Health and Safety Moderate • Contractors will prepare Occupational Health and Safety Plans in line with
• Site workers will be exposed to risks of accidental collisions with the ESHG provided in this ESMF (annex 3) and site specific ESMPs that will
moving vehicles, strains, and ergonomics from repeated be prepared for the sub-projects
movements or from lifting and heaving of heavy objects, slips • The project workers and contractor will abide by the Labor Management
and falls. Accidental cuts from tools and machines are also Procedures provided for this project
safety risks. • Contractors waste management plans will include handling and
• Dust and particulate emissions and welding works from management of hazardous waste
rehabilitation site may cause respiratory and eye impairment • Provision and use Personnel Protective Equipment (PPE) by workers will be
health concerns for workers and the public enforced
• Movement of trucks carrying sand and materials, lack of road • First aid will be provided at construction site, staging area and mobile
safety measures may also cause risk of accident, injury and • Provision of potable water, toilets and wash water to the workers
death • The SPIU will assess living conditions of workers’ camps and ensure
• Some hazardous materials maybe used during this project and appropriate living conditions in line with the framework stated in annex 5.
contact with such may pose skin problems or otherwise. • Drivers will undergo road safety training
• Workers may face poor living and labor conditions
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Community Health and Safety Moderate • Contractors will develop and implement drivers training plan in conjunction
• All activities during pre-construction and construction phase can with Road Safety/ State Traffic Management Agencies
cause potential safety hazards to students, teachers and • Caution signs and flagmen will be used at strategic locations to provide
residents who are close to the construction site. This includes warning and guidance especially for children crossing
potential accidents from movement of equipment and vehicles • Construction activities to be carried out during holidays preferably, or
to site, lack of road safety measures, exposure to hazardous otherwise site managers and HSE officer to ensure children stay off
materials and waste equipment areas, staging areas and construction sites.
• If the toilet facilities are not well maintained during the • Stockpiles of sand, clay and other materials should be properly covered with
operation phase, they may become hotspots for fly infestation trampoline-kind of materials
and other pathogens that may cause water borne diseases such • Cements should be stored in a safe ventilated room
as diarrhea, dysentery and typhoid • Recommended toilets are ECO toilets, VIP latrines which are easier to
• Classrooms may be expanded in areas prone to erosion and manage. Maintenance and sustainability plans for sanitation facilities
landslides which could become a disaster should be developed by the PIUs and Government prior to implementation
• Exposure of students to alcohol and drugs as a result of project • Intervention designs should take into consideration erosion prone areas to
activities in the area avoid future disasters.
• Contractors should have responsibility for reporting and investigating
incidents to the PIUs, which should also be reported to the World Bank
Disruption of traffic and public utilities deliveries Moderate • Traffic management plans should be prepared as part of ESMPs
• Some schools in built up areas may cause increase in traffic • The contractors should liaise with the State Traffic Management Agencies
during construction and operation phases in management of traffic during construction, while school management
• Conveyance of materials may cause vehicular traffic should also liaise with these agencies during operations.
• Site preparation may disrupt the supply of public utilities such as • The PIU should liaise with public utility providers including Ministries of
water and electricity during excavation and terracing, electrical Work/LGA to map locations of public utilities prior to site clearance
cables and water pipe passing through the site may be
unearthed, and this may disrupt the supply of these services.
*impact rating is a function of the probability of the impact occurring against the impact significance
4.5 Negative Social Impacts and Mitigation Measures
Impacts Impact Mitigation Measures
Rating
Disturbance from Construction Activities Low • Construction activities can maximize the holiday periods (usually in late
The noise level will disturb the students and interrupt their classes March – late April, mid-July – mid September, early December – early
and disturb also their concentration levels. It is also likely to cause January), or after school hours
hearing impairment to workers and nearby residents. • Noise mufflers should be used on noisy equipment
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Land Acquisition, Displacement of People, Restriction of Access, Moderate • Activities that will involve major land acquisition will not be funded by this
Assets project. School selection must be done according to the project
• Construction and expansion of schools may need land from development objectives and should be in places void of land disputes
private owners/communities • A stand-alone Resettlement Policy Framework (RPF) has been prepared for
• Land acquisition for construction may involve the displacement this project.
of people in proximity of schools especially schools with • Site-specific Resettlement Action Plan (RAPs) will be prepared for sub-
insufficient land. projects
• Building of perimeter fence may affect people’s crops • The project should comply with the provisions of the RPF/RAPs, associated
• Temporary/illegal squatters in selected facilities may be grievances should be channeled and addressed through the project GRM.
displaced including IDPs, Military etc. Transactional agreement for borrow pit/staging area/workers campsite
• Peoples access may also be blocked as a result of the project acquisition/lease should be properly documented and adjudged as fair (by
(easement) the SPIU social safeguards officers).
• Inadequate resettlement practices for displacements, land
acquisitions, livelihoods disturbance, acquisition of borrow pits/
staging areas/ workers campsite could lead to conflicts
Labor Influx Substantial • Use of local labor should be encouraged in the project
• The project may face influx of labor to local communities • All workers must sign Code of Conducts (contractors’ company, company
especially where skilled laborers are not available in some management, skilled and unskilled labor, sub-contractors etc.), see annex
project sites. This could lead to Increase in potential spread of 11 for sample. Workers campsite should be located away from social
STIs/STDs, HIV/AIDs due to workers on site, increase in GBV/SEA sensitivities in line with the campsite management plan in annex 5
especially for Girls been exposed to contractors, sexual relations • Sensitization of students and workers on Code of Conduct, prevention of
between contractors and minors and resulting pregnancies, STIs/STDs/GBV/SEA risks by health workers, Women Affairs, relevant NGOs
encourage presence of sex workers in the project communities • A stand-alone GBV assessment and action plan is been prepared for this
• This could also lead to competition for resources like water, project. The PIUs should ensure actions are implemented
health facilities, electricity in the project locations • A GBV-GRM will be constituted for the project with access for the Girl
student in line with project GBV Assessment.
• Female Guidance Counsellors will be provided in every intervention school,
they will also be trained on GBV and social management procedures. Safe
spaces will also be provided for use as their office
• The ESMPs should identify possible areas of competition for resources and
indicate where necessary the need for contractors to make provisions for
such resources/ where the project should provide these resources e.g.
drugs in the primary healthcare centers
Potential Child Labor and Forced Labor Substantial • The PIUs should monitor compliance with the project Labor Management
• Under-aged children may be used by contractors as cheap labor Procedures
• There could also be incidences of forced labor or poor terms and • Contractors should be sensitized on the prohibition of use of children as
conditions of employment labor and the associated sanctions
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Grievances could also ensue from unfair treatment of workers • Workers Grievance Redress Mechanism (GRM) should be provided in the
ESMPs and all workers should be informed of the process
Security challenges for workers and Equipment Substantial • The PIUs and contractors should collaborate to develop security
The northern region is very susceptible to violence and conflicts and management plans and liaise with police/ Military where required.
civil works are likely to worsen this situation due to the presence of • Community leaders should also be used to sensitize their youths to desist
workers and equipment. from such nefarious activities
Generally, workers may be prone to kidnapping at camp sites and
equipment not well secured may be vandalized or stolen away.
These instances may even cause hoodlums to shift their attention to
these areas especially to sites in remote areas.
Insecurity Risks and GBV Risks during Operation Phase Substantial • Girls should be formed into groups in commuting to and fro school
The project will ultimately lead to increase in Girls enrolment which • All participating schools should be securely fenced round with limited
means more Girls will traverse to school daily and more Girls will also access and on-site trained security personnel
be accommodated in hostels, this may lead to: • Engage the services of monitoring groups to curb such risks including
• Exposure of Girls to sexual exploitation as they traverse to neighborhood inspectors, mother’s association, SBMCs, PTA, Community
school leaders, Religious leaders etc. Tier capacities should also be strengthened
• Increased risk of kidnapping on the way and in school by provision of incentives and monitoring tools.
• Exposure of more Girls to GBV in schools, cultists, alcohol, drugs • The GBV action plan as part of the project GBV assessment should be
• Sexual harassment of female employees for all categories of enforced
workers • Stakeholders should be encouraged to report inadequate practices through
• If the Government cannot sustain the stipends for Girls after the the GBV-GRM, and these reports should be forwarded to the adequate
project tenure this could leave them in a worse off state than referral service in line with the project GBV action plan.
before the project • Government should define a sustainability plan for interventions beyond
the project lifecycle and discuss with the World Bank
• More funding should be allocated to the education sector
• CCTVs can also be put in schools were possible to enable the principal to
monitor the students
Inadequacy of Teachers and Facilities to Cater for Increased Substantial • Government of the participating states must have a plan for teachers’
Enrolment recruitment especially female teachers that respond to the demand of
• Girls enrolment may exceed the rate of teacher recruitment identified schools/communities
especially female teachers • Participating schools should identify their growth plans and estimates on
• Facilities may also not be sufficient to cater for enrolment rates capacity of facilities to enrolment ratio and the PIUs should comply with
especially with the free education policy this plan
• Colleges of Education may not have sufficient capacity for • Incentives should be provided for female teachers. Scholarships can also be
continuous teachers’ development provided for females to get NCE
• Risks of funds not reaching the intended targets, fund • The project can liaise with previous similar education projects to leverage
mismanagement and lack of accountability on their approach. Teachers training can be done in phases
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Community expectations may be raised in view of construction • The project should develop a transparent monitoring and evaluation
of schools, however if schools are not staffed with teachers (and framework at all levels of implementation
female ones too to address security concerns of parents), social
tensions may rise in targeted communities
Vulnerable Groups Moderate • Building designs should be disable friendly and deliberate attempts at
• Vulnerable Groups and people with disabilities may be supporting vulnerable groups should be made by the project.
disadvantaged from gaining from the project, especially if • Interventions should consider areas in proximity to IDPs so displaced Girls
facilities are disability-unfriendly. can also benefit from the program
• In addition, internally displaced Girls due to insurgency may also
miss out from benefiting from the program
Community Health and Safety Moderate • Contractors will develop and implement drivers training plan in conjunction
• All activities during pre-construction and construction phase can with Road Safety/ State Traffic Management Agencies
cause potential safety hazards to students, teachers and • Caution signs and flagmen will be used at strategic locations to provide
residents who are close to the construction site. This includes warning and guidance especially for children crossing
potential accidents from movement of equipment and vehicles • Construction activities to be carried out during holidays preferably, or
to site, lack of road safety measures, exposure to hazardous otherwise site managers and HSE officer to ensure children stay off
materials and waste equipment areas, staging areas and construction sites.
• If the toilet facilities are not well maintained during the • Stockpiles of sand, clay and other materials should be properly covered with
operation phase, they may become hotspots for fly infestation trampoline-kind of materials
and other pathogens that may cause water borne diseases such • Cements should be stored in a safe ventilated room
as diarrhea, dysentery and typhoid • Recommended toilets are ECO toilets, VIP latrines which are easier to
• Classrooms may be expanded in areas prone to erosion and manage. Maintenance and sustainability plans for sanitation facilities
landslides which could become a disaster should be developed by the PIUs and Government prior to implementation
Exposure of students to alcohol and drugs as a result of project • Intervention designs should take into consideration erosion prone areas to
activities in the area avoid future disasters.
• Contractors should have responsibility for reporting and investigating
incidents to the PIUs, which should also be reported to the World Bank
Grievances Substantial • The project should comply with the GRM provided in chapter 8.
• Social conflict and grievance may arise from selection of • GRMs will also be prepared in the site specific ESMPs.
participants for grants, social norm disagreements with the • Adequate consultation, advocacy and sensitization of all interest groups
project objectives, criteria for school selection and beneficiaries should be carried out throughout the project lifecycle in line with the
of cash transfers and other benefits, and other project activities Stakeholder Engagement Plan (SEP)
• Boys on the other hand may become aggrieved that emphasis is • Advocacy should be done amongst Boy groups as well on the special needs
been paid on Girls only of Girls hygiene and health implications which should create compassion.
• Unacceptability of the project due to cultural/religious beliefs or And Boys will also benefit from these facilities in co-education intervention
lack of trust for Government interventions schools
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
General Project Sustainability Substantial • Mothers/female guardians should be carried along in dispensing of money
• Girls may become exposed to unmonitored spending of money to Girls to enable monitoring
• The project may not be sustained during the operation phase • Sustainability plans should be developed by every state and reviewed by
especially with change in Government the World Bank. (this could be added as part of the ESCP)
• The goals for the skills acquisition component may not be fully • Skills acquisition can be programmed for Fridays and weekends where
achieved due to competition for time with other academic possible to allow for adequate learning hours
activities • Government of participating states need to make deliberate efforts to
• Teachers employed during the duration of the project may lose increase education budgets and develop a sustainability plan to cater for all
their jobs afterwards due to unavailability of funds after the teachers been recruited and payment of incentives to Girls, teachers and
project elapses families
• The benefiting Girls may just be interested in the money and not • The cash transfers/incentives/ grants will be tied to certain conditions as
in gaining quality education will be defined by the project including academic performance, school
• There could be general failure to ensure community buy-in and attendance, payment for qualifying exams etc.
participation in project implementation which could hamper • There should be adequate consultation with community and school
project sustainability stakeholders to ensure their buy-in and participation.
*impact rating is a function of the probability of the impact occurring against the impact significance
4.6 Environmental and Social Management Plan
The range of environmental and social impacts/risks associated with the proposed civil works is described in the matrix table below. The ESMP
matrix outlines the various specific impacts with corresponding mitigation measures, indicator and cost of mitigation. It is expected that majority
of these impacts will occur during the construction phase of the project, while fewer impacts are perceived during the pre-construction and
operation phases but are nonetheless several.
Table 5: Environmental and Social Management Matrix Table
PRE-CONSTRUCTION PHASE
Project Potential Negative Mitigation Measures Indicator Cost ($) Responsibility
Activities Impacts/Risks
Land clearing, erosion, habitats • Stockpiles of sand, clay and other materials Re-vegetated land Part of Contractors
excavation, destruction, fugitive should be properly covered with contractor’s
creation of emission, disruptions to trampoline-kind of materials Burrow pits budget
access, classroom activities, air • Reuse excavated topsoil after necessary reclaimed
creation of and land pollution quality tests
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
burrow pits, • Locate burrow pits away from water bodies Air quality
campsites and and less vegetation areas. parameters within
staging areas • Burrow pits should be reclaimed permissible limits
• Minimize land clearing areas as much as
possible and Revegetate disturbed non -
operational land
• All machineries and vehicles must comply
with international noise standards. These
machineries shall be properly serviced for
‘perfect’ and noise-free operation.
Mobilization Influx of labor to local • Use of local labor should be encouraged in Evidence of signed Part of Contractor Management/SPIUs
of workers to communities/school could the project Code of Conducts/ awareness
site lead to Increase in • All workers must sign Code of Conducts (see Report on training and
potential spread of annex 11 for sample) and be trained on the and sensitization sensitization
STIs/STDs due to workers implications costs
on site, increase in • Workers campsite should be located away Zero incidence of
GBV/SEA especially for from social sensitivities in line with the report of
Girls been exposed to campsite management plan in annex 5 misconduct
contractors, sexual • Sensitization of students and workers on
relations between Code of Conduct, prevention of
contractors and minors STIs/STDs/GBV/SEA risks by health workers,
and resulting pregnancies, Women Affairs, relevant NGOs
encourage presence of sex • Stakeholders should be encouraged to
workers in the project report inadequate practices through the
communities GRM, and these reports should be
forwarded to the adequate referral service
in line with the project GBV action plan.
