Ministry of Education and Science of Ukraine Ukraine Improving Higher Education for Results Project Stakeholder Engagement Plan (SEP) January 2021 DRAFT - Subject to Changes Table of Contents 1. INTRODUCTION 7 1.1 Sector Background 7 1.2 Project Information 8 1.3 Purpose and Objectives of the Stakeholder Engagement Plan 10 2. REGULATORY CONTEXT 11 2.1 Ukraine Citizen Engagement Legislation 11 2.2 World Bank Citizen Engagement Requirements 12 3. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES 13 3.1 Consultations on the Education Reform Prior to this SEP 13 3.2 Consultations on Relevant Analytical Work Conducted by the World Bank 13 3.3 Consultations on the Proposed Project Design/Components 14 4. STAKEHOLDER IDENTIFICATION AND ANALYSIS 14 5. STAKEHOLDER ENGAGEMENT PROGRAM 17 5.1 Stakeholder Engagement Action Plan (Preparation Phase and/or Prior to the Launch of Individual Activities) 17 5.2 Stakeholder Engagement Action Plan (Implementation Phase after the Launch of Project Activities) 20 5.3 Timeline for Provision of Comments and Feedback 23 5.4 Proposed Information Disclosure Approach 24 5.5 Roles and Responsibilities and Estimated Budget 27 6. GRIEVANCE REDRESS MECHANISM 27 6.1 Objective of the GRM Mechanism 27 6.2 Awareness Building 29 6.3 Roles and Responsibilities for GRM 29 6.4 Monitoring and Reporting on GRM Implementation 29 7. REFERENCES 30 8. ANNEX A – GRIEVANCE/INQUIRY RECORD 31 ABBREVIATIONS AND ACRONYMS CPF Country Partnership Framework ECA Europe & Central Asia ESF Environmental and Social Framework ESS Environmental and Social Standard GRM Grievance Redress Mechanism HE Higher Education HEI Higher Education Institution M&E Monitoring & Evaluation MOES Ministry of Education and Science MOF Ministry of Finance NAHEQA National Agency for Higher Education Quality Assurance PBCs Performance-based conditions PDO Project Development Objective PIU Project Implementation Unit POM Project Operational Manual SEP Stakeholder Engagement Plan SEA/SH Sexual Exploitation and Abuse/Sexual Harassment TA Technical Assistance TOR Terms of Reference UCEQA Ukrainian Center for Education Quality Assessment WB World Bank 1. INTRODUCTION 1.1 Sector Background Ukraine’s higher education sector is undergoing ambitious and challenging reforms in several sub-sectors that can unleash and maximize the human potential of the Ukrainian society and translate it into higher economic growth and welfare. Important new laws have been passed in recent years that set the framework for modernization in several sub-sectors, including the Law on Higher Education in 2014, the Law on Research and Scientific Activity in 2015, and the Law on Education in 2017. At the same time, the COVID-19 pandemic has significantly affected teaching and learning in Ukrainian universities, and the switch to online and distance modalities has revealed significant challenges.  Higher Education Reform The 2014 Law on Higher Education supported important reforms which aimed to align the Ukrainian higher education with the Bologna process. It supported the implementation of the three-cycle structure of Higher Education – Junior Bachelor (short cycle), Bachelor – Master – PhD and plus 4th or postdoctoral cycle – Doctor of Science. It encouraged the academic, organizational and financial autonomy of Ukrainian universities (by allowing international grants for research and education to be placed in private bank accounts and not only on the State Treasury). In September 2017, the Ukrainian Parliament passed amendments which increased student participation in university governance, tied financial aid to cost of living increases, improved financial transparency at HEIs, imposed term limits for university presidents and deans, and further promoted academic autonomy. They also restructured public university funding in a way that incentivizes universities to compete for the best students. Further reforms are now underway.  The World Bank Support to the Education Reform in Ukraine The World Bank has been an important counterpart in advancing the education reforms in Ukraine. The Country Partnership Strategy, under Focus Area 3: Efficiency and Inclusiveness of Social Service Delivery, highlights the critical importance of the education sector for both the improvement in the delivery of public services and making markets work. For some time, the assistance focused primarily on providing technical assistance and analytical work to strengthen the capacity for data and evidence-based policy making. The World Bank’s recent Education Flagship Report has identified several key challenges in the higher education sector where the Government’s reform program could be strengthened, particularly around quality, efficiency, and transparency. This analysis identified opportunities for more efficient and productive use of resources to strengthen the reform agenda. This analysis flagged several key issues in the sector, including improving institutional governance structures and capacity, targeting resource flows, aligning incentives for key stakeholders, and delivering more effective feedback and transparent information. 7 1.2 Project Information Based on the analysis from the Education Flagship Report, the World Bank is currently engaged with the Ministry of Education and Science of Ukraine in developing an investment operation to help advance the ongoing reform of the higher education.  Project Development Objective The Project Development Objective (PDO) is to improve efficiency, conditions for quality, and transparency in higher education system of Ukraine. To achieve this objective, the operation would be structured in the following components, as described below.  Project Components Component 1: Sector-Wide Improvements to Governance, Financing, Quality and Transparency. The objective of this component is to support the Government with implementation and monitoring of sector-wide reforms affecting higher education governance and financing, quality, and transparency, as well as support strategic communications related to both the project and the larger higher education reform. This component contains two mutually reinforcing sub-components: 1.1 which supports strategic sector-wide investments to strengthen system management, planning and monitoring, and 1.2 which reimburses against specific results through performance-based conditions (PBCs). Sub-component 1.1 – Strategic sector-wide investments to support autonomy, transparency, and monitoring This sub-component would support strategic investments in information systems (including Higher Education Management Information System (HEMIS)),surveys evaluations, standardized tools for learning assessments, and comprehensive communications campaigns and outreach efforts for the ongoing higher education reform. In particular, these strategic investments are needed to support the introduction of autonomy reforms and performance-based incentives for HEIs, and to improve transparency of funding and information flows within the sector. This sub-component will also finance the design, establishment and implementation of a National Student Survey (NSS) and support introduction of digitally enhanced standardized learning assessments for higher education. Sub-component 1.2: Strategic results to strengthen performance-based incentives in higher education To incentivize policy changes and implementation of key activities, this sub-component will finance critical performance-based conditions (PBCs) related to introduction and implementation of performance- based incentives at the system-level and at institutional levels in the higher education sub-sector. Under the PBCs mentioned below, the project will co-finance results that will lay the foundations for performance-based incentives to improve efficiency, conditions for quality, and transparency in higher education while building on the strategic activities financed under sub-component 1.1. This sub- component will reimburse the Government for results achieved in support of the following specified disbursement-linked indicators (PBCs): o PBC 1: Performance-based funding formula for HEIs. The proposed Project will support the implementation of the Government’s financing and governance reforms in the higher education sector, specifically implementation of a performance-based funding formula for public HEIs that incorporates a stability funding component and a performance-based component. 