Environmental Protection Agency and Ministry of Lands and Natural Resources Ghana Landscape Restoration and Small-Scale Mining Project (P171933) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Appraisal Version October 12, 2024 1 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Ghana (the Recipient) is implementing the Ghana Landscape Restoration and Small-Scale Mining Project (the Project), with the involvement of the Environmental Protection Agency (EPA) under the Ministry of Environment, Science, Technology and Innovation (MESTI) and the Ministry of Lands and Natural Resources (MLNR), as set out in the Original and Additional Financing Agreements (the Agreements). The International Development Association (the Association), also acting as the administrator of the Global Environment Facility (GEF), has agreed to provide the original financing and additional financing for the Project and the Additional Financing (AF) activities, as set out in Agreements. This ESCP supersedes previous versions of the ESCP for the Project and shall apply both to the original and the additional financing for the Project referred to above. 2. The Recipient shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Association]. The ESCP is a part of the Agreements. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the Agreements. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Recipient shall carry out or cause to be carried out, including, as applicable, their respective timeframes; institutional, staffing, training, monitoring and reporting arrangements; and grievance management. The ESCP also sets out the environmental and social (E&S) documents that shall be prepared or updated, consulted, disclosed and implemented under the Project, consistent with the ESSs, in form and substance acceptable to the Association]. Said E&S documents may be revised from time to time with prior written agreement by the Association. As provided for under the referred Agreements, the Recipient shall ensure that there are sufficient funds available to cover the costs of implementing the ESCP. 4. As agreed by the Association and the Recipient, this ESCP will be revised from time to time, if necessary, to reflect adaptive management of Project changes or unforeseen circumstances or in response to Project performance. In such circumstances, the Association and the Recipient agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient ’s Representative specified in the Agreements. The Recipient shall promptly disclose the updated ESCP. 5. The subsection on “Indicators for Implementation Readiness� below identifies the actions and measures to be monitored to assess Project readiness to begin implementation in accordance with this ESCP. Nevertheless, all actions and measures in this ESCP shall be implemented as set out in the “Timeframe� column below irrespective of whether they are listed in the referred subsection. 2 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY IMPLEMENTATION ARRANGEMENTS AND CAPACITY SUPPORT A ORGANIZATIONAL STRUCTURE a. The established PCUs at EPA and MLNR shall use their resources and qualified staff a. The established PCU and EPA and MLNR who are already at post respectively, to support management of environmental and social these positions shall be PCUs and (E&S), health and safety risks and impacts of the Project, including an Environmental and maintained throughout Project Implementing Social Specialist and a Gender Specialist at the EPA PCU; and an Environmental implementation. Agencies Specialist and a Social and Gender Specialist at the MLNR PCU. b. The appointed Project Coordinators at EPA and MLNR who respectively serve as administrative heads shall continue to oversee the implementation of the E&S instruments. b. The Regional and District Level Environmental and Social Focal c. The Project shall continue to use the appointed Regional and District Level E&S Focal Points and Personnel who have Points to support the management of E&S risks. been appointed by implementing agencies to support E&S d. Existing collaboration arrangements with the Ministry of Food and Agriculture (MoFA); management shall be maintained Forest Services Division (FSD) and Wildlife Division (WD) of the Forestry Commission throughout the project (FC); Ghana Cocoa Board (COCOBOD); Minerals Commission (MC); Ghana Geological implementation. Survey Authority (GGSA); Lands Commission (LC); Ghana Extractive Industry Transparency Initiative (GHEITI); and Precious Minerals Marketing Company (PMMC) shall continue to be used to manage E&S risks and impacts of the Project. B CAPACITY BUILDING PLAN/MEASURES Continue to provide capacity building for relevant Project Staff, regional and district level Throughout Project EPA and MLNR implementing