Land Loss of livelihood, loss of • Ensure full participation of land owners and Compliance with See RPF Participating State Governments
Acquisition/ assets and psychosocial local communities in consultations the RPF
Involuntary impacts • Limit expansion within the school’s owned
Resettlement/ premises Payment of
Restriction of • Compliance with provisions in the RPF and compensation
Access RAPs
Identification Possible social conflicts • Borrow pit selection must be done Evidence of Part of Contractors
of Borrow pits with land owner adequately through all-round level of Transactional Contractors’
and Burrow pits likely to be consultation Agreement for budget
extraction of sites for dumping waste,
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
materials entry points for gully • Borrow pits must be reclaimed once borrow pits 6,000 Monitoring:
from burrow erosion and hotspots for the civil works are completed acquisition (Monitoring) State Project Implementation
pits breading vector-borne • Transactional agreement must be Units
diseases done with the direct land owner Borrow pit
• Land verification with traditional Reclamation Plan
Excavation, Disruption of public rulers and the relevant LGAs
Creation of facilities (wires and power • Contractor should obtain permission Cases of
Access Roads lines) from necessary MDA prior to complaints or
excavation works disruption of
Extraction of • Proper and rapid-notification to PAPs facilities
Materials and Water contamination, in case of disruptions
excavation accidental spillage and • All public facilities must be identified,
water sedimentation and relocation plans put in place in Complaints from
Soil Erosion view of possible disruptions Students or PAPs
• Avoid concrete works close to water
bodies Cases of water
• All equipment used must be in safe turbidity
working conditions and periodically
serviced
• Compact soil immediately after
removal of topsoil
• Monitoring of compliance
•
•
CONSTRUCTION PHASE
Project Potential Negative Mitigation Measures Indicator Cost ($) Responsibility
Activities Impacts/Risks
Extraction of Dust emission, traffic • Enforce speed limit and train drivers • Cases of Part of Contractors/ State Traffic
materials and congestions, accidents and regularly respiratory Contractors Management Agencies/ Road
transport of incidents along the • Avoid extraction and excavation during complaints Budget Safety
materials vehicular route extreme dry season • Dust emission
• Cover stockpiles and install pollution controlled
control devices • Traffic mgt. plan
• Use of PPE • Traffic signs
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Implement Traffic Management Plan • Certificate of
• Use appropriate equipment for crushing attendance for
stones training
Masonry and OHS related risks • Use of PPE Cases of 9,700 Contractors
Carpentry • Availability of Health Insurance for Accidents/Incidents
Works workers
• Presence of functional first aid kids with
transfer First-aider on site/ community
health service worker
Welding Risks of fire outbreak • Use of PPE Cases of Part of Contractor
Works within the working area, • Train, supervise and regular PEP talks with Accidents/Incidents Contractor’s
accidents due to unsafe personnel Budget
working conditions • Ensure machinery and equipment are
Accidents due to always in good working conditions and
inadequate equipment or comply with the ESS-2 guidelines
unsafe • Remove any know hazards within the
work environment
Masonry and Risks of loss of biodiversity • Ensure civil works are far away from water Cases of water 6,000 Monitoring:
Carpentry due to degradation of bodies and natural habitats bodies pollution (monitoring) State Project Implementation
Works water bodies and • Ensure material stockpiles are safely Units
disturbance of natural stored away from such areas
habitats • Stockpiles should be stored in strategic
points
• Stockpiles should be covered during rainy
season or extreme weather conditions
• Monitoring and compliance
Disposal of Increase in waste burden • Implement Waste Management Plan Waste Part of Contractor/ SPIUs
cleared for the school • Contractor should reuse and recycle Management Plan Contractors
materials and management materials Cost
excavated • Only necessary materials should be Evidence of littered
materials Increase in inappropriate excavated from burrow pits wastes
acts of burning waste • Liaise with the state MDA on waste Monitoring
management costs (same
as above)
Extraction of Loss of topsoil and • Reclaim all borrow pits Cases of non- Part of Contractors / SPIUs
materials Landscape value • Hold topsoil and revegetate compliance Contractors
from borrow Cost
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
pits and Associated effects on • Implement OHS Plan and Labor
excavation ecosystem Management Procedures
within the OHS Risk 6,000
school (monitoring)
premises
All Civil works • Disruption of school • Adequate sensitization amongst students Vegetated areas 4,861 Contractors/ School
activities • Install erosion control management
• Noise and dust • Civil works should be done during off- Rainwater
emission school hours Harvesting System
• Risks of soil erosion • Concentrate the construction activities to
due to runoffs water dry season to the extent possible
coming from class • Re-vegetate areas where bare soil is
rooms roofs created due to
construction works
• Site excavation works to be planned such
that a section is completed, constructed
or rehabilitated before another section
begins.
Presence of Presence of foreign • Use of local labor should be encouraged in Evidence of signed Part of Contractor Management/ SPIUs
foreign workers in the school/ the project Code of Conducts/ awareness
workers on communities could lead to • All workers must sign Code of Conducts (see Report on training and
site Increase in potential annex 11 for sample) and be trained on the and sensitization sensitization
spread of STIs/STDs due to implications costs
workers on site, increase in • Workers campsite should be located away Zero incidence of
GBV/SEA especially for from social sensitivities in line with the report of
Girls been exposed to campsite management plan in annex 5 misconduct
contractors, sexual • Sensitization of students and workers on
relations between Code of Conduct, prevention of
contractors and minors STIs/STDs/GBV/SEA risks by health workers,
and resulting pregnancies, Women Affairs, relevant NGOs
encourage presence of sex • Stakeholders should be encouraged to
workers in the project report inadequate practices through the
communities GBV-GRM, and these reports should be
forwarded to the adequate referral
service in line with the project GBV action
plan.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Masonry Risks of increased energy • Ensure minimization and optimization of Monitoring Part of Contractors
works, day to consumption power usage plans for Contractors’
day civil Risks of school building • Ensure equipment, appliances and lights reduction of Budget
works collapse due to old are switched off when not being used; energy use
structures, adjacent to • Install energy saving fluorescent tubes at
rehabilitated structures all lighting points
• instead of bulbs which consume higher
electric energy;
• Explore use of renewable energy like solar
energy
All Overuse of water and • Contractors should make provision for all Evidence of conflict 2,500 Contractors
construction conflicts arising from water civil works with students or
works usage by contractors • Harness rainwater harvesting community
• Promptly detect, repair water pipe, tank members
leak
• Sensitize staff to conserve water; Install
water conserving taps that turn-off
automatically when water is not being
used
Poor hygiene and • Provide mobile toilets Clean toilet Part of Contractors
sanitation due to sewage • Install toilets away from rivers or areas contractors
with shallow groundwater cost
• Always keep clean toilets
Littered wastes • Implement 3R principles (Reducing, Solid waste Bins Part of Contractors
reusing, recycling) wastes; contractors
• Avail solid waste bins and sort garbage Presence of cost
accordingly rodents or rats
• Construction materials left over at the end
of construction are used in other projects
rather than being disposed of
• Use of durable, long-lasting materials that
will not need to be replaced as often
Land Degradation of cultural • Avoid land takes from burial sites, shrines Evidence of See RPF State Project Implementation
Expansion sites or archaeological areas and consider the complaints of Units (SPIUs)
alternative disruption
• Implement the ESS 8
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
All civil works Risks of different work • Train workers on STDs and sensitize them Evidence of 5,000 Contractors/ SPIUs
hazards (falls. Slips, burnt, • Voluntary free medical tests complaint of new
ergonomics, fatigue, • Ensure that all plans and equipment to be disease within the
stress, fire incidents, STDs used are certified by the relevant project area
etc.) authority
• Provide well stocked first aid box to be Emergency Plans
easily accessible within the premises;
• Fire-fighting equipment e.g. fire No of
extinguishers and hydrant systems should accidents/incidents
be provided at strategic locations
• Regular inspection and servicing of the
equipment must be undertaken by expert
• Provide all necessary signage (English and
local language) indicating works in
progress, communicate to public on
segments to be worked on, alternative
routes;
• Circuits must not be overloaded;
• Electrical fittings near all potential sources
of ignition should be flame proof
• All electrical equipment must be earthed
• Keep a record of all hazardous chemicals
used at construction sites
• No eating or drinking in areas where
chemicals are stored or used;
• Provide workers with PPEs regularly
• Ensure that construction workers are
provided with adequate supply of
wholesome drinking water;
All civil works Deterioration of workers • Provide clean water always Cases of complaint Part of Contractors
health • Provide training to workers on OHS from workers Contractor’s
• Workers welfare should be important to based on welfare Budget
Child Labor/Forced Labor contractors and their sleep and work conditions
environment must be conducive
• Contractors must avoid hiring children for Presence of Child
menial activities no matter the situation. labor
No one should be forced to work
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• OHS should be monitored systematically Evidence of forced
Labor
Insecurity at project sites • The proponent must hire a security outfit Cases of insecurity Costs will be SPIUs
in high risk areas as will be identified in complaints integrated in
the ESMPs to provide intelligent tips to a security
contractors assessment
• Contractor should cooperate with as required
administration to appoint security
personnel operating 24 hours where
needed
• Body-search the workers to avoid getting
weapons on site, to ensure nothing is
stolen
• Ensure only authorized personnel get to
site
• Security alarms will be installed in vehicles
and other appropriate devices or areas;
Possible social conflicts • The proponent must ensure a functional Cases of Conflicts Part of Contractors
with students or GRM is in place throughout civil works Contractors’
community members • Community members must be given the Budget
priority during workforce selection
• Identify construction workers by wearing
uniforms and even name tags;
• Prohibit all construction workers from
socializing with students or residents,
collection of timber forestry products
Operation Phase
Project Potential Negative Mitigation Measures Indicator Cost ($) Responsibility
Activities Impacts/Risks
Enrollment/ Disabled Girls/ internally • Facilities design should take into Numbers of Part of State Ministries of Education/
School displaced Girls may not consideration disability-friendly solutions benefiting disabled project SPIUs
Operations benefit from the project • Interventions should consider areas in Girls/ IDP Girls design/
proximity to IDPs so displaced girls can selection
also benefit from the program
Teachers may be • The State Ministries of Education to draw Ratio of Teachers - State Governments/ State
insufficient to match the up a sustainability plan on teacher to Students not Ministries of Education
number of students from recruitment exceeding 1:60
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
increased enrollment to
exceed the national
provision of 1: 60
• Mothers/female guardians should be Minimal incident State State Ministries of Education/
Increased number of girls carried along in dispensing of money to reports Education State Ministries of Women
exposed to harassment, Girls to enable monitoring Budget/ Affairs/ School Management
SEA/GBV • Project should leverage on the use of Functional State Health/
monitoring groups (formal and informal) Guidance and Women
Exposure of Girls to sexual to monitor conduct of the school Girls counselling in Affairs
immoralities, alcohol, within the localities schools programs
substance abuse etc. in • The Guidance and counselling function
school should be strengthened via provision of Number of
safe spaces, specialized trainings and Girls awareness
should be encouraged to seek counsel and campaigns in
report abuse schools
• Sensitization and awareness programs,
sex education should be integrated as part
of school activities
• Access to functional sickbays/clinics
should be provided for the Girls
• The project may not be • Sustainability plans should be developed Monitoring and Part of State State Governments/ State
sustained during the by every state and reviewed by the World Evaluation results Education Ministries of Education
operation phase Bank. (this could be added as part of the Budget
especially with change in ESCP) Long term program
Government • Government of participating states need sustainability index
• Teachers employed to make deliberate efforts to increase
during the duration of education budgets and develop a
the project may lose sustainability plan to cater for all teachers
their jobs afterwards been recruited and payment of incentives
due to unavailability of to Girls, teachers and families
funds after the project
elapses
• Loss of access to grants
may expose the Girls to
social ills
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
School School building collapse • Intervention/design to consider locations Zero incidence/ Part of State Ministries of Education/
Operations from erosion or landslides that are prone to such hazards and ensure accident report on design costs SPIUs
mitigation measures are embedded in the such cases
designs
TOTAL 40,061
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
4.7 Labor Influx
This project may face an influx of non-local labor and working conditions issues as skilled laborers might
not be available in some of the project sites. Therefore, the FPCU/SPIUs will take concrete measures to
mitigate potential labor influx-related risks such as workers’ sexual relations with minors and resulting
pregnancies, presence of sex workers in the community, the spread of HIV/AIDS, sexual harassment of
female employees, child labor and abuse, increased dropout rates from school, inadequate resettlement
practices, and fear of retaliation, failure to ensure community participation, poor labor practice, and lack
of road safety. These risks require careful consideration to improve social and environmental
sustainability, resilience and social cohesion. Mitigation measures included in the ESMP table which must
be monitored by the SPIUs include:
(a) assessing living conditions of workers’ camps and ensuring appropriate living conditions;
(b) establishing proper agreement with host community on equipment staging area
(c) establishing and enforcing a mandatory Code of Conduct for the company, managers and
workers, and an Action Plan for implementation;
(d) ensuring appropriate location for these camps;
(e) taking countermeasures - indicated in the Social Management Plan - to reduce the impact of
the labor influx on the public services; and,
(f) devising and implementing a strategy for maximizing employment opportunities for local
population, including women.
4.8 Gender Based Violence
4.8.1 Introduction and Statistics
Nigeria ranks 118 out of 134 countries on the Gender Equality Index.6 Women’s disadvantaged position
and lack of decision-making power in the social, economic and political spheres is reflected in policies,
laws and resource allocation that thwart progress towards gender equality in the country. More than 70
percent of women live below the poverty line, and maternal mortality ratio is among the highest in the
world at 576 per 100,000.7 More than half of people living with HIV (3.2 million) are women (55 percent). 8
Girl enrollment in school lags behind boys, and represents one third to one quarter of classroom
participants depending the state; and two-thirds of the 10.5 million out-of-school children, are girls. 9
6
British Council Nigeria. Gender in Nigeria report 2012; UNDP Human Development Report 2016. See:
http://hdr.undp.org/en/content/gender-inequality-index-gii.
7
The 2013 Nigeria Demographic and Health Survey (NDHS). See:
https://dhsprogram.com/pubs/pdf/PR41/PR41.pdf.
8
UNAIDS 2017 Data. See:
http://www.unaids.org/sites/default/files/media_asset/20170720_Data_book_2017_en.pdf.
9
NDHS 2013.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
The wide diversity and distinct socio-economic, cultural and political contexts across Nigerian geopolitical
regions and states results in different gender related vulnerabilities. While gender inequitable norms
prevail throughout the country, these vary by region and interact with other structural, community and
individual factors exposing women, girls and boys to some forms of GBV more than others. The
socioeconomic status of women and girls in the northern zones lags behind those in the south: only 3
percent of girls in the North complete secondary school, over two-thirds aged 15-19 years are unable to
read compared to less than 10 percent in the South, and 76 percent are married by age 18 in the
northwest. 10 Child marriage, acceptance of wife beating, restricted movement of women and girls are
more pronounced in the North, and the prevalence of sexual violence, conflict related GBV and SEA is
higher than in the South. In the South FGM, IPV, physical violence by any perpetrator, trafficking and
harmful widowhood practices are more prevalent.
The term ‘gender-based violence’ reflects the underlying and systemic gender inequality which is a key
driver of violence. Gender inequality exists in Nigerian households and communities, as in every society
in the world; it results in women and girls experiencing limited choices, as well as restricted access to
resources and opportunities compared to men and boys. The unequal distribution of power between men
and women, along with engrained norms and rigid expectations on gender roles are the core drivers of
GBV. GBV cuts across culture, level of education and income, religion, ethnicity, and other demographic
indicators. GBV is directed at an individual based on his or her biological sex or gender identity. It includes
physical, sexual, verbal, emotional, and psychological abuse, threats, coercion, and economic or
educational deprivation, whether occurring in public or private life.
4.8.2 Manifestations of GBV
To understand if an act of violence is an act/manifestation of GBV, one must consider whether the act
reflects and/or reinforces unequal power relations between males and females. Many—but not all—
forms of GBV are criminal acts in Nigeria laws and policies
• Physical Violence (such as slapping, kicking, hitting or use of weapons)
• Emotional abuse (such as systematic humiliation, controlling behavior, degrading treatment,
insults, and threats);
• Sexual violence, which includes any form of non-consensual sexual contact, including rape;
• Early/forced marriage, which is the marriage of an individual against her or his will often occurring
before the age of 18, also referred to as child marriage;
• Economic abuse and the denial of resources, services, and opportunities (such as restricting
access to financial, health, educational, or other resources with the purpose of controlling or
subjugating a person);
• Trafficking and abduction for exploitation
4.8.3 National Legal and policy framework on GBV
Nigeria’s national government has taken steps to penalize and address GBV and SEA, although a clear
leadership with the leverage to garner multi-sectoral support to address this complex problem seems
10
NDHS 2013; British Council Nigeria, 2012.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
absent. The institutional champion of women’s and children’s rights and GBV issues within the
government is the Federal Ministry of Women Affairs and Social Development (FMWASD). But it has
limited influence on sectoral ministries who need to enforce policy, insufficient budgetary resources 11 and
insufficient institutional capacity to enact its mandate.
The regulatory framework to address both GBV, SEA and VAC is uneven because the Nigerian legal system
is plural, and different legal systems co-exist, namely, the statutory law, Sharia law in the northern regions,
and customary law in rural areas. The simultaneous application of this three-tier system creates
differentiated degrees of protection to women’s and children’s rights 12 which varies in every state and its
enforcement is weak. There is a lack of clear mandates regarding which institutions oversee child
protection and the design and implementation of violence prevention strategies and provision of services.
Insufficient budget allocation both at national and state levels, coupled with inadequately trained and
staffed structures to provide social welfare, justice, education and health services that are women, child
and survivor-centered. While efforts to provide GBV survivors with basic response services is concentrated
in the NE by international non-governmental organizations or the UN system, there are very limited
government or non-governmental services in the rest of the country, those that exist are for the most part
unregulated, uncoordinated and unpredictable. 13 This is aggravated by a generalized lack of trust of
citizens, particularly women, in the criminal justice system to enforce the existing laws. Moreover, lack of
awareness of laws and knowledge of rights, amidst a context dominated by social norms that legitimate
the perpetration of abuse, stigma and underreporting, results in the consequent impunity of perpetrators,
possible re-victimization of survivors and the reproduction of the cycle of violence.