8 o PBC 2: Financial autonomy for HEIs. The proposed Project will support the Government’s vision for financial autonomy for HEIs by financing actions that enable such autonomy. Two PBCs would be supported under this PBC:  PBC 2.1: Financial autonomy for HEIs: package of laws. This will include necessary revisions to the Law on Higher Education and/or related laws to address issues of budgetary institutions and related aspects of financial autonomy for HEIs.  PBC 2.2: Financial autonomy: adopting bylaws. This will include development and adoption of bylaws for financial autonomy in HEIs in accordance with existing legislation. o PBC 3: Performance-based rector contracts with KPIs signed (scalable). Within the frame of financial autonomy of higher education, the system of performance-based relationships between the MOES and HEIs shall be introduced. These are to be established in the form of performance agreements (contracts), whose KPIs are negotiated jointly between the MOES and the rector of the HEI. Component 2: Alliances and Partnerships for Improved Efficiency and Quality The objective of this component is to support the Government improve fiscal efficiency in the higher education sector and to support merged HEIs to improve conditions for quality teaching and learning as part of institutional merger processes. This component is also divided into two sub-components: Sub-component 2.1: Strategic investments to ensure successful university mergers Under this sub-component, the Project would finance packages of investments including goods and minor civil works. These would be specified in detail in the POM, but they would be selected by MOES to promote successful implementation of governance and financial autonomy reforms, as well as quality of higher education1. In particular, “merger support packages” could include the following: laboratories for teaching, research, and/or learning, equipment for laboratories, learning support facilities, and other learning spaces, modern digital infrastructure and IT to support distance learning, and minor refurbishment/rehabilitation. New construction would not be supported. Sub-component 2.2 - Strategic results to support consolidation in higher education To incentivize policy changes and implementation of key activities, this sub-component will finance a critical disbursement-linked result related to institutional mergers and consolidation of the network of higher education institutions in Ukraine. This component will follow a result-based approach and will co- finance a result under the PBC mentioned below: o PBC 4: Number of mergers of public HEIs under MOES (scalable). This PBC recognizes the significant challenges associated with incentivizing institutional mergers and consolidating the number of state HEIs, despite the widespread recognition that the status quo in Ukraine in terms of the number of HEIs relative to the declining student-age population is unsustainable. This PBC would be achieved on a scalable basis, measured as the number of mergers of state HEIs under MOES. 1 HEIs benefiting from the ongoing Higher Education Project financed by the European Investment Bank (EIB) and the Nordic Environment Finance Corporation (NEFCO) would not be subject to mergers. 9 Component 3 – Capacity Building and Education Environment Enhancement The objective of this component is to build capacity and improve the educational environments, academic managers research capacity in HEIs, including with a focus on supporting HEIs to maintain learning continuity and operational resilience via remote and distance modalities. In the short-term, this will support HEIs to adapt to the new operating reality imposed by COVID-19. In the medium-term, this will ultimately improve the overall relevance, quality and external economic efficiency of the HEIs and their graduates in support of innovation and economic development. To build capacity of academic managers in HEIs, this component would also support targeted training for managerial staff in several key areas, including, inter alia, development of change management plans, academic innovation, labor market linkages, strategic planning and change management, entrepreneurship and business engagement, human resource management, and financial management/taxation. This component would also support the establishment of an Operational Sustainability Team within the MOES, staffed by a small number of specialized consultants to facilitate the process of introducing financial, staffing, human resources, and other types of autonomy at the institutional level. This would help to enhance sustainability for long-term implementation of the project. Additionally under this component, , the project would finance pre-defined categories of goods and services, including modern digital infrastructure for distance learning, digital devices, multimedia equipment and software, electronic learning management systems, and similar types of IT investments to improve quality of distance learning modalities. Investments would also include modern basic teaching laboratories and advanced scientific research laboratories, equipment, and minor refurbishment and rehabilitiation. Component 4: Project Management, Monitoring & Evaluation The objective of this component is to support the effective management and implementation of the proposed project. The component would finance a comprehensive communications campaign and outreach effort for the ongoing higher education reform. Additionally, the component would finance the day-to-day management and monitoring of the proposed project through the establishment and maintenance of a Project Implementation Unit (PIU) or similar, as defined in the Project Operational Manual (POM) at the Ministry of Education and Science (MOES). It would finance salaries for PIU staff/consultants, including fiduciary, environmental and social risk management staff and incremental consultants, training activities, targeted technical assistance, and operating costs, including outreach related to the project and the project-specific Grievance Redress Mechanism (GRM). 1.3 Purpose and Objectives of the Stakeholder Engagement Plan The Ministry of Education and Science (MOES) of Ukraine recognizes the critical importance of effective communication and stakeholder engagement for the successful implementation of the proposed ambitious reform package. To this end, the project will have a strong communication and stakeholder engagement to ensure that all the stakeholders are being informed and consulted both prior and during project implementation. The purpose of the SEP is to provide a framework for appropriate stakeholder consultation and information disclosure which is appropriate to the context of the country. The goal of the SEP is to facilitate decision-making by involving project-affected people and other stakeholders in a timely manner so that these groups are provided enough opportunity to voice their opinions and concerns. The SEP is a useful tool for managing communications between MOES and its stakeholders. 