agencies’ staff, contract workers, communities etc.: implementation PCUs, and • Project Management (scope, implementation, monitoring and Reporting) Contractors • World Bank Environmental and Social Framework and Standards • National Environmental Requirements • Sub-project Screening and Scoping • Grievance Redress Mechanism • Community health and safety • Occupational Health and Safety • Environmental and Social Report preparation and other reporting requirements • GBV/SEA risk management and child rights protection • Gender and Disability inclusion • Information on World Bank’s Safeguards Incidents Reporting Tool (ESIRT) provided. • Emergency preparedness and response MONITORING AND REPORTING 3 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY C REGULAR REPORTING Prepare and submit to the Association regular monitoring reports on the environmental, Submit quarterly reports to the EPA and MLNR social, health and safety (E&S) performance of the Project. The reports shall include: Association throughout Project PCUs implementation. Submit each • Status of preparation and implementation of E&S documents required under the report to the Association no later ESCP, including the LMP, Child Labor prevention protocols and the Gender and than 15 days after the end of GBV/SEA/SH Action Plan. each reporting period. • Summary of stakeholder engagement activities carried out as per the Stakeholder Engagement Plan. • Complaints submitted to the grievance mechanism(s), the grievance log, and progress made in resolving them. • E&S performance of contractors and subcontractors as reported through monthly contractors’ and supervision firms’ reports. • Number and status of resolution of incidents and accidents reported under action E below. D CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports to the Contractors, through Require contractors and supervising firms to provide monthly monitoring reports on E&S Association as annexes to the EPA and MLNR performance in accordance with the metrics specified in the respective bidding documents reports to be submitted under PCUs and contracts and submit such reports to the Association. action C above. E INCIDENTS AND ACCIDENTS Notify the Association of any incident or accident relating to the project which has, or is Notify the Association no later Contractors and likely to have, a significant adverse effect on the environment, the affected communities, than 24 hours after learning of the implementing the public or workers, including those resulting in death or significant injury to workers or incident or accident; Provide agencies through the public; acts of violence, discrimination or protest; unforeseen impacts to cultural available details upon request. EPA and MLNR heritage or biodiversity resources; pollution of the environment; dam failure; forced or child PCUs labor; displacement without due process (forced eviction); allegations of sexual exploitation or abuse (SEA), or sexual harassment (SH); or disease outbreaks. Provide available details of the incident or accident to the Association upon request. Provide review report and Corrective Action Plan to the Arrange for an appropriate review of the incident or accident to establish its immediate, Association no later than 10 days underlying and root causes. Prepare, agree with the Association, and implement a following the submission of the Corrective Action Plan that sets out the measures and actions to be taken to address the initial notice, unless a different incident or accident and prevent its recurrence. timeframe is agreed to in writing by the Association. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ENVIRONMENTAL AND SOCIAL ASSESSMENTS AND/OR PLANS 4 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1. Adopt and implement site-specific Environmental and Social Impact Assessments 1. Adopt relevant ESIAs and EPA, MLNR PCUs, (ESIAs), and corresponding Environmental and Social Management Plans (ESMPs) for ESMPs prior to commencement and implementing part of the Project and AF for which the ESIAs/ESMPs are required, consistent with the of works, and thereafter agencies. relevant ESSs. implement the ESIAs and ESMPs throughout Project implementation. 2. Using the E&S screening tools, the Project (and the AF) will identify the potential risks of 2. Throughout Project activities, including potential Sexual Exploitation and Abuse (SEA)/ Sexual Harassment implementation. Once prepared (SH) risks, and thereafter, prepare, adopt, and implement mitigation plans, i.e., and approved, tools and Environmental and Social Impact Assessments (ESIAs) and Environmental and Social instruments apply throughout Management Plans (ESMPs); Resettlement Action Plan (RAP); Biodiversity Management Project implementation. Plans (BMPs) and other instruments as required, in a manner acceptable to the Association. 