Two key national laws address GBV: the Child Rights Act (CRA, 2003), and the Violence Against Persons
Prohibition Act (VAPP, 2015) which have been passed by the Federal Capital Territory (FCT) but not by
many of the 36 states, making them inapplicable in those that haven’t adopted them. While CRA has been
passed in 24 states, VAPP has been passed in 4 states in addition to the FCT. Where laws are domesticated,
implementation remains weak as institutional capacities are weak (social welfare, police, family courts).
In practice, the legal and judicial systems provide women and children with little protection against
violence, and timely and adequate support services are scarce and often ill-equipped to respond to
survivors’ needs.
4.8.4 GBV Risks in the Adolescent Girls Initiative for Learning and Empowerment Program
GBV risks in the project is substantial due to the nature of the project which is centered around adolescent
Girls. This could include public harassment including verbal insults, physical abuse, rape, harmful practices
and child trafficking. Specific project GBV exposure may come from the following:
• Having to travel long distances to school exposes the girls to risks
• Absence of streetlights within schools and around school areas
• Influx of workers to school environment
• Recruitment of male teachers and male staff in the schools
• Lack of awareness on different forms of GBVs and sensitization
11 UN Women data from 2011.
12
UN CEDAW 2017.
13
UNICEF 2018.
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• Social norms and beliefs
• Stigmatization of GBV victims
• Conflicts between parents/guardians about the use of funds/conflicting social norms about girls’ access
to education. In such cases, incidents of interpersonal violence (IPV) such as domestic violence may be
exacerbated
• Non-functional referral pathway for GBV victims
A stand-alone GBV assessment is been prepared for the project with defined action plans and the
Government will include commitments on GBV in the Environmental and Social Commitment Plan (ESCP)
and ensure that funds are made available timely for implementation of such action plans. The PIUs will
include in the bidding documents (‘pre-qualification’ and ‘employers’ requirements’) key principles and
specific requirements to address GBV so as to reduce and mitigate the risks of GBV especially during
project implementation. Such measures will include:
- GBV/SEA assessment of project with attendant mitigations actions and costs;
- Mandatory contractors’ code of conduct on sexual harassment;
- Monthly site visits by the safeguard unit/GBV officer to monitor GBV/SEA during
construction/implementation phase;
- Community and workers’ sensitization on GBV/SEA;
- Provision of referral units for survivors of GBV/SEA;
- Provisions in contracts for dedicated payments to contractors for GBV/SEA prevention activities
against evidence of completion;
- Contractor and SPIU requirement to ensure a minimum target of female employment with
incremental rewards of the obtainment of this target.
The project is expected to comply with the GBV assessment and action plans that will be developed for
the project.
4.9 Monitoring Plan
Environmental and Social monitoring is an important component of the ESMF. It establishes appropriate
criteria to validate the predicted impacts and ensure that any unforeseen impacts are detected, and the
mitigation adjusted where needed at an early stage. The plan will ensure that mitigating measures are
implemented during renovation, upgrading and maintenance. The objectives of the monitoring plan are
as follows:
• Improve environmental and social management practices;
• Check the efficiency and quality of the ESMP processes;
• Establish the scientific reliability and credibility of the ESMP for the project
• Help to correct deviations from mitigation measures or unanticipated changes
• Provide the opportunity to report the results on safeguards and impacts and proposed mitigation
measures implementation;
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4.10 Monitoring Procedure
While monitoring indicators, responsibilities and budget have been included in the generic ESMP matrix
table (see table 9 above), site specific ESMPs will also contain a detailed monitoring program. A checklist
can be easily used to ascertain compliance to environmental and social requirements of the subprojects.
A sample checklist that can be used by the E&S consultant is depicted in annex 6.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
CHAPTER FIVE: ENVIRONMENTAL AND SOCIAL SCREENING OF
SUBPROJECTS
5.1 Introduction
This chapter sets out procedures to be adopted for the screening of sub-projects once the project specific
location and design of the subprojects are known, with the aim to identify potential negative impacts and
appropriate mitigation measures.
5.2 Environmental and Social Screening Procedures
The objective of screening is to determine the appropriate level of environmental and social impact
assessment and management for a proposed subproject. Environmental and Social screening process
distinguishes sub-projects and activities that have negative environmental and social impacts or those
which will provide opportunities to enhance positive impacts and identify the appropriate instruments
and plans that will be required to mitigate the envisaged impacts. A generic environmental and social
checklist that can be used for this purpose, for various sub-projects is presented in Annex 6.
All potential sub-project intervention sites will be screened for Environmental and Social (E&S) impacts
prior to approval by the PIU and the Bank. The Environmental and Social Assessment Unit of the State
PIU can carry out the screening or consultants can be engaged to conduct the screening. As shown in
figure 3 below, the sub projects will be subjected to an Environmental and Social Screening (E&S)
procedure using the screening checklist. The 3 possible outcomes from the screening include:
1. carry out a simple Environmental Review if the sub project may create a few minor and easily
mitigated environmental problems, this is for low risk projects;
2. carry out an ESIA for projects with more significant, disperse, irreversible risks, this is for high risk
projects (however, it is not envisaged that any subproject will require ESIA. For subprojects that
require attention to existing environmental problems at the site rather than potential new
impacts, an environmental audit may be more useful than an impact assessment in fulfilling the
EA needs.
3. carry out an ESMP if the sub project may create minor environmental problems that are site
specific and require frequent site visits or construction modifications to minimize or eliminate
impact, this is for moderate and substantial risk projects.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Environmental and Social Screening Procedure
Substantial/
Rehabilitation/Constru Environmental and Moderate Risk
ction – classrooms, Social Screening
Proposal hygiene & sanitation Checklist (ESSC)
Yes ESIA/ESMP/ Develop TOR ESIA/ ESMP ESIA/ESMP
Technical specification facilities, skills (Annex 6)
Feasibility Studies ER /EA Report
acquisition centres, Field Study
fence, repairs, furniture Consultation should be held with
etc. stakeholders at the project
locations and institutional levels
Monitoring Plan;
Training and Capacity
Strengthening Plan;
ESMP costing
ESIA – Environmental and Social Impact Assessment
ESMP – Environmental and Social Management Plan
ER - Environmental Review
EA – Environmental Audit
No further
action
Low Risk Environmental
Statement
Figure 1: Environmental and Social Screening Process
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
5.3 Development of Terms of Reference for ESMP/ESIA
The report of the screening exercise (according to both Nigeria EIA decree and World Bank requirements)
will be sent to the World Bank for review and clearance. Following the review of the screening and
scoping, terms of reference (TOR) and the preparing ESIA/ESMP will be prepared by the client and cleared
by the World Bank.
5.4 Development of Terms of Reference for ESMP/ESIA
The World Bank favors preventive measures over mitigation or compensatory measures, whenever
feasible. The ESIA/ESMP will be carried out by seasoned consultants, the report will be cleared by the
World Bank and disclosed in-country according to national laws, and on the World Bank external website.
5.5 Integrating Environmental and Social Mitigation Measures in Project Design and Tender
Documents
The mitigation measures developed and in subsequent specific safeguards instruments (ESIA/ESMP) will
be integrated into the project design and tender documents. By using this approach, the mitigation
measures will become part of the project construction and operation phase. By including the mitigation
measures in the contract or in specific items in the Bill of Quantities, monitoring and supervision,
mitigation measure implementation could be covered in the engineering supervision provisions of the
contract. This integration is articulated as follows:
Project Design The mitigation measure integration in the design phase will help in
strengthening the benefits and sustainability of the project. Such a step
will enhance the mitigation measures in terms of specific mitigation
design, cost estimation of the mitigation measure, and specific
implementation criteria.
Project Contract The project contractor should be bound by the parameters identified in
the environmental and social assessments (ESMP) pertaining to
specific mitigation measures in the contract. The final acceptance of
the completed works should not occur until the environmental
clauses have been satisfactorily implemented.
Bill of Quantities The tender instruction should explicitly mention the site-specific
mitigation measures, materials to be used, labor camp
arrangements and waste disposal areas, as well other site specific
environmental and social requirements.
Supervision and The purpose of supervision is to ensure that specific mitigation
Monitoring parameters identified in the environmental and social assessment and
as bound by the contract is satisfactorily implemented.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
CHAPTER SIX: ESMF IMPLEMENTATION ARRANGEMENTS
6.1 Introduction
The success of the implementation of the environmental and social standards will depend on
commitment, coordination, capacity and defined roles and responsibilities of actors in the
implementation arrangements. This section defines the roles, responsibilities and institutional
arrangements and capacity building plan for the ESMF implementation. It is highly critical that all relevant
MDAs collaborative effectively as failure to do so will bring ineffectiveness and failure of the program
development objective.
To ensure that ESF and ESS standards are mainstreamed and effectively managed there will be a dedicated
Project Coordinating Unit (PCU) at the Federal Level and State Project Implementation Units (PIU) at the
State level for the participating States. Within the Federal PCU and each PIU, there shall be skilled staff in
the areas of environmental and social management, specifically, environmental and social officers.
6.2 Institutional Roles and Responsibilities for Implementing the ESMF
The roles and responsibilities of the various institutions towards the implementation of the ESMF are
outlined in table 10 below
Table 6: Roles and Responsibilities for ESMF Implementation
Institution Roles and Responsibilities
Federal Project • Ensure timely preparation of all ESF instruments E&S Frameworks
Coordinating Unit • Communicate ESF instruments to all stakeholders at the Federal Level through
(PCU) consultations and disclosure
• Ensure E&S staffing of the State PIUs with qualified officers
• Provide oversight monitoring function on the timely preparation, review and
implementation of site-specific E&S instruments
State Project Steering • Provide support to the State PIU in terms of guidance, conformity and
Committee operation of the ESMF. Specifically;
• Ensure funds are made available by the Government for addressing project
E&S requirements as stipulated in the ESCP, ESMF, SEP, LMP and other plans
• Promote multi-sector dialogue and ensuring conformity
• Sector policy and project harmonization
• Taking decisions on recommendations from the PIU
State Project • Responsible for the day to day implementation of the Project including the
Implementation Unit preparation of annual work plans
• Coordinate E&S planning and response
• Ensure that the project design and specifications adequately reflect the
recommendations of the ESIAs/ ESMPs
• Monitor the project work to ensure that the activities are carried out in a
satisfactory manner
• Progress reports and budgets
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Disclosure of E&S instruments prepared for the project in coordination with
the EA department of the Ministry of Environment/ FPCU
Environmental and • Reviews TOR and ESMPs prepared for the sub-project sites
Social Assessment • Ensure that the project design and specifications adequately reflect the
Officers – PIU recommendations and mitigation in the ESMPs
(Environmental • Co-ordinate application, follow up processing and obtain requisite clearances
Officer, Social required for the project, if required
Officer, GBV Officer) • Prepare compliance reports with statutory requirements
• Develop, organize and deliver training program for the SPIU staff, the
contractors and others involved in the project implementation, in line with
training plan in the ESMF, RPF, SEP, LMP, ESMPs
• Ensures that ES commitment clauses including labor and GBV management
components are contained in the contractors bidding documents and contracts
• Ensure sensitization of contractors and project communities on Code of
Conduct, prevention of STDs/STIs, GBV/SEA
• Establish and implement a Grievance Redress Mechanism
• Ensure contractors prepare their C-ESMPs and implement it
• Monitor contractor’s compliance to the ESMP, Code of Conduct, Labor
Management Plan (LMP) and other site-specific plans prepared including
Occupational Health & Safety (OHS), Waste Mgt. Plan (WMP) etc.
Ministry of Women • Collaborate on sensitization and advocacy on girl’s child education
Affairs, Ministries of • Ensure effective GRM and GBV reporting mechanism at the state level
Education • Implement sex education campaigns in schools and risks associated with
under-age marriage/pregnancy
Local Government • Serve as a liaison between the community members and the project
Authority (LGA) institutions
• assist in the implementation of the proper community mechanism
• awareness campaign for the proposed project, amongst the various relevant
grass roots interest groups
• Monitor and report on project activities to the PIU
• Channel for Grievance Redress Mechanism
CBOs, NGOs, • Monitor and evaluate project activities
Associations, Groups, • Partner with the project on sensitization and delivery of project objectives
School Management • Independent observation of project compliance to E&S Requirements
World Bank • Review and clearance of TORs, ESMF/ESMPs
• Recommend additional measures for strengthening environmental
management
• Provide oversight guidance on E&S
6.3 Capacity Assessment of Institutions to Implement the ESMF
The first step in pursuing capacity building is to identify the capacity building needs of the various
stakeholders. Capacity building should be viewed as a continuous process and it should be viewed as a
process of equipping individuals with the understanding, skills and access to information, knowledge and
training that enables them to perform effectively. An outcome of the public consultations is the capacity
needs assessment for implementation of E&S procedures at the State Ministries, Departments and
Agencies (MDAs) as well as the PIU. Effective implementation of the ESMF can be inhibited by limited
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
technical skills and resource constraints. Some of these capacity gaps have been identified in the
“Assessment of the Government’s Policy and Regulatory Framework” in Chapter 2. Further limitations
identified include:
• limited knowledge of the line MDAs on Nigerian EIA Laws and the World Bank Safeguards policies;
• lack of enforcement of development control regulations;
• lack of coordinated synergy amongst MDAs on E&S planning and response
Effective implementation of the ESMF necessitates the need for technical capacity in the human
resource base of implementing institutions as well as logistic facilitation. Implementers need to identify
and understand the environmental and social issues.
6.4 Training Plan
Table 7: Training Plan for ESMF Implementation
Training Title Participants Timeline Cost ($)
• World Bank ESS Stakeholder State MDAs, FPCU, Project 12,000
Engagement SPIUs Preparatory
• Nigerian EIA Procedural Guideline
Environmental
• Social Clauses in Contractors’
contract and bidding documents
• ESMF Implementation
• Operationalization of Grievance FPCU, SPIUs Prior to 18,000
Redress Mechanism Construction
• GBV Training
• Labor influx management/ Labor
Management Plan
• Occupational Health and Safety/
HSE
• Code of Conduct for Contractors SPIUs, Contractors, Prior to
• GBV Sensitization and Training Supervision Construction
• ESMP Training and Implementation Consultants
TOTAL 30,000
6.5 Disclosure of Documents
The FPCU/SPIUs will make copies of this ESMF and other Safeguard Instruments (such as
ESIA/ESMP/RAP/ARAP) available to the public and relevant MDAs through media advert (radio,
television), community forums and the government official website in line with the National EIA
procedures as stipulated by FMEnv. Specifically, the publication will be launched for 21 days:
In 2 National Newspapers
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Local newspapers in the participating states
Radio announcements
Designated centers at the Federal and State levels including Federal Ministry of Education, Federal
Ministry of Environment
Websites of Federal Ministry of Education, Environment and other relevant MDAs
World Bank external website
6.6 Estimated ESMF/ESMP Implementation Budget
The indicative budget for implementing the ESMF/ESMP is $269,565 (N97,043,720), for estimated 7 states
participation across all participating schools. It includes the cost of mitigation and management, capacity
building and strengthening for safeguards, GRM and GBV prevention and management. The details are
presented in table 12 below.
Table 8: Budget for ESMF/ESMP Implementation
S/No Activity Description Estimate US Estimate
($) Naira(N)
1. Capacity Building Training workshops: 30,000 10,800,000
Average of N1,500,000 per state (cost of hiring expert
consultants, venue, refreshment, logistics, training
materials etc.)
Training for building E&S capacity of SPIU-1 day
Training for MDAs monitoring compliance to
mitigation – 1 day
Training for all contractors on HSE, CoC, GRM, C-
ESMP – 2 days
2. Awareness creation Meetings, Workshops and Stakeholder Engagement 19,444 7,000,000
and Sensitization Meetings:
Average of N1,000,000 per state
Sensitization and awareness programs on health
campaigns on STIs/STDs, stakeholder engagement
meetings in schools, communities, at state level,
mobilizing community-based associations for monitoring
3. ESMP Mitigation Implementation of Mitigation measures for E&S 40,061 14,421,960
Costs Risks:
Average of N2,060,280 per state spread across all
schools in various locations for environmental and
social mitigations
4. Monitoring & Monitoring of implementation of mitigation 116,666 42,000,000
Compliance for E&S measures by SPIU/MDAs including site visits,
logistics
Hiring of consultants/ experts to prepare
ESMPs/RAPs in the 7 states
Disclosure of E&S Instruments for the project
Average of N6,000,000 per state
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
5. GRM Establishing and operationalizing GRM, GRCs 38,888.9 14,000,000
Implementation Cost incentives:
Purchase and manage complaint boxes, training of
GRCs, stipend for GRC members for monitoring
and reporting activities, designated phone access,
project monitoring of grievance log/compliant
boxes (twice weekly) etc.