10 The main objective of the SEP is the following:  To understand the stakeholder engagement requirements of the Ukrainian legislation  To identify key stakeholders that are affected, and/or able to influence the Project and its activities  To develop a stakeholder’s engagement process that that gives stakeholders the opportunity to participate and influence project design and implementation  To define the information disclosure provisions under the project  To establish a formal Grievance Redress Mechanism under the project  To define roles and responsibilities for the implementation of the SEP  To define the monitoring arrangements to ensure that the SEP remains an effective and up-to-date tool for stakeholder engagement 2. REGULATORY CONTEXT 2.1 Ukraine Citizen Engagement Legislation Ukraine has the following legislation related to citizen/stakeholder engagement which covers both the right to access information and participation in policy development and decision-making:  Access to Information Legislation, Guidelines and Practices The Constitution of Ukraine guarantees the right to access for information for Ukrainian citizens (article 34, paragraphs 2 and 3). The Laws #2939 ‘On Access to Public Information’, #2657 ‘On Information’, and #183 ‘About state secret’ provide the regulatory framework for access to various types of public information. According to the Law ‘On Access to Public Information, information held by public authorities cannot be restricted, unless it is categorized as confidential, secret, or for internal use only. The restrictions must follow the ‘three-part test’ (tryskladovi test) of public information, as stipulated in Article 6, paragraph 2. The Law mandates public institutions to create structural units or appoint freedom of information officers. The Law assigns the monitoring functions to the Secretariat of the Ukrainian Parliament Commissioner for Human Rights (Ombudsman’s Office). The violation of the right to request and obtain information to citizens is punishable by fines while the refusal to provide access for journalists in their work can be punished by a fine, or 3 years’ imprisonment (Article 171 of the Criminal Code). On the other hand, the punishment for revealing a state secret can reach up to 5 years’ imprisonment. In the Council of Europe’s assessment, the access to information legislation in Ukraine is advanced and well developed. However, some drawbacks still exist which are accounted for primarily by the public servants’ lack of knowledge of the legal requirements and how to put them into practice. Another problem is that the responses provided are often of poor quality, incomplete or delayed. Finally, the administrative fees are somewhat high which disincentivize citizens from seeking information.  Ukrainian Citizen Engagement Legislation The procedures for public for public consultation are described in two government regulations: The first is Regulation # 996 ‘On the Procedure for Consulting the General Public on Establishing and Implementing the Public Policy which specifies the form and methods for public consultations and distinguishes between direct consultations, such as conferences, meetings, seminars, web conferences, and indirect forms, such as public surveys. The second is Regulation #976 ‘On the Procedure of Civic 11 Expertise of the Activities of the Executive Bodies’ which mandates public authorities to conduct consultations with the public at the request of NGOs, trade unions, public associations, employers and representatives of local administrative bodies. Ukraine was taking steps to make public consultations a legally-binding procedure through the proposed draft Law ‘On public consultations’. The law was assessed by and positive reviews from the OSCE, but it is not clear at this point whether the law was adopted and/or at what phase in the legislative process it is.  Ukrainian Mechanisms for Complaints Law #393 ‘On Citizens’ Appeal’147 defines (Article 3, paragraph 4) and regulates (Articles 16-19) the application of complaints mechanisms. Both national and local authorities are obliged to objectively consider citizens’ complaints, to compensate citizens for any breach of their rights and to provide justification for any decision taken in the examination of complaints. The violation of the above- mentioned Law leads to the disciplinary, administrative or criminal liability of the public officials. An increasing number of public authorities, regional and city administrations develop online mechanisms for the submission of complaints/grievances by citizens with emerging best practice examples, such as the city of Odessa. 2.2 World Bank Citizen Engagement Requirements Stakeholder engagement is not a novel concept. The World Bank staff has always engaged a multitude of stakeholders to ensure effective project preparation, project implementation and project monitoring. The World Bank increasingly recognized the development impact that can be achieved by empowering citizens to participate in the development process and integrating citizen voice in development programs as key enablers to achieving results. To ensure a more coherent and strategic approach to understanding the environmental and social concerns of groups affected by WB-funded projects, the Board of Executive Directors approved the Environmental and Social Framework (ESF), which went into effect in 2018. The ESF protects people and the environment from potential adverse impacts that could arise from Bank-financed projects and promotes sustainable development. Within the ESF, ten Environmental and Social Standards (ESSs) set out responsibilities for Borrowers. The Standards are designed to help Borrowers manage project risks and impacts as well as improve environmental and social performance, consistent with good international practice and national and international obligations. While the previous World Bank safeguards instruments provided avenues for some public consultations, under the new ESF, it has become a stand-alone requirement providing broader opportunities to all types of stakeholders and interested parties to get involved in the planning, implementation and monitoring of the Bank investments. The Environmental and Social Standard on Stakeholder Engagement and Information Disclosure (ESS 10) defines the requirements for stakeholder engagement which are the following:  Establish a systematic approach to stakeholder engagement that helps Borrowers identify stakeholders and maintain a constructive relationship with them  Assess stakeholder interest and support for the project and enable stakeholders’ views to be considered in project design  Promote and provide means for effective and inclusive engagement with project-affected parties throughout the project life-cycle  Ensure that appropriate project information is disclosed to stakeholders in a timely, understandable, accessible and appropriate manner 12 3. SUMMARY OF PREVIOUS STAKEHOLDER ENGAGEMENT ACTIVITIES 3.1 Consultations on the Education Reform Prior to this SEP The introduction of education reforms was preceded by extensive consultations with interested and affected parties. The process included focus groups with teachers, students, parents, university administrators and regional authorities where they had the opportunity to voice their views on the gaps in the existing system and suggest improvements going forward. Having circulated the first draft for consultations and received extensive feedback, the Ministry of Education and Science created additional working groups to further refine and incorporate common sets of issues of concern that emerged after the first round of consultations: 1) how to develop effective partnerships between teachers, parents and students with the appropriate balance of rights, obligations and responsibilities; 2) the university and teacher autonomy and the striking the right balance between expected extensive autonomy and accountability for results; and 3) the equitable distribution of education funding. The policy development process and the following draft Education Law raised concerns over the right of minorities to learn in their own language. The Ukrainian educational authorities sought the opinion of the Venice Commission and the Council of Europe on the linguistic provisions of the law in line with the Framework Convention for the Protection of National Minorities and the European Charter for Regional or Minority Languages. These two instruments require that decisions that affect national minorities should be taken in consultation with their representatives which is the appropriate way to develop an inclusive education system and society. 3.2 Consultations on Relevant Analytical Work Conducted by the World Bank Prior to the project the World Bank carried out a comprehensive research and analysis on the education sector in the country. The World Bank’s recent Education Flagship Report has identified several key challenges in the sector where the Government’s reform program could be strengthened, particularly around quality, efficiency, and transparency. This analysis aimed to assess the performance of Ukraine’s education system in terms of quality and equity of outcomes and identify opportunities for more efficient and productive use of resources to strengthen the reform agenda. This analysis flagged several key issues in the sector, including improving institutional governance structures and capacity, targeting resource flows, aligning incentives for key stakeholders, and delivering more effective feedback and transparent information flows. The World Bank team jointly with the Ministry of Education and Science conducted two rounds of consultations (in February and then May 2019) with policy development stakeholders (academia, NGOs, university representatives, and others) on the preliminary findings and the final version of Education Sector Review that focused on the equity, effectiveness and efficiency concerns in the education sector. The topics of debates covered broadly two subject areas: a) rebuilding public trust in education and b) keeping the momentum of the reform. Based on the feedback provided during the first round of consultations, several key issues were raised including cost differentials between budget-funded and privately-funded seats across programs in universities; and financing mechanisms to incentivize HEI mergers and network consolidation. Very importantly, the World Bank team visited and discussed initial findings with selected universities in Lviv, Zaporizhia and Kharkiv oblasts. 13 3.3 Consultations on the Proposed Project Design/Components Based on the Bank’s analytical work and discussions with Ukrainian educational authorities, the proposed project components were identified to address the most pressing current needs where the Ukrainian Ministry of Education and Science would benefit from additional resources and support for evidence- based policy making in higher education to respond to the challenge of declining student numbers and the need to direct resources to those higher education institutions that are both relevant to the labor market requirements and deliver quality education. The Ministry of Education and Science identified strong communication and stakeholder engagement as a critical factor to get the buy-in required for the successful implementation of the project components. With regards to gender awareness and inclusion, the project will support both the development of a national university student survey to assess this in qualitative and quantitative terms and as an input and feedback mechanism on the overall university environment and on gender awareness and inclusiveness. This feedback would help to inform university policies and plans related to student enrollment, academic counselling, teaching and other relevant areas. On October 8, 2019 and February 27, 2020, the World Bank team and the Ministry of Education and Science conducted introductory stakeholder workshops with representatives of the academia, universities, regional authorities and other donors involved in the sector to seek their input and feedback on proposed project components. 4. STAKEHOLDER IDENTIFICATION AND ANALYSIS There are several groups of people and social groups who are interested in the Project. In accordance with the World Bank ESF guidelines, the list of stakeholders is categorized as follows:  Affected Parties People, social groups and organization who will be directly or indirectly affected by the project: This group includes students of higher educational institutions, parents of the students, universities’ management boards, university lecturers, and university professors who will benefit from the proposed investments or be affected by the changes in the funding formulae for higher education and associated investments in better learning environments and overall university environments.  Other Parties People, social groups and organizations who may have a possibility to influence and make decisions on implementation of the project and/or may have an interest in the Project. This group includes governmental entities such as: the Ministry of Education and Science, Ministry of Finance, and other central agencies; multilateral and bilateral donors that are also involved in the educational sector reform in higher education; national think tanks and NGOs; and trade unions.  Vulnerable and Disadvantaged Groups Disadvantaged/vulnerable individuals and groups are those who may do not have a voice to express their concerns or understand the impacts of a project, are sometimes excluded from stakeholder engagement. In 14 the context of Ukraine, the following vulnerable groups can be identified: a) internally displaced families with children as a result of the conflict in Eastern Ukraine; b) families with children with special learning needss; c) poor households with more than two children; d) marginalized ethnic communities, such as Roma; d) orphans and social orphans that live in an institutionalized environment and who may miss on the benefits and services provided by the project. The project is not targeting the vulnerable groups specifically because it focuses more on the systemic transformation of the higher education system. However, it is expected that the introduction of the new educational methodologies and improved learning environments will also benefit the above-mentioned vulnerable groups. At this point in the project design, it is not clear what the exact geographical areas of intervention are going to be. Once these are defined, the MOES/PIU will (i) identify vulnerable and disadvantaged groups in geographical areas of intervention; (ii) engage with them following the approach laid out in this SEP; and (iii) create an enabling environment at university level to ensure that they benefit from all project activities and investments. There are no exclusively vulnerable and disadvantaged groups as such that were excluded or that do not have access to quality education, although there is a deep divide between rural and urban population. In rural areas, most people engaged in agriculture and rural industries for their livelihoods are considered poor. Children in rural locations are disadvantaged due to lack of adequate facilities, poor road connectivity to reach good educational facilities, and lack of proper transport services etc. Even though the education system in Eastern part of Ukraine has been disturbed due to the conflict and some of the institutions closed, the students in the Government controlled areas are provided with opportunities to get enrolled in education institutions and able to get formal education without much hindrance over the past few years. 