Average of N2,000,000 per state for all sites
6. GBV Prevention and GBV Assessment and implementation of GBV To be captured in stand-alone
Management Action Plan: GBV assessment
Hire GBV expert to map referral services and
sensitize stakeholders especially participating
schools, capacity building for school Guidance and
Counselors on GBV and survivor centered approach
7. Sub-Total 245,059.9 88,221,564
8. Contingency 10% of Sub-total 24,505.99 8,822,156.4
Grand Total 269,565.89 97,043,720
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
CHAPTER SEVEN: STAKEHOLDER CONSULTATION
7.1 Introduction
In line with the requirements of ESS10, stakeholder consultations will form an integral part of this project,
from project preparatory, implementation through operations. Accordingly, a stand-alone Stakeholders
Engagement Plan (SEP) has been developed for the project.
The ESMF study included consultations with identified stakeholders including government agencies,
project affected areas and social groups. Consultations were conducted from 23-25 October in Kano and
30 October-I November in Ekiti state through interviews and focus group discussions. This involved
intensive stakeholder / public involvement and participation with representatives from:
• Federal Ministry of Education
• State Ministries of Education
• State Universal Basic Education Board (SUBEB)
• State Ministry of Women Affairs
• NIPEP (Federal and State)
• School Management/ Principals
• Students
• School Basic Management Committee (SBMC)
• Mothers Association
In addition, the ESMF was presented to stakeholders from Federal Ministry of Education and the Bank’s
task team on November 5th at the World Bank Office during the project mission. Inputs were made to the
ESMF based on discussions at the meeting including the following:
• The need to include vulnerable groups who may be further disadvantaged from the project
• Stressed the need to ensure interventions include fortification/ establishment of perimeter fences
in selected schools
• Emphasis on the project not skewed towards any land acquisition for construction rather to
expand within existing school premises which could be vertical expansion where space is limited
Enlarged stakeholder consultation was held on 20th November to discuss the identified project risks and
mitigation, institutional responsibilities for implementing the ESMF and general E&S procedures.
Stakeholders in attendance were representatives from Federal Ministries of Education, Women Affairs &
Social Development, Health, representatives of state Ministries of Education, SUBEB, State Ministry of
Health, High Level Women Advocate (HILWA), School Basic Management Committee (SBMC), Principals
of Girls Secondary Schools, Education sector expert, World Bank Task Team and E&S Specialists. Discussion
details are presented in table 18 below.
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
7.2 Summary of Consultations
The following table provides a summary of consultations in terms of key concerns and responses.
Key Concerns Response
Inquiry as to the selection criteria for the It was explained that the states will align with selection
participating schools and also the beneficiaries of the based on poverty mapping. More details will be provided
grants. as the project design proceeds.
The importance of advocacy and sensitisation It was reiterated that such awareness campaigns are
campaigns especially amongst religious and embedded as key components in the proposed project.
traditional leaders was stressed as a critical success Furthermore, the project team has already embarked on
factor to address social norms related to Girl child a series of robust consultations with all interest groups.
education.
Increase in enrolment may lead to increase in There will be sensitization programs for the Girls on risks
exposure of Girls to sexual harassment and of GBV/SEA/STIs/STDs. Female teachers, guidance and
exploitation as they commute to and from school. counsellors, PTA members, Mothers Association etc. will
serve as role model and provide monitoring assistance. In
addition, a stand-alone GBV assessment is been
conducted for the project with detailed action plans to
further mitigate such risks.
It was suggested that the project should also support The project is still at a design phase, though emphasis is
with provision of textbooks. on rehabilitation and expansion of structures, however,
the recommendation will be documented in the ESMF
report.
Concerns on the modalities and effectiveness of the The skills component is been designed in a manner that
provision of marketable skills, which was emphasised will provide beneficial skills which is currently not been
should be useful within the context of the immediate offered to the Girls. This will also drive on a need’s
community. assessment.
With respect to security, stakeholders stressed the This will be looked into in the project design, however,
need for perimeter fence in all schools to be such intervention will be geared at access restriction as
supported. opposed to fortified fortress like structures.
Table 9: Summary of Enlarged Consultations with Stakeholders in Kano
Date of meeting 24th October 2019
Venue NIPEP Office, Kano State Ministry of Education
Participants Representatives from SME, KSSUBEB, NIPEP, SMoF, Social Mobilisation Officer, SMBC
Purpose of the To inform stakeholders of the proposed project, obtain their perception and seek likely
Meeting environmental and social risks that may be associated with the project
Major Findings • The state has a policy on free and basic compulsory education
and Discussion • The state also has a Girls Education Policy
Areas • Girls have a lower rate of passing pre-qualifying exams in SS2 and thus some of them drop
out as they will be required to pay for the exams for a re-sit
• Other factors that lead to low enrolment and retention of Girls include: access to
secondary schools, poverty, security/GBV risks, kidnapping, social norms placing no value
on education of Girls, early marriage, child labor
• There is huge infrastructure adequacy in schools and also inadequate teachers, especially
female teachers as they do not want to travel long distances to get to work, also due to
the absence of conducive staff quarters
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
• Hygiene and waste management practices in the schools are not environmentally friendly
• School selection will be based on poverty mapping
• Major risks from the project will include: social norms not agreeing with the project,
grievances based on selection of schools, exposure of Girls to security risks in school and
GBV
How Concerns • The identified risks can be addressed by timely and continuous consultations with
were addressed stakeholders particularly traditional leaders, community leaders, all stakeholders
• Sensitization of traditionalist, parents on the importance of Girl child education and its
benefits to the family should be continuous
• Formal and non-formal groups will be engaged in monitoring of the Girls to reduce their
risks of exposure to social ills
• The Girls will also be sensitized on risks of GBV/SEA/STIs/STDs, female teachers, guidance
and counsellors, PTA members, Mothers Association etc. will serve as role model and
guidance also
Recommendations • The project should support with provision of textbooks to students
• Leverage on the success of NIPEP in the State
• The skills component should synergies with IDEAS project, also World Bank funded
• Non-formal monitoring groups should be strengthened including SBMCs, Mothers
Association etc. this could be in the form of training, incentives, monitoring tools etc.
• Incentives should be provided for female teachers to go to the rural areas
• The identified risks can be addressed by timely and continuous consultations with
stakeholders
Table 10: Meeting with Rep of Women Affairs and Mothers Association
Date of meeting 24th October 2019
Venue NIPEP Office, Kano State Ministry of Education
Participants Representatives from Women Affairs, Mothers Association
Purpose of the To inform them of the proposed project, obtain their perception and understand the roles they
Meeting will play in addressing social risks in the project
Major Findings • The Ministry of women affairs has been collaborating with Ministry of education with
and Discussion issues pertaining to Girl child education and the protection of the Girl child.
Areas • Mothers association play a key role in sensitizing parents to allow their wards go to school
to create opportunity for a better future for them. Though most of their work is voluntary,
they are made of mothers within the local communities
• They also informed the team that pressure on early marriage, poverty, less emphasis on
Girls education are major factors contributing to low enrolment and retention of Girls in
school. The Girls themselves need to understand the importance of getting an education
• Major risks from the project will be if the Girls need to travel long distances to school which
might expose them to social risks like GBV/SEA, kidnapping etc.
• Lack of synergy and cooperation amongst the state actors may impede the success of the
project
How Concerns • The identified risks can be addressed by setting up the Girls in groups to commute together
were addressed to and fro school
• Non-formal groups will be engaged in monitoring of the Girls to reduce their risks of
exposure to social ills
• The Ministry of Women Affairs will also play an oversight role to ensure that Girls are not
exploited as a result of the project
• The Ministry of Education and Women Affairs should synergies to ensure the success of
the project and that the benefits are achieved. Capacity building on roles and
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
responsibilities will be conducted during preparation and implementation phases of the
project
Recommendations • Non-formal monitoring groups should be strengthened including SBMCs, Mothers
Association etc. this could be in the form of training, incentives, monitoring tools etc.
• Conditional Cash transfer money should not be given to the Fathers as they may not use it
for the intended purpose
Table 11: Consultations in Secondary Schools
Date of meeting 24th October 2019 &
25th October 2019
Venue Government Girls Secondary School, Yargaya, Kano State
Government Girls Secondary School, Sabon Gari, Kano State
Government Girls Secondary School, Panisan, Kano State
Participants School Management, Teachers, Representatives from SME, SUBEB, Women Affairs, Mothers
Association
Purpose of the To inform them of the proposed project, obtain their perception and understand the current
Meeting issues with respect to Girl Child education and the status of facilities in the schools
Major Findings • The number of classrooms in some of the schools are not adequate for the number of
and Discussion students in the class thus overcrowding the classes
Areas • There are no chairs and tables in many of the classes and Girls have to receive lectures on
the floor
• Inadequacy of female teachers as most of them do not want to travel long distances to
school to teach
• The facilities in the schools are dilapidated and inconducive for effective learning including
the classrooms and hostels
• Toilets are in very poor conditions, grossly inadequate for the number of girls in the school,
no attached water facility to the available toilets, and for the boarding schools the location
of the toilets are remote, unsecure and unkept. Previous interventions did not do a good
job in the renovation of toilets as most of them are back to poor states.
• Waste is poorly managed, mainly by open dumping and open burning. Sewage on the other
hand is usually evacuated by informal handlers who dispose them off at nearby lands for
use as manure
• The project is a welcome development and setting up of skill centers should be based on
the peculiar needs of the project environment to ensure that these skills are marketable
afterwards. Some skills mentioned include catering, wedding decoration, tailoring, poultry,
fisheries, leatherworks
• The major envisaged project risks are driving up enrolment without provision of matching
facilities
• Security risks and harassment of the Girls
How Concerns • The project is planning to intervene in renovation/construction of additional facilities in
were addressed the school which will be done prior to enrolling beneficiaries
• The school management will work with the SME/SUBEB to draw up a work plan that will
identify what is feasible and what is not for each school
• On security risks, Government and volunteer groups will serve as monitors to prevent
social ills that may be associated with the project. On the other hand, Girls will be
sensitized on safe practices, GBV/SEA/STIs/STDs
• A GBV-GRM will also be put in place at the project locations
Recommendations • Female teachers should be given transport allowance and other incentives to encourage
them to teach in rural areas
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Table 12: Consultations with Stakeholders in Ekiti State
Date of meeting 30th October 2019 &
31st October 2019
Venue Office of the Permanent Secretary, State Ministry of Education, Ekiti State
Ministry of Education, Conference Hall
Participants Technical Adviser, Representatives from SME, SUBEB, Women Affairs, Gender Desk Officer,
Director Schools.
SEPIP Coordinator and other representatives of SEPIP, Director School of Basic Studies,
Surveyor
Purpose of the To inform stakeholders of the proposed project, obtain their perception and seek likely
Meeting environmental and social risks that may be associated with the project
Major Findings • There has been political interest of the Governor’s wife on Girl child education and
and Discussion development and some laws relevant to this are in discourse in the state e.g. reintegrating
Areas pregnant girls back to school
• Girls’ schools are not enough in the school to cater for the needs of Girl education. Many
schools can only admit one third of the applicants because of the limited facilities available
in the school
• Girls have to travel long distances to school which exposes them to men that take
advantage of them including Okada riders who offer them free transport.
• Poverty, when parents cannot afford fees or transport money to school also leads to drop-
outs
• The major challenge with Girls retention rate in schools is early pregnancy rates
• Other factors that lead to low enrolment and retention of Girls include: harassment of
Girls, sexual exploitation, more emphasis on educating boys in poorer homes
• Hygiene and waste management practices in the schools are not friendly and Girls are
often harassed when trying to use these facilities
• School selection will be based on need and spread across the senatorial districts
• The state requests that in addition to renovation of existing schools, more schools should
be built across the state to promote access in line with the state policy of students not
traveling beyond 1km to get to school
• Project risks may include:
- Land acquisition for construction of new schools
- Availability of space for expansion in existing schools
- Exposure of more Girls un-monitored as they traverse to and for school especially for
day schools. Harassment from cultists
- Boys may feel disadvantaged by not benefiting from the project
- Sustainability of the free education policy and the intervention beyond the project
lifecycle
How Concerns • Land acquisition will be avoided as much as possible, but where it cannot be totally avoided
were addressed it will be minimal and the provisions of the RPF will be adopted in developing and
implementing site specific RAPs
• Preferable expansion may be more of vertical structures than horizontal structures in
locations with limited space
• Monitoring groups will be empowered to monitor the Girls movement and conduct of
community members including Neighborhood Inspectors, PTA, community Development
Officer, Area Education Officers amongst others. Girls Clubs could also be formed to enable
peer monitoring. Women Affairs will collaborate with the SME Gender desk to implement
sensitization programs on sexual education, GBV/SEA, health talks, provision of sanitary
kits to Girls etc.
• Consultations should also be carried out with Boys so they feel carried along, they will also
benefit from renovation of classrooms, hygiene facilities in co-education schools
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• The project will continue to liaise with Government to ensure political will and funds
allocation for the sector
Recommendations • The state would develop a work plan for the sector which will be aligned with the
objectives of the proposed project. The state should leverage on the success of SEPIP and
the proposed IDEAS project
Table 13: Consultation in Schools in Ekiti State
Date of meeting 31st October 2019
Venue Immaculate Girls Secondary School, Ekiti State
St Louis Girls Secondary School, Ekiti State
Participants School Management, Teachers, Representatives from SME, SUBEB, Women Affairs
Purpose of the To inform them of the proposed project, obtain their perception and understand the current
Meeting issues with respect to Girl Child education and the status of facilities in the schools
Major Findings • The number of classrooms are grossly inadequate and schools cannot take more than 30%
and Discussion of Girl applicants
Areas • The environment is untidy as they do not have lawn mowers to cut the grass around the
school
• The facilities in the schools are dilapidated and inconducive for effective learning including
the classrooms and hostels. Insufficient beds in the hostels and no staff quarters
• Toilets are in very poor conditions, grossly inadequate for the number of girls in the school,
no attached water facility to the available toilets
• Skills centers are not functional and not adequate for the number of Girls interested in
participating
• Waste is poorly managed, mainly by open dumping and open burning.
• The project is a welcome development and setting up of skill centers should be based on
the peculiar needs of the project environment to ensure that these skills are marketable
afterwards. Some skills mentioned include catering, wedding decoration, tailoring, ICT,
honey making
• The major envisaged project risks are:
- Security risks from weak fences that allows hoodlums climb into the school
- Traffic increase and risk of student accidents for schools in built up areas
- Increase in waste burden from increased enrolment
- Exposure of more Girls to sexual harassment both in and out of school
- Change in Government policy may not favor the project
How Concerns • The project is planning to intervene in renovation/construction of fence in the participating
were addressed schools. CCTV cameras can be put in schools where possible and additional security
measures should be provided for the schools
• The PIU will ensure that the school management/contractors work with the State Traffic
Management Agencies to control traffic, assist with student crossing and prevent accidents
• All contractors will develop waste management plans prior to commencement of
construction. Modern incinerators can be provided as part of the project to manage waste
in the operation phase. Waste to wealth schemes can also be embedded as part of the
proposed entrepreneurship programs. The project will invest in Eco toilets and VIP latrines
as they are easier to manage especially where water availability is limited
• A GBV-GRM will also be put in place at the project locations. Monitoring will be done by
both formal and non-formal groups
Table 14: Consultations with Female Students in Ekiti State
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
Date of meeting 31st October 2019
Venue St Louis Girls Secondary School, Ekiti State
Participants Girl Students
Purpose of the To understand the issues Girls, face in school and their perception about the project
Meeting
Major Findings • They need more classes and more toilets in the school
and Discussion • The Girls prefer female teachers to male as they relate with them easily and they advise them
Areas • On skills acquisition the Girls mentioned preference for tailoring, hair dressing, home decoration
• Generally, Girls prefer boarding school to day schools
• With respect to management of their used sanitary pads: they wrap them up and dump them in
a space designated for frequent burning
• The Girls attested to receiving sensitization on sexual health, hygiene and sanitation from ex-
students, NGOs and Ministries
Recommendations Girls should be duly consulted in project design as this will make the project interventions more useful
and sustainable
Table 15: Stakeholders Workshop Key Discussions
Date of meeting 20th November 2019
Participants Representatives from Federal Ministries of Education, Women Affairs & Social Development, Health,
representatives of state Ministries of Education, SUBEB, State Ministry of Health, High Level Women
Advocate (HILWA), School Basic Management Committee (SBMC), Principals of Girls Secondary
Schools, Education sector expert, World Bank Task Team and E&S Specialists
Purpose of the To discuss the ESMF with stakeholders, specifically, project risks and mitigation, institutional roles
Meeting for ESMF implementation and E&S procedures
Key Discussion • The Nigerian EIA procedures and the World Bank Environmental and Social Framework was
Areas explained to stakeholders and the need for the ESMF to identify and address inherent project E&S
risks
• Stakeholders raised concerns on the fact that some states have not domesticated important
legislations like the Child’s Right Act, National Policy on Girl Child Education and that it will be
important for intending states to take this seriously. A representative from the Federal Ministry of
Women Affairs reiterated the Minister’s commitment to see that these laws are domesticated in
all states.
• The market skills will be beneficial to the entire school and not just the Girls selected as Grant
beneficiaries
• The representative from women affairs stated that Female Genital Mutilation should also be
considered as a barrier to adolescent Girl education. The TTL stated this will be considered under
the stand alone GBV assessment as such areas require expert assessment.
• The need for a grievance redress mechanism for the project was also reiterated. GRM will be made
accessible to the project beneficiaries and the participating Girls. A GRM will also be established
for project workers in line with the Labor Management Procedures (LMP). The SPIUs will monitor
the grievance process and ensure all complaints are listened to, documented, investigated and
closed. In addition, a corrective action plan should be developed for recurring grievances.
Recommendations A sector expert, Prof Oladipo reiterated the need for a project sustainability plan which will be based
on the principles of equity, social cohesion, Governance structure, and gradual integration of the
project into the state plan before the end of the project.
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7.3 Pictures of Stakeholders Consultations
Plates 12: Consultations with Stakeholders in Kano
Plates 13: Consultations at GGSS, Panisan, Kano
Plates 14: Site Visit at GGSS, Yargaya, Kano
Plates 15: Consultations with Rep of Women Affairs, Mothers
Association, Kano
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Plates 20: Consultations with PTA in Immaculate Girls School, Ekiti
Plates 21: Consultations with Stakeholders in Ekiti State
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CHAPTER EIGHT: GRIEVANCE REDRESS MECHANISM
8.1 Introduction
This section presents the Grievance Redress Mechanism developed to address in clarity and predictability
how grievances, complaints, and concerns will be received, assessed, sorted, resolved, and monitored in
line with the project. Some examples of potential concerns include:
• Grievances may arise from any of the following: involuntary resettlement and compensation
issues gender-based violence/SEA issues
• exclusion from project benefits and non-compliance of the contractor to the agreement reached
with RAAMP or the community
• Poor construction waste handling
• lack of alternative route for movement during construction, etc.
A Grievance Redress Mechanism (GRM) will be implemented to ensure that all complaints from local
communities are dealt with appropriately, with corrective actions being implemented, and the
complainant being informed of the outcome. It will be applied to all complaints from affected parties. The
SPIU will maintain a Complaints Database, which will contain all the information on complaints or
grievances received from the communities or other stakeholders. This would include: the type of
complaint, location, time, actions to address these complaints, and final outcome. The Social officer in the
PIU will oversee that the framework will function properly. The functioning of the GRM system, how to
register complaints (written, by phone, or in person), where to go and hours of service, all should be
clearly explained in local languages during public consultations on the project.
8.2 Grievance Redress Committees
The PIU shall set-up grievance redress committees that will address any complaints during project
implementation. This will be treated in two folds; 1) GBV related GRM and 2) non GBV related GRM.
A classified procedure for confidentiality is required in the cases of GBV and thus, a GBV risk management
plan will be prepared as part of the stand-alone GBV assessment and action plan for this. Grievance
Redress Committees (GRCs) shall be constituted at various levels to implement the GRM for the project
including community level, PIU level, FPCU level, Judiciary as shown below.
First Level GRM: GRC at the Site/Community Level: Composed at the school/community level, easily accessible to
the school/community people. This will comprise of school principal, PTA chairman, Guidance Counselor,
community leader shall be part of the committee among other identified persons. This committee will be expected
to receive and document all complaints received in the Grievance Log Book. The committee will investigate all
project related complaints and resolve/provide responses. Where the issue cannot be resolved at this level it will be
referred to the SPIU. In addition, complaint box will be placed within the school and in strategically accessible
location in the nearby community to the school, such as markets, civic center’s etc. that will encourage aggrieved
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parties drop their complaints. The SPIU will put in place a mechanism to access these compliant boxes at least twice
weekly and attend to complaints. Designated phone numbers to receive complaints will also be provided at the
project site, all complaints received will be documented. Recurring complaints should be flagged by the GRCs and
the SPIU should develop a corrective action plan, implement and close the process.
Second Level of GRM: GRC at the SPIU Level: This committee shall comprise of PIU members including the Project
Coordinator, Social Officer among others, and other state level representative from within the State Project
Monitoring Committees. If the complainant does not accept the solution offered by the SPIU-GRC, then the
complaint is referred by the Sate Project Coordinator to the FPCU. In all cases, there must be a feedback process
until the compliant is closed. Recurring complaints should be flagged by the GRCs and the SPIU should develop a
corrective action plan, implement and close the process.
Third Level of GRM: GRC at the FPMU Level: The Federal Project Coordinating Unit (FPCU) will be required to
intervene in grievances beyond the state level resolution.
Court Redress of Grievances: While the purposes of GRM put in place by this Project is to resolve all issues caused
by the project implementation out of court and to save time which is usually involved in litigation matters, it is not
out of place to anticipate a scenario where aggrieved person is not satisfied with the process and judgment given by
the grievance redress committee(s). Therefore, SPIU shall inform aggrieved persons of their right to seek for redress
in the court of law as the final resort.
The Grievance Redress Committee will be responsible for:
• Communicating with the affected persons (AP’s) and evaluate if they are entitled to compensation;
• Making the list of affected persons public and the established grievance redress procedure;
• Recommending to the Social Officer of the PIU solutions to such grievances from affected persons;
• Communicating the decisions to the AP’s;
• Acknowledging appeals from persons, households or groups who rightfully will not be affected by
the project, but claim to be; and
• Recommending to the SPIU whether such persons should be recognized as AP’s, and to
communicate back the decisions to the Claimants.
8.3 Expectations When Grievances Arise
When people present a grievance, any of the followings is or are expected from the project
management/channel of grievance resolution by the local people:
• acknowledgement of their problem;
• an honest response to questions/issues brought forward;
• an apology, adequate compensation; and
• Modification of the conduct that caused the grievance and some other fair remedies.
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8.4 Typical Grievance Redress Process
The process of grievance redress will start with registration of the grievance(s) to be addressed, for
reference purposes and to enable progress updates of the cases. Thus, the person affected by the project
will file a complaint with the Grievance Redress Committee. The complaint should contain a record of the
person responsible for an individual complaint, and records dates for the date the complaint was
reported; date the Grievance Log was uploaded into the project database; the date information on
proposed corrective action was sent to complainant (if appropriate), the date the complaint was closed,
and the date response was sent to complainant.
The officer receiving the complaint (part of the GRC) will ensure that each complaint has an individual
reference number and is appropriately tracked, and recorded actions are completed. The response time
will depend on the issue to be addressed but it should be addressed with efficiency. The Grievance
Committee will act on it within 10 working days of receipt of grievances. If no amicable solution is reached,
or the affected person does not receive a response within 15 working days, the affected person can appeal
to the SPIU, which should act on the grievance within 15 working days of its filing. These timelines are
further illustrated in table 14 below:
Table 16: Typical Steps in a Grievance Redress Process
Steps Process Description Completion Responsible
Time frame Agency/Person
1 Receipt of Document date of receipt, name of 1 day Secretary to GRC at project
complaint complainant, village, nature of level
complaint, inform the SPIU
2 Acknowledgement By letter, email, phone 1-2 days Social officer at SPIU
of grievance
3 Screen and Visit the site; listen to the 5-10 days GRC & social officer & the
Establish the Merit complainant/community; aggrieved PAP or his/her
of the Grievance assess the merit representative
4 Implement and Where complaint is justified, carry out 14 days or at a PC-PIU and Social Officer
monitor a redress resettlement redress in line with the time specified in
action entitlement matrix/OP 4.12 writing to the
aggrieved PAP
5 Extra intervention Review the redress steps and 10 days of State Project Coordinator
for a dissatisfied conclusions, provide intervention receiving status
scenario solution report
6 Judicial Take complaint to court of law No fixed time Complainant
adjudication
7 Funding of GRC logistics and training, redress No fixed time The proponent
grievance process compensation, court process
*All complaints including anonymous ones must be registered, treated and responded to.
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8.5 GBV-GRM
Based on the substantial GBV risk profile of the project as well as the vulnerable population the project
wishes to target (adolescent girls), a separate GBV related GRM will be constituted to receive GBV related
complaints that is tailored to be sensitive to the sensitivities of reporting GBV and for vulnerable
population. The GBV-GRM composition must be sensitive to create safe-space for reporting grievances.
The GRM should primarily serve to refer complaints to the GBV service provider and record resolution of
the complaint. GBV-GRM formation and procedures will be elaborately treated in the stand-alone project
GBV assessment, however, the GRM will operate under the following principles:
• The project GBV specialist will make certain the availability of an effective grievance redress
mechanism (GRM) for GBV with multiple channels to initiate a complain
• Refer cases where needed and work with GBV Services Providers as entry points into service provision
to raise awareness of the GRM
• Provide essential services and referrals for survivors, based on the GBV mapping of services
documented
• Report case through the GRM as appropriate keeping survivor information confidential and
anonymous
• Cases brought through the GRM are documented and closed.
A stand-alone GBV assessment is been conducted for the project with an action plan which will also
contain a GRM process for GBV related issues, however, a recommended framework for the Girl student
to report such issues is stated as follows, this can be built on/modified in the GBV assessment.
First Level GBV- Any Girl with GBV/SEA, sexual harassment complaints should report to the Guidance
GRM: GRC at the Counselor in the school. The guidance counsellor must be a qualified person trained on
School survivor-centered approach mechanism with links to referral services, and a safe space for
consultation with the Girls. The Guidance Counsellor should report the matter to the school
principal in a manner that will protect the Girl and ensure confidentiality at all times. The
matter should not be discussed at any open forum like PTA meeting or school management
meetings.
Second Level of Where the matter cannot be resolved at the level of the Guidance counsellor/Principal, it
GBV-GRM: GRC should be referred to the Gender desk of the State Ministry of Education. Protection and
at the State Level confidentiality for the complainant should be guiding principles in handling the case.
Recurring issues from a particular school should be flagged, investigated, the SME/Women
Affairs to develop and implement a corrective action plan.
Third Level of The Gender desk of the state ministry of education can liaise with the state ministry of
GBV-GRM: women affairs and collaborate to resolve the issue and involve referral services or law
enforcement as deemed necessary. Psychosocial counselling and other necessary support
should be provided to the survivor to ensure completion of education. It is important that
the identity of the Girl is protected at all levels.
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CHAPTER NINE: LABOR MANAGEMENT PROCEDURES
9.1 Introduction
This Labor Management Plan (LMP) was developed by the Federal Ministry of Education (Federal Project
Management Unit) for the Adolescent Girls Initiative for Learning and Empowerment Program. It identifies
labor requirements and sets out the procedures for addressing labor conditions and risks associated with
the proposed project, which is aimed at helping the project to determine the resources necessary to
address project labor issues. The LMP is enshrined within the context of the World Bank ESS 2: Labor and
Working Conditions.
The risks and impact associated with workers as well as community health and safety, and the risk
associated with labor impact are moderate due to the nature of minimal construction activities which are
well understood and expected to have limited impacts as they can largely be avoided, minimized or
managed through procedures, including procedures set out in this LMP. The LMP will be reviewed
continually during project implementation and adequate measures and procedures to manage negative
impacts will be put in defined. A detailed stand-alone Labor Management Procedures (LMP) has been
developed for the project, however, key provisions are captured within this section.
9.2 Characterization of labor requirements
For the Adolescent Girls Initiative for Learning and Empowerment Program, there will be various
categories of direct and indirect staff and workers. The main labor and staff required in the project will
include:
• Staff of the Federal Project Coordinating Unit and the State Project Implementation Units
• Staff of the sub agencies/departments that will be participating in the project
• Teachers in schools
• Contract workers brought in to rehabilitate the schools
• Primary Suppliers
• Community Workers
The table below highlights and analyses the potential labor related risks and impacts in view of the
anticipated labor utilization and general baseline settings of the project area.
9.3 Labor Risk Identification and Analysis
Table 17: Labor Risk Identification and Analysis
Risk/Impact Analysis (Magnitude, Extent, Timing, Mitigation
Likelihood, Significance)
Arbitrary • The duration of the contracts offered to • The State Project Implementation Unit
decisions by contractor workers are short and may (SPIU) will closely supervise the
contractors on not allow employees adequate time Contractor Recruitment Plan and ensure
terms and and information for meaningful fairness of Employment Terms and
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Risk/Impact Analysis (Magnitude, Extent, Timing, Mitigation
Likelihood, Significance)
conditions of collective bargaining, leading to Conditions against the applicable and
employment discontent of employees and disputes. prevailing National stipulations
• Project workers may not be provided • All information and documentation must
with information and documentation be provided at the beginning of the
that is clear and understandable working relationship and when any
regarding their terms and conditions of material changes to the terms or
employment. conditions of employment occur
• Where applicable, project workers will
receive written notice of termination of
employment and details of severance
payments in a timely manner
Poor working • The Rights of workers under national • Project workers will be paid on a regular
conditions (unsafe labor and employment law (which will basis as required by national law and
work include any applicable collective labor management with a principle of
environment, agreements), may be abused “equal pay for equal work”
underpayment, • Workers payment may be delayed, • In the case of subcontracting, the
lack of workers’ irregular, or may be underpaid. Borrower will require such third parties
rights, etc.) • Campsites may be poorly managed, to include equivalent requirements and
unconducive for workers, insecure, non- compliance remedies in their
poor sleeping conditions, lack of access contractual agreements with
to basic amenities like water, toilets, subcontractors
healthcare etc. • The SPIU shall inspect the campsites to
• The general appearance of the camp ensure workers have appropriate living
deteriorates making camp life quarters, sanitation facilities separate for
unpleasant male and female, basic amenities
• All project workers will be provided with
adequate periods of rest per week,
annual holiday and sick leave, as
required by national law.
• Ensure that camp grounds and common
areas are routinely cleaned and
organized with appropriate signage in
place, and that grounds are maintained
(e.g., grassed areas are regularly mown).
Non- • Decisions relating to the employment • The employment of project workers will
discrimination and or treatment of project workers may be based on the principle of equal
equal opportunity discriminate against certain classes of opportunity and fair treatment, and
workers including women, vulnerable there will be no discrimination with
groups amongst others. respect to any aspects of the
• Payment of workers may be based on employment relationship, such as
discrimination e.g. male may be paid recruitment and hiring, compensation
higher than women even on the same (including wages and benefits), working
level of job schedule. conditions and terms of employment,
• Foreign workers may be treated better access to training, job assignment,
than local workers in terms of living
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Risk/Impact Analysis (Magnitude, Extent, Timing, Mitigation
Likelihood, Significance)
conditions, unequal pay, varying promotion, termination of employment
closing time etc. even when they are or retirement, or disciplinary practices.
on the same level of qualification and • The SPIUs are compelled to safeguard
experience the interests of women and girls,
including gender parity at the workspace,
appropriate sanitation facilities at
workplace and appropriate PPEs for
women.
Sexual • The project will provide support • The Teacher-Counsellors appointed to
Harassment of packages to recruited teachers to carry out the life-skills facilitation should
teachers ensure that they are qualified and ready be selected as focal points for reporting
to teach in the target communities; incidents of harassment; alternate or
including short-term placements secondary focal points should be
• Risks of sexual harassment of teachers identified in case the accused is the
and other staff is a possible Teacher-Counsellor
• Training administered to teachers should
include protocols on how sexual
harassment will be addressed at the
school, including if its escalated beyond
the school environment
• Teachers should also be made aware of
the GBV-GRM for the project
Child Labor • There is a risk that children (below the • The minimum age of eighteen (18) will
age of 18) will be used as labor in the be enforced at recruitment and in daily
project. staff team talks by Contractors. SPIU will
• Under-aged persons within the also supervise this through the
community may be disguised as above Contractor Management Checklist.
18 to enable them to work and get • Contractors will liaise with community
paid liaise to attest to the age and conduct of
all local hires, and maintain a list of same
• Hired project workers above 18 shall
conduct his/her activities in ways that
are not detrimental with respect to
education or be harmful to the child’s
health or physical, mental, spiritual,
moral or social development
Forced Labor There is a risk that there could be • Contractors will ensure that no forced
involuntary or compulsory labor, such as labor exists in the project by gathering
indentured labor, bonded labor, or documents and appropriate proof.
similar labor-contracting arrangements. • A consent section will be part of the
This prohibition covers any of the employee signed employment contract.
aforementioned. Contractors will ensure that if labor is
sourced from any sub-contracting
agency, the workers are not subject to
coercion and forced labor conditions.