17 universities and 11 research institutions have successfully moved out of the conflict zones and operate in other regions of the country. The main groups of stakeholders identified so far are listed in the table below. The list can be updated and modified during Project development or implementation. Once the exact geographical area for specific project interventions are determined, the project staff dealing with the communication/stakeholder engagement will keep a registry of various specific stakeholders related to the categories outlined below: 1. University students 2. Parents of university students 3. Vulnerable groups, such as internally displaced students and children; households with disabled children; poor households with many children, orphans and social orphans 4. Ministry of Education and Science 5. National Agency for Higher Education Quality Assurance 6. State Enterprise ‘Scientific-Methodological Center of Higher and Professional Pre-Higher Education’ 7. National Qualifications Agency 8. Higher education institutions and their management boards 9. Teaching staff of universities 10. Ministry of Finance 11. Local think tanks, policy institutes and NGOs 12. Employers 13. Multilateral and bi-lateral donors involved in the education sector reform 15  Summary of Stakeholder Interest in and Influence over the Project The table below summarizes the potential role, interests and influence for each of the above-mentioned stakeholders. Stakeholder Potential Role of Stakeholder Interest Influence It is the main driver and implementor of the High High MOES reform MoF Provides funding for higher education sector High High Impacted by the financing formula, beneficiary High Medium HEI of investments Provide the quality assessment framework and Medium Medium NAHEQA methodology State Enterprise Medium Medium ‘Scientific- Methodological Center Support for the institutionalization of higher and of Higher and professional pre-higher education reforms Professional Pre- Higher Education’ National Qualifications Responsible for implementation of public policy Medium Medium Agency in the field of qualifications Main beneficiaries of training programs and High High Teaching staff of investments in labs and equipment, affected by universities financing formula Think Tanks Provide alternative data and policy advice Medium Low Provide investments in similar areas and need to High Medium Multilateral and coordinate to avoid overlap and maximize bilateral donors impact Benefit from improved education which may High Low University students affect their life-long earning potential Interested in ensuring an improved education for High Low Parents their children Since the geographical areas geographical areas Medium Low Vulnerable and where project interventions will be implemented disadvantaged group are not clear, social screening will be conducted based based on ESMF to identify vulnerable and disadvantaged groups in respective project areas High Medium Benefit from improved knowledge and skills of Employers university graduates 16 5. STAKEHOLDER ENGAGEMENT PROGRAM Stakeholder engagement is an inclusive two-way iterative process that should be conducted throughout the project life cycle to ensure that the views, concerns and opinions of the project-affected groups are considered. The table presents a comprehensive, but very tentative set of engagement activities that may take place during the project preparation stage through to implementation. The Ministry of Education and Science, jointly with the World Bank team should work further to identify and prioritize the strategic stakeholder engagements to be carried out, particularly during the preparation phase. Due to worldwide COVID-19 pandemic any follow up public consultation meetings with stakeholders to present and discuss the ESMF and RPF, LMP, ESCP and other project related documents will be conducted remotely / virtually. Given the evolving situation around COVID-19 in Ukraine and around the world, face-to-face consultations, workshops for stakeholder engagement are not advisable. Alternative means of consultations should be explored by implementing entity, following the latest public health guidelines of Ukraine, WHO and World Bank stakeholder’s engagement guidelines closely in order to adjust the format of consultations taking to account some restriction s. In particular, these restrictions will affect Bank requirements for public consultation and stakeholder engagement in projects, both under implementation and preparation. WHO has issued technical guidance in dealing with COVID-19, including: (i) Risk Communication and Community Engagement (RCCE) Action Plan Guidance Preparedness and Response; (ii) Risk Communication and Community engagement (RCCE) readiness and response; (iii) COVID-19 risk communication package for healthcare facilities; (iv) Getting your workplace ready for COVID-19; and (v) a guide to preventing and addressing social stigma associated with COVID-19. These alternative types of stakeholder’s engagement could be but not limited to e-mail, videoconferences, social media, local and national media, radio, and other means. All these documents are available on the WHO website through the following link: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/technical-guidance. 5.1 Stakeholder Engagement Action Plan (Preparation Phase and/or Prior to the Launch of Individual Activities) Project Topic of Target Stakeholders Issues Raised Methods Time- Responsibilities component Consultation /Expected Used table/location/dates Decisions All Stakeholder All Agreement Emails, letters Prior to project Appropriate Ministry of engagement and on/Disclosure of the to effectiveness Education and Science communication SEP stakeholders staff/PIU/communication and outreach with officer plan appropriate background information 17 and SEP, posting on ministerial website for feedback All Project-related All Agreement Emails, letters Prior to project Appropriate Ministry of GRM system on/Disclosure of the to effectiveness Education and Science GRM system stakeholders staff/PIU/communication with officer appropriate background information, posting on ministerial website for feedback Component 1: Expected University management, Discuss timing and Emails, letters Exact appropriate Appropriate Ministry of Sector-Wide changes in rectors, deans, MoF, expectation of the used to timing to be Education and Science Improvements university Council of Rectors of changes in the provide determined jointly by department/PIU director to governance and Ukrainian Institutions of funding formula to background ministry and HEIs plus person(s) responsible Governance, funding Higher Education, provide the same information management, but for communications and Financing, student associations starting point for all for thought prior to the launch of stakeholder engagement Quality and universities; and the activity Transparency discussion; Discuss the dedicated selection of HEIs webpage (to and expected be outcomes determined), follow up Clarify that the video- eligibility criteria conferencing for investments or virtual based on results workshop (s) and compelling as needed vision for the future Component 2: Description of University rectors, Discuss the Emails, letters Exact appropriate Appropriate Ministry of Alliances and establishment of deans, professors, objective and used to timing to be Education and Science Partnerships criteria for student associations content of the provide determined jointly by department/PIU director 18 for Improved merged HEIs activity; eligibility background ministry and plus person(s) responsible Efficiency and which will be criteria (universities information universities, but after for communications and Quality rehabilitated and identified in the for thought initiation of merger stakeholder engagement equipped POM); time of the and launch; proposal discussion; application process dedicated webpage (to be determined) video- conferencing or virtual workshop (s) as needed Component 3 Description of University rectors, Discuss the criteria Emails, letters Exact appropriate Appropriate Ministry of – Capacity establishment of deans, professors, of HEI selection, used to timing to be Education and Science Building and criteria for HEIs student associations time of the launch, provide determined jointly by technical department/PIU Education which will be aims of the background ministry and HEIs director plus person(s) Environment rehabilitated and component information management, but responsible for Enhancement equipped and for thought prior to the launch of communications and broader support, and the activity stakeholder engagement including HEI discussion; capacity building dedicated webpage (to be determined) video- conferencing or virtual workshop(s) as needed Improving Introduction of Students, Student Discuss the Emails, letters Exact appropriate