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Risk/Impact Analysis (Magnitude, Extent, Timing, Mitigation
Likelihood, Significance)
Labor Influx • The project may face influx of labor to • Encourage hiring of labor from the host
local communities especially where communities. Maintain labor relations
skilled laborers are not available in with local communities through a code
some project sites. This could lead to of conduct (CoC)
Increase in potential spread of • The Code of Conduct must be signed by
STIs/STDs, HIV/AIDs due to workers on all categories of workers. Workers must
site, increase in GBV/SEA especially for be trained on the provisions of the CoC
Girls been exposed to contractors, about refraining from unacceptable
sexual relations between contractors conduct toward local community
and minors and resulting pregnancies, members, specifically women and
encourage presence of sex workers in informed of the sanctions for non-
the project communities compliance. Training must be conducted
• This could also lead to competition for for all new hires including sub-
resources like water, health facilities, contractors.
electricity in the project locations • Contractors should make resources
available for their workers especially
where stated in the ESMP
Grievance • Workers may be aggrieved due to • Contractors shall comply with the
Mechanism unfair treatment, poor working Grievance redress mechanism defined to
conditions, conflicts, poor pay, handle workers grievances in a fair and
overstretched working hours amongst timely manner.
other things. • The SPIU shall provide oversight to
• A GRM will be designed to address ensure effective implementation of the
concerns promptly, using an GRM.
understandable and transparent
process that provides timely feedback
to those concerned in a language they
understand, without any retribution,
and will operate in an independent and
objective manner
• The grievance mechanism will not
impede access to other judicial or
administrative remedies that might be
available under the law
Occupational • Site workers will be exposed to risks • Contractors should provide HSE training
Health and Safety of accidental collisions with moving for all workers before commencement
vehicles, strains, and ergonomics of work and periodically
from repeated movements or from • All contractors should have full time
lifting and heaving of heavy objects, HSE officers on their team
slips and falls. Accidental cuts from • Contractors should provide adequate
tools and machines are also safety PPEs for all their workers and the
risks. contractors HSE officers should enforce
• Dust and particulate emissions and compliance
welding works from rehabilitation site
may cause respiratory and eye
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Risk/Impact Analysis (Magnitude, Extent, Timing, Mitigation
Likelihood, Significance)
impairment health concerns for • First aid boxes should also be provided
workers and the public at construction site, staging area and
• Movement of trucks carrying sand mobile
and materials, lack of road safety • Contractors will prepare Occupational
measures may also cause risk of Health and Safety Plans
accident, injury and death • Contractors should report OHS
• Contractors should comply with accident/incidents to the SPIU
National and international labor promptly, and the SPIU/FPMU should
legislations report this to the Bank within 48hrs (in
• Every site will have emergency accordance with the Environmental and
prevention and preparedness and Social Commitment Plan (ESCP)
response arrangements to emergency • Contractors waste management plans
situations will include handling and management
• Maintain a safe working environment of hazardous waste
including workplaces, machinery, • Contractors should ensure training for
equipment and processes under their their drivers and liaise with the State
control are safe and without risk to Traffic Management Agency to control
health, including by use of traffic during project implementation
appropriate measures relating to
chemical, physical and biological
substances and agents.
• Where required, hire security for
workers
Right of • Workers have the right to freely form, • The SPIU will ensure that workers are
Association and join or not join a trade union for the informed of their right of association
Collective promotion and protection of the and collective bargaining
Bargaining economic interest of that worker • The SPIU should also inform workers of
• Workers have a right to organize and the workers GRM and their right to
collective bargaining, and utilize the system
representation
Contractor • Records of workers engaged under • Documents should be kept at the site
Management the Project, including contracts must office with the site engineers and SPIU
be kept office
• Records of all training attended by • The FPCU team should check these
workers including CoC, HSE, records during monitoring visits
STIs/STDs, GBV etc.
• Accidents/ incidents and
corresponding root cause analysis
(lost time incidents, medical
treatment cases), first aid cases, high
potential near misses, and remedial
and preventive activities required
(Corrective Action Register)
• Records of strike actions, reasons and
resolution reached
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Risk/Impact Analysis (Magnitude, Extent, Timing, Mitigation
Likelihood, Significance)
• Records of grievances and how they
were resolved
• Records of all sanctions, punishments
and terminations with reasons and
follow-up actions taken
Primary Suppliers Primary suppliers could also have Primary suppliers should maintain records
occupational injuries, incident/accidents related to occupational injuries, illness and
while performing project related lost time accident, which should be
functions reviewed by the contractor every quarterly
Discipline and • Disciplinary process should be laid • The SPIU should periodically review
Termination of out before commencement of work workers disciplinary and termination
Employment and explained to every worker processes to ensure that they are
• Termination of appointment should executed fairly and without prejudice
abide by the following principles: • Where unfair treatment is established
Valid or reasonable; the SPIU should put in place corrective
Clear and unambiguous; action and follow up to ensure
The employee is aware, or could execution
reasonably be aware of the rule
or standard; and
The procedure to be applied in
the event the employee
contravenes any of these rules
Occupational Health and Safety Compliance
The requirements of the Environmental and Social Standard 2 on Occupational Health and Safety will be
to carry out site specific risk assessments and develop appropriate risk prevention and mitigation
measures. Where risk prevention and mitigation require provision of personal protective equipment
(PPE), appropriate PPE will be provided to workers who are tasked to work on high risk tasks or areas.
During risk assessment which will be conducted during screening process, possible hazards or risks related
to the project activities will be identified. To this end, the appropriate PPE will be provided during project
implementation. The identification of PPE will be done will be done during the screening and
development of site-specific environmental and social management plans (ESMPs).
9.4 Grievance Redress Procedures for Workers
This procedure requires every employer, including contractors, to have a Formal Grievance Procedure which
should be known and explained to the employee.
The framework to be adopted for workers to lodge their grievances is outlined below:
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First Level GRM: Composed at the community level and easily accessible to workers. This committee will
GRC at the comprise of community liaison officers, supervision consultant site engineer, representative
Site/Community of school management among other identified persons. In addition, complaint box will be
Level
placed in the school that will encourage aggrieved workers drop their complaints. This should
be checked regularly (at least twice weekly) by a designated person in the committee. This
committee will be expected to report to the SPIU.
Second Level of This committee shall comprise of PIU members including the Project Coordinator, Social
GRM: GRC at the Officer among others, and other state level representative from within the State Project
SPIU Level Monitoring Committees. If the complainant does not accept the solution offered by the SPIU-
GRC, then the complaint is referred by the Sate Project Coordinator to the FPCU
Third Level of The Federal Project Coordinating Unit (FPCU) will be required to intervene in grievances
GRM: GRC at the beyond the state level resolution.
FPMU Level
Court Redress of While the purposes of GRM put in place by this Project is to resolve all issues caused by the
Grievances project implementation out of court and to save time which is usually involved in litigation
matters, it is not out of place to anticipate a scenario where aggrieved person is not satisfied
with the process and judgment given by the grievance redress committee(s). Therefore, SPIU
shall inform aggrieved persons of their right to seek for redress in the court of law as the final
resort.
9.5 Roles and Responsibilities for Managing the LMP
The State Project Implementation Units (SPIUs) have the overall responsibility to oversee all aspects of
the implementation of the LMP including occupational safety, health and welfare of workers, and ensure
contractor compliance. The SPIUs will address all LMP aspects as part of procurement for works as well as
during contractor induction/training. This role will primarily be part of the responsibilities of the
Environmental and Social Officers of the SPIUs, however, they will be required to liaise with other staff of
the SPIU and report frequently to the Project Coordinator on all LMP matters.
Contractors will be responsible for implementation of the plan on a daily basis and providing the required
human, financial and training resources for effective compliance. However, implementation of the project
will be done in collaboration with several other stakeholders at national, state, schools and community
level who will also be expected to assist in the management of workers within their areas of jurisdiction
in the project
Specific roles are outlined below:
Occupational Health and Safety
Contractors must engage a minimum of one Health Safety and Environment (HSE) officer in every team
to ensure the day-to-day compliance with specified health and safety measures and records of any
incidents. Minor incidents and near misses will be reported to the SPIUs (through the SPIU Environmental
Officer) on a monthly basis, serious incidents should be reported immediately and not later than 24hrs.
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Minor incidents will be reflected in the quarterly reports to the World Bank, while major accidents/deaths
should be flagged to the World Bank within 48hrs.
Labor and Working Conditions
Contractors will keep records in accordance with specifications set out in this LMP. The SPIUs may at any
time require records to ensure that labor conditions are met. Where issues are spotted, the SPIU will
ensure that immediate remedial actions are implemented. A summary of issues and remedial actions will
be included in quarterly reports to the World Bank.
Worker Grievances
Contractors must engage a minimum of one social officer in every team to handle issues relating to social
risks. The SPIUs (through the social officer) will review the effectiveness of the workers grievance redress
mechanism as stipulated in section 9.4 above and ensure that all complaints by workers are resolved. The
SPIU will report this as part of the quarterly E&S reports to the World Bank.
Additional Training
The contractor will set up a system of daily HSE PEP talks, routine safety trainings and specialized job
trainings for workers. Trainings will form part of the contractor’s responsibility. The contractors HSE
officers will provide safety instructions to contractor staff. The SPIU will liaise with contractors to deliver
trainings to address risks associated with labor influx including GBV/SEA. The contractor will be
obligated to make staff available for this training, as well as any additional mandatory trainings required
by the SPIU, as specified by the contract
Occupational Health and Safety compliance
The contractor shall comply with all provisions of the LMP, site-specific ESMPs that will be prepared,
including occupational health and safety plans, emergency plans amongst others. In addition, contractors
shall procure the identified PPE and First Aid kit for use during project implementation and these will be
included in the Bill of Quantities (BoQs). The Contractor shall organize training for workers on the use of
PPE and First Aid kit. It is also expected that every contractor will have an HSE Manual which will
demonstrate the company’s personnel commitments to HSE compliance.
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CHAPTER TEN: SUMMARY AND RECOMMENDATION
This ESMF has provided a general view of the environmental and social conditions under which the Project
will be implemented. This ESMF addresses the Project’s need to monitor and mitigate negative
environmental and social risks and impacts of the project and promote sustainability. This report is
necessary at this point of project preparation to inform decision making on project design and modalities
for implementation in such a way as to minimize identified risks and negative impacts.
As described in the report, labor influx is likely to aggravate GBV/SEA issues. Contractors must prepare
and sign all levels of CoCs requested and present a C-ESMP that specifically addresses the aforementioned.
The submission and acceptance of the C-ESMP is a mandatory process, essential prior to the
commencement of any form of civil works. The SPIU is responsible for monitoring compliance to the E&S
requirements.
The Labor Management Procedures set out in this ESMF will also be monitored by the SPIU to ensure
protection and fairness for all categories of workers associated with the project.
For Physical and Cultural aspects which may be impacted on; the SPIU and its Contractors should have
effective collaboration and liaison with the communities. Furthermore, “Chance Find Procedures” must
be adhered to and compliance monitored.
It has been reiterated throughout the report that the project should be designed and implemented in a
manner that is disable-friendly to ensure that vulnerable groups are not placed at more disadvantage as
a result of this project.
The report has provided the standard procedure and institutional arrangements for environmental and
social screening, categorization and approval of sub-projects and serves as a guide to develop detailed
site-specific Environmental and Social Impact Assessment (ESIAs)/ Environmental and Social Management
Plans (ESMPs) that would be consulted upon and disclosed prior to project commencement. The effective
use of this ESMF would be regularly reviewed as part of the project’s Monitoring & Evaluation (M&E)
system.
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ANNEX 1: CONSULTATION ATTENDANCE SHEETS
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ANNEX 2: ENVIRONMENTAL HEALTH AND SAFETY GUIDELINES
The EHS guidelines for any World Bank financed project contains performance levels and measures that
should be considered for new and existing facilities. The application of ESH involve the establishment of
site-specific targets, with appropriate timetable for achieving them which should be tailored to the
hazards and risks associated with the project. This proposed project may involve activities on existing and
new facilities, consequently the ESHG outlined below will considered both situations.
Nigeria’s ESH guideline differs from the World Bank guidelines, then the more stringent one should be
applied. However, if the less stringent guideline is chosen or more appropriate measures than those
provided in this EHS Guideline below probable based on specific project circumstances, a full and detailed
justification for any proposed alternatives should be provided by the proponent as part of the site-specific
environmental assessment. This justification should demonstrate that the choice for any alternate
performance levels is protective of human health and the environment,
The proponent should adhere to the following ESH Guidelines
• Identify all ESH hazards and associated risks early as possible for project life cycle. The ESHG must
be considered during site selection process, product design process, engineering planning process
for capital requests, engineering work orders, facility modification authorizations, or layout and
process change plans
• Involve ESH professionals, who have the experience, competence, and training necessary to
assess and manage ESH impacts and risks
• Carry out specialized environmental management functions including the preparation of project
or activity-specific plans and procedures that incorporate specific and relevant technical
recommendations as shown below
• The proponent must understand the likelihood and magnitude of ESH risks associated with this
project based on: whether the project will generate significant quantities of emissions or
effluents, or involve hazardous materials or processes; the potential consequences to workers,
communities, or the environment if hazards are not adequately managed, which may depend on
the proximity of project activities to people or to the environmental resources on which they
depend
• Prioritize the risk management strategies with the objective of achieving an overall reduction of
risk to human health and the environment
• Favor strategies that eliminate the cause of the hazard at its source, for example, by selecting less
hazardous materials or processes
• When impact avoidance is not feasible, incorporate engineering and management controls to
reduce or minimize the possibility and magnitude of undesired consequences, for example, with
the application of pollution controls to reduce the levels of emitted contaminants to workers or
environments.
• In some instances, prepare workers and nearby communities to respond to accidents, including
providing technical and financial resources to effectively and safely control such events, and
restoring workplace and community environments to a safe and healthy condition.
• The ESH performance should be monitored
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The table below highlights key issues to monitor and consider under ESHG
Area Parameter Guidelines Specifications
Environment Air Emissions and Ambient Air Quality Point Source, Fugitive sources and mobile
Projects with significant sources of air emissions, and potential for significant impacts to sources.
ambient air quality, should prevent or minimize impacts such that it does not affect the e.g. VOC, PM, GHGs, NO x , SO 2 , ODS, CO
people and the environment
Energy Conservative Energy Management, Energy Efficiency, Process
Conserving energy should be viewed in the context of overall consumption patterns, Heating, Process Cooling,
including those associated with production processes and supporting utilities, as well as
overall impacts associated with emissions from power sources.
Wastewater and Ambient Water Quality General Liquid Effluent Quality: Discharge to
• Understand the quality, quantity, frequency and sources of liquid effluents in its Surface Water, Sanitary wastewater, Septic
installations. System
• Plan and implement the segregation of liquid effluents principally along industrial,
utility, sanitary, and storm-water categories, Wastewater Management: Industrial and
• Identify opportunities to prevent or reduce wastewater pollution through such Sanitary Waste Water
measures as recycle/reuse within their facility,
• Assess compliance of their wastewater discharges with the
applicable: (i) discharge standard
Water Conservation Water monitoring/management techniques;
• Zero discharge design/Use of treated waste water should be included in project Process and cooling/heating water recycling,
design processes Reuse, and other techniques; and Sanitary
• Use of localized recirculation systems in plant/facility/shops (as opposed to water conservation techniques
centralized recirculation system), with provision only for makeup water
• Project design should have measures for adequate water collection, spill control
and leakage control system
Hazardous Materials Management Hazard Assessment, Preventive Measures,
• Avoid or, when avoidance is not feasible, minimize uncontrolled releases of Management Actions, Control Measures,
hazardous materials or accidents (including explosion and fire) during their Emergence Preparedness and Response
production, handling, storage and use
Waste Management Waste Prevention, Recycling and Reuse,
• Establish waste management priorities at the outset of activities based on an Collection, Transport, Storage, Treatment and
understanding of potential Environmental, Health, and Safety (EHS) risks and Disposal.
impacts and considering waste generation and its consequences Monitoring
• Establish a waste management hierarchy that considers prevention, reduction,
reuse, recovery, recycling, removal and finally disposal of wastes
• Avoid or minimizing the generation waste materials, as far as practicable
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Area Parameter Guidelines Specifications
• Where waste generation cannot be avoided but has been minimized, recovering
and reusing waste
Noise Prevention, Control, Monitoring and Noise
• Select equipment with lower sound power levels Level
• Install silencers for fans
• Install suitable mufflers on engine exhausts and compressor components
• Re-locate noise sources to less sensitive areas to take advantage of distance and
shielding
• Site permanent facilities away from community areas if possible
• Reduce project traffic routing through community areas wherever possible
• Plan flight routes
Contaminated Land Risk Screening, Interim Risk Management and
Detailed Risk Screening
Occupational Health and The General Guidelines for this OHS is as follows: General Facility Design and Operations
Safety • Eliminate the hazard by removing the activity from the work process. Examples Communication and Training
include substitution with less hazardous chemicals, using different manufacturing Physical, Chemical and Biological Hazards
processes, etc. Personal Protective Equipment (PPE)
• Control the hazard at its source through use of engineering controls. Examples Radiological Hazards
include local exhaust ventilation, isolation rooms, machine guarding, acoustic Special Hazard Environments and Monitoring
insulating, etc.
• Minimize the hazard through design of safe work systems and administrative or
institutional control measures. Examples include job rotation, training safe work
procedures, lock-out and tag-out, workplace monitoring, limiting exposure or work
duration, etc.
• Providing appropriate personal protective equipment (PPE) in conjunction with
training, use, and maintenance of the PPE.
Community Health and Water Quality and Availability Surface water
Safety Water Quality Ground Water
• Prevent adverse impacts to the quality and availability of groundwater and surface Drinking Water
water resources.
• Project should at all times be protected so that they meet or exceed applicable
national acceptability standards or in their absence
Water Availability
• Groundwater or surface water abstraction for project activities should be properly
assessed through a combination of field testing and modelling techniques,
Structural Safety of Project Infrastructure • Existing structures, Soils and foundations
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Area Parameter Guidelines Specifications
• Site grading, Structural design
• Specific requirements based on intended use
and occupancy
• Accessibility and means of egress
• Types of construction, Roof design and
construction
• Fire-resistant construction, Flood-resistant
construction
Life and Fire Safety • Health and education facilities (classrooms)
All new buildings accessible to the public should be designed, constructed, and • Hotels, convention centers, and leisure
operated in full compliance with local building codes, local fire department regulations, facilities
local legal/insurance requirements, and in accordance with an internationally accepted • Retail and commercial facilities
life and fire safety (L&FS) standard (see annex) • Airports, other public transport terminals,
transfer facilities
Traffic Safety Training, Prevention, Control,
• Traffic safety should be promoted by all project personnel during displacement to Accidents/Incidents
and from the workplace, and during operation of project equipment on private or
public roads
• Regular maintenance of vehicles and use of manufacturer approved parts to
minimize potentially serious accidents caused by equipment malfunction or
premature failure.
• Adoption of best transport safety practices across all aspects of project operations
with the goal of preventing traffic accidents and minimizing injuries suffered by
project personnel and the public
Transport of Hazardous Materials
Projects should have procedures in place that ensure compliance with local laws and
international requirements applicable to the transport of hazardous materials
Disease Prevention Communicable Disease, Vector Borne Disease
• Provide surveillance and active screening and treatment of workers
• Awareness and Sensitization in health matters
• Education initiatives
• Provide treatment through standard case management in on-site or community
health care facilities.
Emergency Preparedness and Response • Administration (policy, purpose, distribution,
definitions, etc.)
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Area Parameter Guidelines Specifications
All projects should have an Emergency Preparedness and Response Plan that is • Organization of emergency areas (command
commensurate with the risks of the facility centers medical stations, etc.)
• Roles and responsibilities
• Communication systems, Emergency
response procedures
• Emergency resources, Training and updating
• Checklists (role and action list and equipment
checklist)
• Business Continuity and Contingency
Construction and Environment SAME AS ABOVE
Decommissioning Occupational Health & Safety SAME AS ABOVE
Community Health & Safety SAME AS ABOVE
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ANNEX 3: OCCUPATIONAL HEALTH AND SAFETY PLAN
Considering the potential for rehabilitation works to require medium to large scale labor, and the peculiarity
of the civil, the project will require a Project Occupational Health and Safety Management Plan. The plan
will focus on workers’ health and safety during the major rehabilitation activities
Rehabilitation works under the Project
The PIU (OHS Responsibilities)
The PIU has a responsibility to ensure the health and safety of all persons working on all the
components and sub-components, their own employees, Contractors, Subcontractors and agency
employees.
In this regard, the PIU through the PIU shall: Define systems of work and requirements for Contractors and
Subcontractors to ensure their health and safety on the site. This means that PIU will require Contractors
and Subcontractors to follow safe systems of work, meet statutory and other requirements (Nigerian and
International), and audit their capability to safely manage work performed by their own employees. A
periodic audit by the PIU of the Contractors’ work performance and systems including OHS should be
required as partial basis for payment.
Provide information needed by the Contractors to document and carry our work in a safe manner.
PIU should provide information on hazards and their associated risks while working on any specific part of
the project. This will enable Contractors document their procedures for managing work around hazardous
conditions, and to ensure they are aware of these hazards. PIU will do this by providing a set of requirements
and safe work procedures through the Terms of Reference (TOR) in the Contractors contract document. It
should also highlight Risk and Control Assessments, Work Control Permits etc.
Review Contractors’ Safe Work Mode Method Statements to ensure they comply with Bank’s
Environmental and Social safeguards and statutory HSE Requirements.
Ensure that Contractors follow all safety and environmental requirements.
PIU should monitor health and safety during rehabilitation works. Pre-start checks, inspections and audits
will be conducted while on-site. These checks will look at work practices and methods, equipment
conditions and suitability, and competency of people through checking the permits, licenses etc. Individuals
are not permitted to bring, use or be under the influence of alcohol or non-prescribed drugs on-site.
�����������������������������
Contractors’ Responsibilities
Contractors are responsible for ensuring that their work methods consider and incorporate best
practice and safety requirements.
Contractors are responsible for ensuring that safety and health hazards associated with the work they are
performing, are satisfactorily controlled and do not pose a risk. In the process of carrying out their work a
Contractor may introduce other hazards. The identification and control of these hazards is the responsibility
of the Contractor. These hazards and controls identified by the Contractor must be considered in the Work
Method Statements.
Contractors are responsible for ensuring the health and safety of their employees including Sub-
Contractors. This means that the Contractor is responsible for ensuring that:
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a) their employees and subcontractors are adequately trained and competent in performing their
tasks, and in basic safety procedures.
b) are provided information about processes and materials which are hazardous.
c) are issued with appropriate safety equipment and have appropriate instruction in its use.
d) have safe work methods and are adequately supervised to ensure safe work.
e) work place safety inspections are regularly carried out.
f) there is access to first aid equipment and trained persons
Contractors are responsible for ensuring their plants and equipment are safe. This means that Contractors’
equipment and plants whether their own or hired is a) in a serviceable condition with regular maintenance
and inspections. b) suitable for the task it is to perform and 3) meets the PIU requirements. The primary
concerns of plants are that:
• All guards are in place and secure
• Relevant safety equipment is fitted and working
• Operating controls (indicators, brakes, steering etc.) are working properly b) possible safety or
environmental risk items are satisfactory. (hydraulic hoses, mufflers, exhaust emissions, fluid leaks
etc.).
Proposed rehabilitation works for Access Road
PIU OHS Responsibilities
The PIU has a responsibility to ensure that all farmers, by-passers, visitors and locals are informed about
road rehabilitation
Contractors should be responsible for ensuring that:
• Caution signs are in place.
• Dust reduction methods
• Noise reduction
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ANNEX 4 GENERIC WORKERS CAMPSITE MANAGEMENT PLAN
The Workers Camp Site Management Plan for the project should address specific activity that will be undertaken to
minimize the impacts resulting from siting a worker’s camp on the local project communities.
Elements for managing risks associated with the Workers Campsite under the proposed project
include:
• Location: The Contractor shall ensure to site workers camp at a designated location approved by the
SPIU. The location was determined during the preliminary design preparation in conjunction with the
local communities/authorities with the following criteria:
Be located outside the protection zone of watercourses (100 m) and wetlands;
Be located within an acceptable distance from existing residential areas;
Not located in areas with intact vegetation
The contractor must first obtain the necessary licenses and consents from the local authorities
or from the owner of the needed area; Although it is the contractor's decision, it is
recommended that whenever possible the camps should be handed over to the
administrative or community authorities for future use;
The contractor must submit for the prior approval of the Resident Engineer, the implantation
design and other project structures and specifications related to the camps and sites that are
intended to be built;
The contractor shall take all necessary measures and precautions to ensure that the execution
of the works is carried out in accordance with environmental, legal and regulatory
requirements, including those set out in this document; The contractor shall take all measures
and precautions to avoid any disturbance in the local communities and among the users of
the road, as a result of the project execution;
The contractor shall, whenever possible, apply measures to reduce or eliminate any sources
of disturbances. The contractor shall follow the provisions of this document, as well as the
applicable legislation and standards, during the use, operation and maintenance of the camps
and sites, in particular with regard to water supply and sanitation, solid waste management,
handling and storage of dangerous substances, etc.;
The areas occupied by the camps and sites must be recovered at the end of the project, when
the contractor is demobilized, through the replacement of previously existing conditions,
unless other uses are intended
• Accommodation, Hygiene and Sanitation: The Contractor will ensure that all necessary sanitary
facilities shall be provided for workers expected on site: separate rooms will be provided for male and
female workers, all necessary sanitary facilities complying with World Health Organization (WHO)
regulations will be provided for workers including:
Separate toilets for male and female
Portable water with well-placed overhead tanks
Wash basins
Concrete and covered septic tanks
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• On-site Social and Health Care Facilities: Provision of basic on-site social and medical facilities such
as first aid, basic health care center, recreational center, food service, etc. in order to reduce pressure
on community facility.
• Campsite Safety and Security: Provision of 24 hours security stationed at the Campsite to ensure the
security and safety of construction workforce and construction equipment.
• Campsite Waste Management: Adequate waste management of sewage and other forms of waste
within the campsite. The Campsite shall be equipped with independent toilet facilities for male and
female workers respectively, in order to discourage irregular waste disposal. Furthermore, standards
must be instituted for personal and public hygiene among project workers. Additionally, project
workers shall be properly trained on personal hygiene.
• Establishment of and Training on Workers on Code of Conduct: The Supervising Engineer and
Safeguards Unit shall ensure that Contractors establish a workers’ Code of Conduct (CoC). The CoC
will help mitigate some of the social and environmental impacts of labor influx such as risk of social
conflict, Increased risk of illicit behavior and crime, Increased burden on and competition for public
service provision, Wastewater discharges, Increased demand on freshwater resources, and
Inadequate waste disposal and illegal waste disposal sites etc., will help keep workers (local/foreign)
in check on the rules and regulations binding their engagement. Contractors to ensure provision of
training to workforce on code of conduct and ensure strict compliance. Measures provided for in the
ESMP to deter illicit behavior and other social vices are adequately enforced.
• Training programs: Conduct and ensure key staff, including contractors, receive training regarding the
likelihood, significance and management of influx-related issues such as HIV/AIDS, GBV, SEA, VAC etc.
• Carry out Regular Monitoring: The SPIU shall monitor for change throughout the project cycle to
ensure compliance and on mitigation effectiveness from projects/contractors. Ensure a documented
monitoring program that tracks key social outcomes, changes and issues at regular intervals
throughout the project lifecycle
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ANNEX 5 ENVIRONMENTAL AND SOCIAL SCREENING CHECKLIST
1. State: …………………………………………………………………………
2. Local Government Area: …………………………………………………….
3. Nature of the activity: ………………………………………………………..
4. Brief Description of the Project:………………………………………………
5. Environmental Category of the Main Project
A) GENERAL ELIGIBILITY
Does the activity …
Yes No
Have an impact on areas for which the World Bank Environmental and Social Standards have not
been applied? In particular:
• Disrespect for human dignity, human rights, economic systems and cultures of indigenous
peoples (under ESS7: Indigenous Peoples)?
• Impact on forest health and quality?
• Involve construction of dams?
• Serious consequences resulting in malfunctioning or stopping a dam?
• Effects on waters of two or more states (under OP 7.50 International waterways)?
• Is the project highly contentious and likely to attract the attention of NGOs or civil society
nationally or internationally?
If the answer is YES to one of these general eligibility questions: the sub-project is not eligible under
the Project.
B) ENVIRONMENTAL AND SOCIAL IMPACTS SCREENING
Will the activity …
Yes No If yes give the
extent (in
ha/number)
1 Include clearing of forests?
2 Include removal and/or cutting of a considerable number of trees?
3 Involve reclamation of wetland, land?
4 Potentially affect the ecology of a protected area (e.g., interference
on mammalian or bird migration routes)?
5 Potentially affect geological or soil instability (e.g., erosion,
landslides and subsidence)?
6 Be located in an area threatened by silting?
7 Be located in any flood protection area?
8 Be located in any flood prone area?
9 Be located 60 meters from the bank of a public stream
10 Lead to increase in waste generation
11 Be located in an area where there is no household waste
management system?
12 Generate non-hazardous waste that will be stored on the project
site?
13 Use of hazardous or toxic materials and generation of hazardous
wastes?
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14 Involve the use of an already over-exploited groundwater?
15 Contribute to reducing the amount of water available to other local
users?
16 Be located in an area where there is no sanitation network?
17 Occur in old establishments that may contain asbestos cement?
18 Include large deep excavations?
19 Soil excavation during subproject's construction so as to cause soil
Erosion
20 Have important potential accidental soil erosion, groundwater
pollution and contamination?
21 Greatly increase air pollution and dust generation?
22 Long-term impacts on air quality
23 Greatly increase noise pollution and vibrations?
24 Finance any pesticides or procurement of pesticide equipment
25 Minimum land area required for the proposed development (ha)
26 Available total land area within the identified location (ha)
27 Expected construction period
28 Source of fresh Surface Water
29 Surface Water Use Agriculture Domestic Animal other
30 Change of surface water quality or water flows (e.g. Increase water Yes No
turbidity due to run- off, waste water from camp sites and erosion,
and construction waste) or long term.
31 Separation or fragmentation of habitats of flora and fauna? Yes No
32 Are there any environmentally and culturally sensitive areas within Protected Areas/Migratory
250m? Pathways/Archaeological
sites/Wetlands/Mangroves sands
33 Any historic, archaeological reserve, ancient or protected Yes No
monument, graveyards, temples
34 Need to open new, temporary or permanent, access roads?
35 Acquisition (temporarily or permanently) of land (public or private)
for its development
36 Is there any potential for land dispute, assets and livelihoods If yes, refer to Resettlement Policy Framework
displacement?
37 Involuntary restriction of access by people to legally designated
parks and protected areas
38 Risk of disease dissemination from construction workers to the Yes No
local peoples (and vice versa)?
39 Are children in the project area likely to be used for child labor
If the answer is YES to one of these questions: An Environmental Review (ER)/Environmental Audit/ESMP/ ESIA
will be prepared in line with World Bank requirements – even if, because of the nature of the works, national
procedures do not require the preparation of an Environmental Review (ER) or of an EIA.
If the answer is NO to all questions: According to national regulations, an ER or an EIA will not be mandatory.
However, in compliance with WB ESF the preparation of a fully-fledged ESMP, will be considered as necessary.
The appropriate instrument to be prepared will depend on the risk rating of the sub-project based on the screening
Additional checklists may be developed as required based on the complexity of the projects
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ANNEX 6 ENVIRONMENTAL AND SOCIAL MONITORING CHECKLIST
ACTIVITIES INSTRUMENTS
PREPARATORY PHASE
E&S Framework ESMF RPF PMP
Status of Preparation Yes/No Yes/No Yes/No
Date of Disclosure (in-Country)
Date of Disclosure (World Bank)
Date of Consultations Carried out
E&S Staffing Environmental Social Officer GBV Officer
Officer
Yes/No Yes/No Yes/No
Training for PIU/MDAs ESMF RPF Implementation
Implementation
Date of Training
Participants
Site – Specific Instruments for Sub-Projects
Title of Rehabilitation Project ESIA RAP ESMP
Status of preparation Yes/No Yes/No Yes/No
Review status FPMU/WB FPMU/WB FPMU/WB
Cleared Status Yes/No Yes/No Yes/No
Date of Disclosure (in-Country)
Date of Disclosure (World Bank)
Date of Consultations Carried out
Training on ESIA/ESMP Implementation ESMP RAP
Implementation Implementation
Date of Training
Participants
Developed Operationalized
Grievance Redress Mechanism Yes/No Yes/No
Availability number of complaint boxes on all roads
Total number of contractor staff on project
Locals Foreign
Total number of contractor staff trained on Code of
Conduct (CoC)
Total number of signed code of conduct by staff
and contractor
Host agreement received for contractors
yard/Office
Host agreement received for borrow pits
Host agreement received for contractors residence
IMPLEMENTATION PHASE
Contractors C-ESMP Yes No
Staffing
Availability of Environmental /HSE on contractors Yes No
team
Availability of Environmental Officer/HSE on Yes No
supervision consultants team
Availability of Social Officer on contractors team
Availability of Social Officer on supervision
consultants team
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Training (Contractors, Supervision Consultants) C-ESMP GBV Training/ Code Grievance Redress
Implementation/ of Conduct Mechanism
HSE
Date of Training
Participants
Site Monitoring
Adequacy of site office and campsite (water, ventilation, furniture, toilets, security, first-aid)
Conducive site office in line with OHS requirements
Conducive camp site in line with OHS requirements
Availability of well-stocked first aid box Site office Construction site Mobile kit
Standard Toilet Facility meeting WHO standard Male/female Y/N Water Y/N Adequate septic
Y/N
Adequate waste management Y N
Adequate Staging Area
Fence Y N
Caution Tape Y N
Good housekeeping Y N
Lightening Y N
Occupational Health & Safety Available/ Adequate Compliance
PPEs
Cautionary Signs
Flagmen
Cordon off excavated areas
Mobile First Aid box
Accident/ Incident Fatal Y/N Minor Y/N
Compliance with Traffic Management Plan and
safety (Site Safety and Security, Road/caution
Signs)
Awareness and sensitization of communities on
STIs/STDs
Date of program/ Venue
Participants
Grievance Redress Comments
No of Grievances received
No of grievances resolved
Environmental Parameters Limits Satisfactory Not satisfactory Comments
Air pollution
water pollution
Land pollution
Noise
Fugitive dust
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Environmental and Social Management Framework (ESMF) for the Adolescent Girls Initiative for Learning and Empowerment Program
ANNEX 7: GENERIC WASTE MANAGEMENT PLAN
Objectives of the Waste Management Plan
• Ensure reduction of wastes
• Meet the environmental requirements of the different State FME and other national and international waste
management guidelines.