Appropriate Ministry of transparency student feedback Associations, University objectives of the used to timing to be Education and Science and mechanisms management, deans, tools to be provide determined jointly by technical department/PIU stakeholder such as the Council of Rectors of introduced; timing; background ministry and director plus person(s) engagement National Student Ukrainian Institutions of relevance to information universities, but prior responsible for (under Survey Higher Education, improvements of for thought to the launch of the communications and Component 1) professors and lecturers the HEI educational and activity stakeholder engagement Enhancement of process; relevance discussion; Unified to governance; and dedicated 19 Electronic linkages to the labor webpage (to Graduate market be Tracking System determined) video- conferencing or virtual workshop (s) as needed PBCS PBCs related to Prime Minister’s Office, Seek agreement and Face-to-face / Project preparation Ministry of Education and implementation Ministry of Finance, commitment and virtual phase Science, World Bank of performance- Parliamentary Budget political support for meetings, based funding, and Finance Committee, the PBCs from the official letters financial Parliamentary Education MoF, Prime autonomy for Committee, and other Minister’s Office HEIs, KPI-based project-affected parties and Parliament contracts for Budget and Finance rectors, and Committee mergers of HEIs Component 4: Project Management, Monitoring & Evaluation Project Implementation, MoF, Office of the Clarify roles and Face-to-face / Project preparation Ministry of Education and monitoring monitoring, Prime Minister, responsibilities on virtual phase Science, World Bank reporting and Parliamentary project management meetings, evaluation Committees for arrangements official letters arrangements Education; Budget and Finance; and other project-affected parties 5.2 Stakeholder Engagement Action Plan (Implementation Phase after the Launch of Project Activities) The Ministry of Education and Science and the project team recognize the value of keeping the project stakeholders informed about project progress and implementation challenges throughout the project cycle. The table below presents a proposed stakeholder engagement/reporting plan 20 during implementation on all aspects of project implementation, including compliance with both the national and World Bank environmental and social requirements. Like the table above, this is just a draft table to be refined after further discussions. Project Topic of Target Stakeholders Topics to discuss Methods Used Frequency Responsibilities component Consultation /Expected Decisions All Stakeholder All Present implementation Emails, letters, Semi- Appropriate Ministry of Education engagement and reports, seek feedback reports disclosed annually and Science communication from stakeholders on on ministerial staff/PIU/communication officer and outreach potential improvements website; plan implementation implementation progress workshop/video- conferences, surveys All Reporting on All Present implementation Emails, letters, Semi- Appropriate Ministry of Education project-related reports, seek feedback reports disclosed annually and Science GRM system from stakeholders on the on ministerial staff/PIU/communication officer implementation functioning of the GRM website; system implementation progress workshop/video- conferences, surveys All Reporting on All Present results of the Screening Once, the Appropriate Ministry of Education screening for screening, seek feedback checklist to geographic and Science vulnerable and from those identified identify any locations staff/PIU/communication officer disadvantaged groups vulnerable or are known groups disadvantaged and then groups (Annex semi- X in ESMF) annually Component Expected University management, Present implementation Emails, letters, Semi- Appropriate Ministry of Education 1: Sector- changes in rectors, deans, MoF, reports, seek feedback reports disclosed annually and Science technical Wide university Council of Rectors of from stakeholders on on ministerial department/PIU director plus Improvemen governance and Ukrainian Institutions of challenges and potential website; person(s) responsible for ts to funding Higher Education, student improvements/adjustments implementation communications and stakeholder Governance, associations progress engagement Financing, workshop/video- 21 Quality and conferences, Transparenc surveys y Component Description of University rectors, deans, Present implementation Emails, letters, Semi- Appropriate Ministry of Education 2: Alliances establishment of professors, student reports, seek feedback reports disclosed annually and Science technical and criteria for associations from stakeholders on on ministerial department/PIU director plus Partnerships merged HEIs challenges and potential website; person(s) responsible for for which will be improvements/adjustments implementation communications and stakeholder Improved rehabilitated progress engagement Efficiency and equipped workshop/video- and Quality conferences, surveys Component Description of University rectors, deans, Discuss the criteria of HEI Emails, letters Exact Appropriate Ministry of Education 3 – Capacity establishment of professors, student selection, time of the used to provide appropriate and Science technical Building and criteria for HEIs associations launch, aims of the background timing to department/PIU director plus Education which will be component information for be person(s) responsible for Environment rehabilitated thought and determined communications and stakeholder Enhancemen and equipped discussion; jointly by engagement t and broader dedicated ministry support, webpage (to be and including HEI determined) regional capacity video- authorities, building conferencing or but prior to virtual the launch workshop(s) as of the needed activity Improving Introduction of Students, student Present implementation Emails, letters, Semi- Appropriate Ministry of Education transparency student Associations, university reports, seek feedback reports disclosed annually and Science technical and feedback management, deans, from stakeholders on on ministerial department/PIU director plus stakeholder mechanisms, Council of Rectors of challenges and potential website; person(s) responsible for engagement such as the Ukrainian Institutions of improvements/adjustments implementation communications and stakeholder (under National Higher Education, progress engagement) Component Student Survey professors workshop/video- 1) conferences, Enhancement of surveys Unified Electronic Graduate Tracking 22 System PBCs PBCs related to Prime Minister’s Office, Present implementation Face-to-face Semi- Ministry of Education and Science implementation Ministry of Finance, reports, seek feedback meetings, annually and Science, World Bank of performance- Parliamentary Budget and from stakeholders on official letters based funding, Finance Committee, challenges and potential financial Parliamentary Education improvements/adjustments autonomy for Committee, and other HEIs, KPI- project-affected parties based contracts for rectors, and mergers of HEIs Component 4: Project Management, Monitoring & Evaluation Project Implementation, MoF, Office of the Prime Present implementation Face-to-face / Semi- Ministry of Education and Science, monitoring monitoring, Minister, Parliamentary reports, seek feedback virtual meetings, annually World Bank reporting and Committees for Education; from stakeholders on official letters, evaluation Budget and Finance; and challenges and potential Emails, letters, arrangements other project-affected improvements/adjustments reports disclosed parties on ministerial website; implementation progress workshop/video- conferences, surveys 5.3 Timeline for Provision of Comments and Feedback The Ministry of Education and Science and the World Bank team will make every effort to provide appropriate background and relevant technical information to stakeholders whose feedback is sought on various project issues with enough advance notice (5-10 business days) so that the stakeholders have enough time to prepare to provide meaningful feedback. The MOES/PIU team will gather written and oral comments, review them and commit to report back to stakeholders on how those comments were incorporated, and if not, provide the rationale for reasons for why there were not within 10 to 30 working days from the stakeholder engagement event. 23 5.4 Proposed Information Disclosure Approach The table below provides a preliminary summary of the suggested information to be disclosed based on the project design and topics that might be of interest to stakeholders. The table should be finalized following discussions between the World Bank and Ministry of Education and Science project teams. Project component List/ Type of information to be Methods of Timing/Frequency Target Responsible disclosed disclosure stakeholders stakeholders proposed All Proposed Project Design; PAD Ministry of Before project All Ministry of Education (check the WB requirements for Education and effectiveness and Science/WB team PAD disclosure) Science website; distribution via email to local authorities, universities’ websites or information boards All ESMF documentation that is Ministry of Before project All Ministry of Education required for disclosure by the WB, Education and effectiveness and Science/WB team including Stakeholder Engagement Science website; Plan and GRM description distribution via email to local authorities, universities’ websites or information boards Component 1: Sector- Changes in the funding formula Post on ministerial Annually University Ministry of Education Wide Improvements to website; management and Science, PIU, Governance, emails/letters with boards, deans, university management Financing, Quality the information or lecturers, and Transparency linkages to student information; associations virtual workshops with university administrators 24 Project component List/ Type of information to be Methods of Timing/Frequency Target Responsible disclosed disclosure stakeholders stakeholders proposed Component 2: Publish the selection criteria for Post on Before the selection University Ministry of Education Alliances and participation and the list of merged ministerial/univers of merged HEIs management and Science, PIU, Partnerships for universities to benefit from ity websites; boards, deans, university management Improved Efficiency investments emails/letters with lecturers, and Quality the information or student linkages to After selection associations information; process completed virtual workshops with university administrators Component 3 – Criteria of HEIs selection and the Ministerial and Before and after the University Ministry of Education Capacity Building and aims of this component university start of HEI selection management and Science, PIU, Education websites; boards, deans, university management Environment Publish list of the selected HEIs emails/letters with After component lecturers, Enhancement the information or completion student Results of the improved facilities in linkages to associations HEIs information; virtual workshops External with university stakeholders administrators Improving National Student Survey results After the completion University Ministry of Education transparency and published of the survey management and Science, PIU, stakeholder boards, deans, university management engagement (under lecturers, Component 1) Results of the improved Unified student Electronic Graduate Tracking After the completion associations System published of the enhanced tracking system PBCs PBCs related to implementation of Post on ministerial After relevant laws University Ministry of Education performance-based funding, website; and/or regulations management and Science, PIU financial autonomy for HEIs, KPI- emails/letters with are officially boards, deans, based contracts for rectors, and the information or adopted lecturers, mergers of HEIs linkages to student information; associations, virtual workshops local with university authorities administrators 25 Project component List/ Type of information to be Methods of Timing/Frequency Target Responsible disclosed disclosure stakeholders stakeholders proposed Component 4: Project Management, Monitoring & Evaluation Program Management, Project Progress Reports Post on ministerial Semi-annually All Ministry of Education Coordination and website; and Science, PIU Monitoring and ESMF, SEP and GRM Monitoring emails/letters with Evaluation Reports the information or linkages to information; virtual workshops with university administrators 26 5.5 Roles and Responsibilities and Estimated Budget The overall responsibility for the implementation of the stakeholder engagement and communication process lies with the Ministry of Education and Science with guidance and support from the World Bank, particularly during the project preparation phase. The Ministry will employ a Project Implementation Unit or similar, as defined in the Project Operational Manual, responsible for project management and coordination of all project activities. Within this unit, the Environmental and Social Specialists as well as the Communications Officer will ensure project compliance with the World Bank ESF Standard on Stakeholder Engagement and Disclosure under the overall guidance of the Project Director. 6. GRIEVANCE REDRESS MECHANISM 6.1 Objective of the GRM Mechanism Addressing grievances raised by individual affected by World Bank-funded projects is an important component of managing project risks including SEA/SH risks. A GRM can serve as an effective tool for early identification, assessment and resolution of grievances and therefore for strengthening accountability to beneficiaries. The GRM serves as an important feedback mechanism that can improve project impact and mitigate the undesirable ones. The GRM mechanism will be available to project stakeholders including employees and other affected parties to submit questions, comments, suggestions and/or complaints and provide any form of feedback on all project-funded activities. Grievance Investigation and Resolution Process  Channel to Make Complaints The Ministry of Education and Science intends to establish the following channels through which citizens/beneficiaries/Project Affected Persons (PAPs) can make complaints/suggestions/compliments regarding project-funded activities: a. By Email: mon@mon.gov.ua or alternative email b. Internet: Ministry of Education and Science’s website c. In writing: indicate address /post box where the letters should be sent d. Dedicated phone number: toll-free number (to be formulated in writing) e. By fax: indicate fax The grievance could be submitted anonymously. The anonymous grievance should be received and investigated at the same manner that grievance from identified person or organization. The Ministry guarantee the confidential of complainant`s personal data.  Receipt and Referral The person receiving the complaint will complete a grievance form (see Annex 1), or the complainant can fill the form himself/herself and submit it to one of the addresses above. The dedicated ESF/GRM Officer within the Project Implementation Unit (or its equivalent) will register the grievance in the Registry of Grievances and inform the complainant of the timeframe he/she is expected to receive a response. Then the ESF/GRM staff will refer the case to the Project Director. 27 Within five business days, the Project Director will determine which person/department should be responsible to investigate the complaint, whether the complaint requires and investigation or not and the timeframe to resolve it. The Project Director should ensure that there is no conflict of interest involved for the investigating officer. The length of the investigation process depends on the complexity of the case. However, all complainants should receive feedback on the status of their grievance within ten business days.  