• Establish, implement and maintain waste segregation at source.
• Ensure that PCU and Contractors are responsible for effective waste handling and disposal process, which
shall be monitored by relevant waste disposal authorities
The ESMP will provide detailed information on waste management including the amount and type of waste to be
generated, the sources, and the existing waste management practices and proffer mitigation measures, which will
involve:
• Sensitization amongst the Contractors, workers, laborers on the need for effective waste management in and
around the pumping stations throughout the project activities.
• Community sensitization and mobilization on the adverse consequences of poor waste management.
Waste types
The rehabilitation works will produce vast amount of waste from the construction activities.
The following are some of the materials that can be expected to be generated during construction: vegetation
stripping, concrete forms, packing materials, containers for various construction materials, asbestos, plastics, waste
oil, filters, lubricants and hydraulic fluids, food, sewage, etc. It is necessary to ensure that wastes generated during
construction are handled in a way that protects human, animal and environment health and complies with applicable
regulations.
Recommended Measures for Waste Management
• Minimize the production of waste by using resource efficient products
• Contractors should reuse and recycle waste generated as much as possible
• Identify and classify the type of waste generated. If hazardous wastes are generated, proper procedures must
be taken regarding their storage, collection, transportation and disposal
• Identify and demarcate disposal areas clearly indicating the specific materials that can be deposited in each
• Control placement of all construction waste to approved disposal sites (>300 m from rivers, streams, lakes,
or wetlands).
• Dispose all wastes in authorized areas, metals, used oils, and excess material generated during construction
• Incorporate recycling systems and the separation of materials
• Identify and demarcate equipment maintenance areas (>15m from rivers, streams, lakes or wetlands).
• Identify, demarcate and enforce the use of within-site access routes to limit impact to site vegetation.
• Install and maintain an adequate drainage system to prevent erosion on the site during and after construction.
• Erect erosion control barriers around perimeter of cuts, disposal pits, and roadways.
• Spray water on dirt roads and stockpiled soil to reduce wind-induced erosion and particulates dispersal, as
needed.
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• Identify and demarcate locations for stockpiles and borrow pits, ensuring that they are 15 meters away
from critical areas such as steep slopes, erosion-prone soils, and areas that drain directly into sensitive water
bodies.
• Establish and enforce daily site clean-up procedures, including maintenance of adequate disposal facilities
for construction debris.
The management of other kinds of waste that may be generated is highlighted below
General Waste
• There should be adequate number of garbage bins and containers made available at strategic areas of the site.
The use of plastic bin liners should be encouraged.
• All organic and inorganic materials should be placed and/or disposed of so as not to directly or indirectly
impact any watercourse or groundwater. The placement and disposal of all such products and materials
should be done in an environmentally acceptable manner.
• Solids, sludge and other pollutants generated as a result of construction or those removed during the course
of treatment or control of wastewaters will be disposed of in a manner that prevents their direct or indirect
re-entry into any watercourse or ground water.
• Any waste material that is inadvertently disposed in or adjacent to watercourses should be removed
immediately in a manner that minimizes adverse impacts, and the original drainage pattern should be restored.
• All wastes that are not designated, as combustible waste on-site should be recycled, disposed of in any of
sites (landfill, dumpsites, or waste treatment, if applicable) approved the authority
• Waste materials should be placed and stored in suitable containers. Storage areas and containers will be
maintained in a sanitary condition and shall be covered to prevent spreading of wastes by water, wind or
animals.
• All food wastes should be collected and stored in containers at appropriate locations and should be emptied
at regular intervals and the collected waste should be transported to Government designated waste
management facilities.
Oil waste
• Ensure that all equipment maintenance activities, including oil changes, are conducted within demarcated
maintenance areas designated for such.
• Ensure that oil or other lubricants are never dumped on the ground, in designated areas.
Material waste (concrete, stones, mixtures, cement)
• There should be a designated site for washing of containers or trucks that contain cement wastes.
• Control placement of all construction waste to approved disposal sites (>300 m from rivers, streams, lakes,
or wetlands).
• Concrete waste, including wastewaters from batching or cleaning, should only be disposed of at approved
and designated disposal sites with containment facilities.
• All cement-contaminated wastewater from cleaning or mixing is to be considered toxic and must be prevented
from entering any watercourse or drainage channel for at least 48 hours, in order to allow the water to reach
neutral pH level.
Sewage Disposal
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• It is highly imperative to channel sewage facilities to avoid getting into the ground water, soil or even
resulting to other types of nuisance to the environment.
• Mobile sanitary waste collection and disposal facilities or systems should be made available at the
construction sites, camps, work areas, workshops, stores, and offices.
• All temporary toilets should be placed in environmentally acceptable areas and shall be equipped with
approved septic tanks having safe drainage that are emptied only into approved treatment plants or sewage
tanker truck.
• The temporary toilet facility should be secured to avoid or minimize damage from animals or vandalism.
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ANNEX 8: CONTRACTOR’S CODE OF CONDUCT ON GENDER BASED
VIOLENCE (GBV) AND SEXUAL EXPLOITATION & ABUSE (SEA)
The company is obliged to create and maintain an environment which prevents Gender Based Violence (GBV)
and Sexual Exploitation & Abuse (SEA) issues. The company is also required to maintain an environment
where the unacceptability of GBV and actions against children are clearly communicated to all those involved
in the project. In order to prevent GBV and SEA, the following core principles and minimum standards of
behavior will apply to all employees without exception:
1. GBV/SEA constitutes acts of gross misconduct and are therefore grounds for sanctions,
penalties and/or termination of employment. All forms of GBV/SEA including grooming are
unacceptable, be it on the work site, the work site surroundings, project neighborhoods or at
worker’s camps. Prosecution of those who commit GBV or SEA will be followed.
2. Treat women, children (persons under the age of 18), and men with respect regardless of race,
color, language, religion, political or other opinion, national, ethnic or social origin, property,
disability, birth or other status.
3. Do not use inappropriate language or behavior towards women, children and men. This includes
harassing, abusive, sexually provocative, derogatory, demeaning or culturally inappropriate
words, gestures or actions.
4. Sexual activity with children under 18—including through digital media—is prohibited. Mistaken
belief regarding the age of a child and consent from the child is not a defense.
5. Sexual favors or other forms of humiliating, degrading or exploitative behavior are prohibited.
6. Sexual interactions between contractor’s and consultant’s employees at any level and member of
the communities surrounding the workplace that are not agreed to with full consent by all
parties involved in the sexual act are prohibited. This includes relationships involving the
withholding/promise of actual provision of benefit (monetary or non-monetary) to community
members in exchange for sex – such sexual activity is considered “non-consensual” within the
scope of this Code.
7. All employees are required to attend an induction training course prior to commencing work on
site to ensure they are familiar with the GBV/SEA Code of Conduct.
8. All employees must attend a mandatory training course once a month for the duration of the
contract starting from the first induction training prior to commencement of work to reinforce
the understanding of the institutional GBV and SEA Code of Conduct.
9. All employees will be required to sign an individual Code of Conduct confirming their agreement
to support GBV and SEA activities.
I do hereby acknowledge that I have read the foregoing Code of Conduct, do agree to comply with the standards contained therein
and understand my roles and responsibilities to prevent and respond to GBV and SEA. I understand that any action inconsistent
with this Code of Conduct or failure to take action mandated by this Code of Conduct may result in disciplinary action.
FOR THE COMPANY
Signed by ____________________
Title: _________________________
Date: _________________________
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MANAGER’S CODE OF CONDUCT ON GENDER BASED VIOLENCE (GBV)
AND SEXUAL EXPLOITATION & ABUSE (SEA)
Managers at all levels have responsibilities to create and maintain an environment that prevents GBV and SEA.
They need to support and promote the implementation of the Company Codes of Conduct. To that end,
Project Managers are required to sign up to Codes of Conduct applicable to their managerial duties within the
context and also sign the Individual Codes of Conduct. This commits them to support and develop systems
that facilitate the implementation of this action plan and maintain a GBV-free, child-safe and conflict-free work
environment. These responsibilities include but are not limited to:
Mobilization
1. Establish a GBV/SEA Compliance Team from the contractor’s and consultant’s staff to write
an Action Plan that will implement the GBV and SEA Codes of Conduct.
2. The Action Plan shall, as a minimum, include the
i. Standard Reporting Procedure to report GBV and SEA issues through the project Grievance Redress
Mechanism (GRM);
ii. Accountability Measures to protect confidentiality of all involved; and,
iii. Response Protocol applicable to GBV survivors/survivors (including access to support coping and
post-trauma management strategies) and perpetrators.
iv. Engagement of the services of social service providers (NGOs) with requisite skill in the prevention
and management of GBV and SEA.
3. Coordinate and monitor the development of the Action Plan and submit for review to the
RAAMP-PIU safeguards teams, as well as the World Bank prior to mobilization.
4. Update the Action Plan to reflect feedback and ensure the Action Plan is carried out in its
entirety.
5. Provide appropriate resources and training opportunities for capacity building so members of
the compliance team will feel confident in performing their duties. Participation in the
Compliance tame will be recognized in employee’s scope of work and performance
evaluations.
6. Ensure that contractor, consultant and client staff are familiar with the RAAMP GRM and
that they can use it to anonymously report concerns over GBV and SEA.
7. Hold quarterly update meetings with the compliance team to discuss ways to strengthen
resources and GBV/SEA support for employees and community members.
8. In compliance with applicable laws and to the best of your abilities, prevent perpetrators of
sexual exploitation and abuse from being hired, re-hired or deployed. Use background and
criminal reference checks for all employees.
9. Ensure that when engaging in partnership, sub-grant or sub-recipient agreements, these
agreements
a) incorporate this Code of Conduct as an attachment;
b) include the appropriate language requiring such contracting entities and individuals, and their
employees and volunteers to comply with this Code of Conduct; and
c) expressly state that the failure of those entities or individuals, as appropriate, to take preventive
measures against GBV and SEA, to investigate allegations thereof, or to take corrective actions when
GBV/SEA has occurred, shall constitute grounds for sanctions and penalties.
Training
1. All managers are required to attend an induction manager training course prior to commencing work
on site to ensure that they are familiar with their roles and responsibilities in upholding the GBV/SEA
Codes of Conduct.
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2. Provide time during work hours to ensure that direct recruits attend the mandatory induction training
which covers GBV/SEA training required of all employees prior to commencing work on site.
3. Managers are required to attend and assist with the NGO-facilitated monthly training courses for all
employees. Managers will be required to introduce the trainings and announce results of consequential
evaluations.
4. Collect satisfaction surveys to evaluate training experiences and provide advice on improving the ef-
fectiveness of training.
Prevention
1. All managers and employees shall receive a clear written statement of the company’s requirements with
regards to preventing GBV/SEA in addition to the training.
2. Managers must verbally and in writing explain the company and individual codes of conduct to all
direct recruits.
3. All managers and employees must sign the individual ‘Code of Conduct for GBV and SEA, including
acknowledgment that they have read and agree with the code of conduct.
4. To ensure maximum effectiveness of the Codes of Conduct, managers are required to prominently
display the Company and Individual Codes of Conduct in clear view in public areas of the work space.
Examples of areas include waiting, rest and lobby areas of sites, canteen areas, health clinics.
5. Managers will explain the GRM process to all employees and encourage them to report suspected or
actual GBV/SEA
6. Mangers should also promote internal sensitization initiatives (e.g. workshops, campaigns, on-site
demonstrations etc.) throughout the entire duration of their appointment in collaboration with the
compliance team, service providers and in accordance to the Action Plan.
7. Managers must provide support and resources to the compliance tea and service provider NGOs to
create and disseminate the internal sensitization initiatives through the Awareness-raising strategy
under the Action Plan.
Response
1. Managers will be required to provide input, final decisions and sign off on the Standard Reporting
Procedures and Response Protocol developed by the compliance team as part of the Action Plan.
2. Once signed off, managers will uphold the Accountability Measures set forth in the Action Plan to
maintain the confidentiality of all employees who report or (allegedly) perpetrate incidences of
GBV/SEA (unless a breach of confidentiality is required to protect persons or property from serious
harm or where required by law).
3. Once a sanction has been determined, the relevant manager(s) is/are expected to be personally re-
sponsible for ensuring that the measure is effectively enforced, within a maximum timeframe of 14
days from the date on which the decision was made.
4. Managers failing to comply with such provision can be in turn subject to disciplinary measures, to be
determined and enacted by the company’s CEO, Managing Director or equivalent highest-ranking
manager. Those measures may include:
i. Informal warning
ii. Formal warning
iii. Additional Training
iv. Loss of up to one week’s salary.
v. Suspension of employment (without payment of salary), for a minimum period of 1 month up to a
maximum of 6 months.
vi. Termination of employment.
I do hereby acknowledge that I have read the foregoing Code of Conduct, do agree to comply with the standards contained therein
and understand my roles and responsibilities to prevent and respond to GBV and SEA. I understand that any action inconsistent
with this Code of Conduct or failure to take action mandated by this Code of Conduct may result in disciplinary action.
FOR THE EMPLOYER
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Signed by ____________________
Title: _________________________
Date: _________________________
EMPLOYEE’S CODE OF CONDUCT ON GENDER BASED VIOLENCE (GBV)
AND SEXUAL EXPLOITATION & ABUSE (SEA)
I, __________________________________________ (name of employee), acknowledge that preventing
Gender-based Violence (GBV) and Sexual Exploitation & Abuse are important. GBV/SEA activities constitute
acts of gross misconduct and are therefore grounds for sanctions, penalties or termination of employment. All
forms of GBV or SEA are unacceptable either on the work site, neighbouring project communities, or at
worker’s camps. Prosecution of those who commit GBV/SEA will be followed as appropriate according to
applicable laws. I also acknowledge the need to maintain peaceful relationships and interactions with residents
of project areas.
Specifically, I agree that while working on projects of the Rural Access and Mobility Project (RAAMP), I will:
i. Maintain conflict-free relationships with residents of project areas when such relationships and
interactions become necessary.
ii. Consent to police background check.
iii. Treat women, children (persons under the age of 18), and men with respect regardless of race,
color, language, religion, political or other opinion, national, ethnic or social origin, property,
disability, birth or other status.
iv. Not use language or behavior towards women, children or men that is inappropriate,
harassing, abusive, sexually provocative, demeaning or culturally inappropriate.
v. Not participate in sexual activity with children—including grooming or through digital media.
Mistaken belief regarding the age of a child and consent from the child is not a defense.
vi. Not engage in sexual favors or other forms of humiliating, degrading or exploitative behavior.
vii. Not have sexual interactions with members of the communities surrounding the work place
and worker’s camps that are not agreed to with full consent by all parties involved in the sexual
act. This includes relationships involving the withholding or promise of actual provision of
benefit (monetary or non-monetary) to community members in exchange for sex—such
sexual activity is considered “non-consensual” within the scope of this Code.
viii. Attend and actively partake in training courses related to HIV/AIDS, GBV and SEA as
requested by my employer.
ix. Report through the GRM or to my manager suspected or actual GBV and/or SEA by a fellow
worker, whether in my company or not, or any breaches of this code of conduct.
With regard to children under the age of 18:
x. Wherever possible, ensure that another adult is present when working in the proximity of
children.
xi. Not invite unaccompanied children into my home, unless they are at immediate risk of injury
or in physical danger.
xii. Not sleep close to unsupervised children unless absolutely necessary, in which case I must
obtain my supervisor’s permission, and ensure that another adult is present if possible.
xiii. Use any computers, mobile phones, or video and digital cameras appropriately, and never to
exploit or harass children or to access child pornography through any medium (see also “Use
of children’s images for work related purposes”).
xiv. Refrain from physical punishment or discipline of children.
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xv. Refrain from hiring children for domestic or other labor which is inappropriate given their age
or developmental stage, which interferes with their time available for education and
recreational activities, or which places them at significant risk of injury.
xvi. Comply with all relevant local legislation, including labor laws in relation to child labor.
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