Investigation The person/department responsible for investigating the complaint will collect and review all the facts related to the grievance. The process may include meetings / virtual consultations with the person who filed the grievance (if willing to meet) and those who can facilitate the resolution. The deadline for investigating the complaint may be extended to 30 working days by the corresponding Project Director, and the complainant is to be informed about this fact within 10 working days, whether: - additional consultations are needed to provide response to the complaint; - the complaint refers to a complex volume of information and it is necessary to study additional materials for the response. After the investigation is finalized, the proposed response will be presented to the GRM/ESF Officer and Project Director. The GRM/ESF Officer will record the proposed action in the Registry of Grievances in the section that describes the suggested action (see Annex 1).  Response to the Complainant The complainant will be informed about the results of verification via letter, email or by post, as received. The response shall be based on the materials of the investigation and, if appropriate, shall contain references to the national legislation. The ESF/GRM officer will seek feedback whether the proposed actions are deemed satisfactory and will record the response in the corresponding section of the grievance form.  SEA/SH related grievances As the major civil works are not envisaged by the Project, there are no necessity to create separate GM for addressing of SEA/SH related grievances. In case, if such grievances will be received by the Ministry of Education, they will be investigated and addressed in the framework of general GRM procedure. The personal data of complainant will be protected by the implementer and will not noticed in reports. The focal point for grievance redressing will be specially designated in PIU. This person will attend SEA/SH grievance redress trainings for increasing capacity in PIU related with comprehensive addressing of SEA/SH issues.  Right to Appeal If the complainant is not satisfied with the response, one more attempt will be made to clarify the rationale for the proposed action by the GRM/ESF staff, Project Director and the investigating person/department and other relevant personnel may be involved in the appeals process. A final decision will be taken following the appeal meeting. If the response remains unsatisfactory to the complainant, he/she/they may resort to raising their grievances outside the project GRM system. 28 6.2 Awareness Building The information about the Grievance Redress Mechanism will be available at the Ministry of Education and Science website and will be included in the communications conducted with the project stakeholders, beneficiaries, project affected persons through the communications methods and tools that are part of this stakeholder engagement plan and communications plan under the project, including emails, website, workshops, and face-to-face meetings. The Ministry of Education and Science will notify university management, as well as local authorities (as applicable) of the GRM system and procedures. Specifically, the information will contain the objective of the GRM, the procedure to make a complaint (where, when and how), the investigation process, the timeframe(s) for responding to the complainant, as well as the principle of confidentiality and the right to make anonymous complaints. 6.3 Roles and Responsibilities for GRM The responsibilities for the management of the GRM system include the following and may be updated from time to time in consultation with the ministerial management team and the World Bank task teams. These functions can either be performed by assigned staff, e.g. ESF/GRM Officer or be outsourced to an outside contractor in case the MOES/PIU capacity to handle the workload is exceeded.  Overall management of the GRM system  Developing and maintaining awareness-building  Collection of complaints  Recording complaints  Notification to the complainant on the receipt and timeline to review a complaint  Sorting/categorization of complaints  Thorough review of the issues, including the causal link between project activities and alleged damage/harm/nuisance  Decision-making based on such examination  Processing appeals or continuous communication with complainants with the purpose to resolve issues amicably  Publishing responses to complaints, unless otherwise is requested by complainants due to privacy or other concerns (see above 4.2) Organization and implementation of information materials and awareness campaigns  Reporting and feedback on GRM results 6.4 Monitoring and Reporting on GRM Implementation Policies, procedures and regular updates on the GRM system will be made available on the Ministry of Education and Science website. The MOES/PIU will regularly track and monitor the status of complaints to ensure that all grievances are resolved within the established time-frame. The MOES/PIU will also provide and publish semi-annual reports available to the World Bank team, and all stakeholders that would contain the following information: 29  Status of establishment of the GRM (procedures, staffing, awareness building, etc.);  Quantitative data on the number of complaints received, the number that were relevant, and the number resolved;  Qualitative data on the type of complaints and answers provided, issues that are unresolved;  Time taken to resolve complaints;  Any issues faced with the procedures/staffing or use;  Factors that may be affecting the use of the GRM/beneficiary feedback system;  Any corrective measures suggested/adopted. 7. REFERENCES Draft Ukraine Improving Higher Education for Results Project – Project Appraisal Document (PAD) Ukraine Handbook on Transparency and Citizen Participation, Council of Europe, December 2017 The World Bank Environmental and Social Management Framework, The World Bank, 2017 ESS10 Guidance Notes, The World Bank, 2017 Ukraine Country Partnership Framework for the period FY17-21 Review of the Education Sector in Ukraine: Moving towards Effectiveness, Equity and Efficiency, World, Bank, 2019 A guide to WHO’s guidance on COVID-19 30 8. ANNEX A – GRIEVANCE/INQUIRY RECORD GRIEVANCE/INQUIRY RECORD (Form A) Instructions: This form is to be completed by staff receiving the inquiry or grievance and kept in the Project’s file. Attach any supporting documentation/letters as relevant. Date Grievance Received: Name of Staff Completing Form: Grievance Received (check √): □ National □ Oblast □ Rayon □ City/Village □ Amalgamated hromada Mode of Filing Inquiry or Grievance (check √): □ In person □ Telephone □ E-mail □ Phone Text Message □ Website □ Grievance/Suggestion box □ Community meeting □ Public consultation □ Other ______________ Name of Person Raising Grievance: (information is optional and always treated as confidential) Gender: □ Male □ Female Address or contact information for Person Raising Grievance: (information is optional and confidential) Location where grievance/problem occurred [write in] National: Oblast: Rayon: Village: Amalgamated hromada Brief Description of Grievance or Inquiry: (Provide as much detail and facts as possible) Category 1 Social Safeguards Category 2 Environmental Safeguards Category 3 Grievances regarding violations of policies, guidelines and procedures Category 4 Grievances regarding contract violations Category 5 Grievances regarding the misuse of funds/lack of transparency, or other financial management concerns Category 6 Grievances regarding abuse of power/intervention by project or government officials Category 7 Grievances regarding MOES staff performance Category 8 Reports of force majeure Category 9 Grievance about project interventions Category 10 Other Who should handle and follow up on the grievance: Progress in resolving the grievance (e.g. answered, being resolved, settled): 31