3. Update the ESMF prior to Appraisal of the AF, and 3. Update the Project’s Environmental and Social Management Framework (ESMF) to thereafter implement the ESMF include specific provisions occasioned by the AF, and implement the updated ESMF for throughout Project the Project and the AF, consistent with the relevant ESSs. implementation. 4. Finalise the preparation of the Strategic Environmental and Social Assessment (SESA) 4. Hire a consultant to revise the to guide the Artisanal and Small-Scale Mining (ASM) sector reforms being proposed under draft SESA based on the the project and inform interventions on revising ASM policies and regulations. Association’s review comments, prior to the mid-term review of the Project. MLNR PCU 5. Require EPA, MLNR and relevant implementing agencies to adopt and implement site- 5. Adopt the ESMP and specific Environmental and Social Impact Assessments (ESIAs) and Environmental and incorporate the ESMP as part of Social Management Plans (ESMPs), as set out in the ESMF. The proposed activities the respective bidding documents described in the exclusion list set out in the ESMF shall be ineligible to receive financing for the respective Project under the Project. activities that require the adoption of such ESMP. Once adopted, implement the respective ESMP throughout Project implementation 1.2 MANAGEMENT OF CONTRACTORS As part of the preparation of EPA and MLNR procurement documents and PCUs respective contracts. 5 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Incorporate the relevant aspects of the ESCP, including, inter alia, relevant E&S Supervise contractors throughout assessments or plans, the Labor Management Procedures, and code of conduct, into the Project implementation. Copies of E&S specifications of the procurement documents and contracts with contractors and relevant contracts provided to the supervising firms. Thereafter ensure that the contractors and supervising firms comply and Association] upon request. that they require their subcontractors to comply with the E&S specifications of their respective contracts. Provide copies of the relevant contracts with contractors/subcontractors and supervision firms to the Association]. 1.3 TECHNICAL ASSISTANCE Not applicable to the Project and AF 1.4 CONTINGENT [EMERGENCY] [EARLY] RESPONSE FINANCING Not applicable to the Project and AF 1.5 ASSOCIATED FACILITIES Not applicable to the Project and AF 1.6 USE OF [BORROWER/RECIPIENT’S] ENVIRONMENTAL AND SOCIAL FRAMEWORK Not applicable to the Project and AF 1.7 COMMON APPROACH Not applicable to the Project and AF 1.8 ACTIVITIES SUBJECT TO RETROACTIVE FINANCING Not applicable to the Project and AF ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES The Labor Management Procedures (LMP) for the Project, as part of the Project’s ESMF, Update the LMP as part of the EPA and MLNR shall be updated to include additional provisions occasioned by the AF, and shall be ESMF prior to Appraisal of the PCUs adopted and implemented for the Project and AF, including, inter alia, provisions on AF, and thereafter implement the working conditions, management of workers relationships, occupational health and safety LMP throughout Project (including personal protective equipment, and emergency preparedness and response), implementation. code of conduct (including relating to SEA and SH), forced labor, child labor, grievance arrangements for Project workers, and applicable requirements for contractors, subcontractors, and supervising firms. Contractors shall be required to prepare and implement site specific Labor Management Prior to undertaking of civil works Contractors/ EPA and Plans. MLNR PCUs 2.2 OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT PLAN Prepare the OHS Management Plan prior to commencement of Require contractors and subcontractors to prepare and implement OHS Management civil works, and thereafter Contractors through Measures or Plan in accordance with the updated ESMF. implement the plan throughout EPA and MLNR Project implementation. PCUs. 6 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 2.3 GRIEVANCE MECHANISM FOR PROJECT WORKERS Grievance Redress Mechanisms for Project staff have been established at both the EPA Throughout Project EPA and MLNR and MLNR PCUs respectively, and are operating as described in the LMP and consistent implementation]. PCUs with ESS2. These workers GRMs will continue to operate under the AF. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Adopt and implement Waste Management Plans (WMPs), as part of the relevant ESMPs Adopt and implement the WMPs EPA and MLNR prepared for sub-projects under the parent Project, as well as ESMPs to be prepared for prior to commencement of any PCUs sub-projects under the AF, to manage hazardous and non-hazardous wastes, consistent activities which will generate with ESS3. hazardous and non-hazardous wastes, and thereafter implement Include in all contractor contracts, requirements for proper disposal of all liquid and solid the WMPs throughout Project waste (including plastic trash) and construction waste, sanitation management, including implementation. management of any associated dust emission, and management of potential pollution of water sources, noise impacts during construction and operation of sub-projects under the Prior to signing contractor Project and AF, as specified in the ESMF contracts 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Resource efficiency and pollution prevention and management measures have been Same timeframe as for the EPA and MLNR incorporated in the ESMPs to be adopted under action 1.1 above. preparation, adoption and PCUs implementation of the ESMPs. In respect of the AF, incorporate resource efficiency and pollution prevention and management measures in ESMPs to be prepared under action 1.1 above. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY Same timeframe as for the EPA and MLNR Measures to manage traffic and road safety risks have been incorporated in the ESMPs to preparation, adoption and PCUs be adopted under action 1.1 above. implementation of the ESMPs. In respect of the AF, incorporate measures to manage traffic and road safety risks in ESMPs to be prepared under action 1.1 above. 4.2 COMMUNITY HEALTH AND SAFETY Assess and manage specific risks and impacts to the community arising from the AF Same timeframe as for the EPA and MLNR activities, including, inter alia, behavior of Project workers, risks of labor influx, response to preparation and implementation PCUs emergency situations, and include mitigation measures in the ESMPs to be prepared in of the ESMPs. accordance with the ESMF. 7 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Continue to manage specific risks and impacts to communities arising from Project activities, including, inter alia, behavior of Project workers, risks of labor influx, response to emergency situations, and continue to implement mitigation measures in the ESMPs prepared in accordance with the ESMF. 4.3 SEA AND SH RISKS Update the Gender and SEA/SH EPA and MLNR Action Plan prior to Appraisal of PCUs Update the Project’s Gender and SEA/SH Action Plan to include specific provisions the AF, and thereafter implement occasioned by the AF, and thereafter, adopt and implement the updated Gender and the Gender and SEA/SH Action SEA/SH as part of relevant ESMPs to assess and manage the risks of SEA and SH under Plan throughout Project the Project and AF. implementation. 4.4 SECURITY MANAGEMENT The Project and AF activities will not include the engagement of security personnel. 4.5 DAM SAFETY (FOR ANNEX A ESS4) The Project and AF will not include the creation of a dam. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT [FRAMEWORK] [PLAN] or [PLANS] 1. Adopt the RPF and PF prior to start of referenced Project and AF 1. Adopt and implement the Resettlement Policy Framework (RPF) and Process activity planning, and thereafter EPA and MLNR Framework (PF) prepared for the Project, consistent with ESS5. The RPF and PF implement the RPF and PF PCUs adequately covers activities under the AF. throughout Project implementation. 2. Prepare and implement a Resettlement Plan (RP) or a Livelihood Restoration Plan 2. Prepare and implement the (LRP) for each activity under the Project and the AF that occasions restrictions in access to respective RP or LRP prior to protected areas, and for which RP or LRP is required, as set out in the RPF & PF and carrying out the relevant works, consistent with ESS5. including ensuring that before taking possession of the land and related assets, full compensation has been provided and as applicable, all displaced people have been resettled and moving 3. Conduct a social conflict assessment of Sefwi-Wiawso, one of the new project areas allowances have been provided. under the AF, to understand how the proposed rehabilitation of moribund cocoa farms under the AF could heighten latent tensions between tenant farmers and chiefs regarding 3. Conduct social conflict ownership rights of the lands dedicated to cocoa cultivation by the tenant farmers. assessment prior to Board approval of the AF. 8 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS Screen Project activities (including civil works) to avoid any significant loss or degradation Prepare BMPs prior to EPA and MLNR of natural habitats and to avoid damaging any protected areas or critical habitats, in commencement of project PCUs accordance with the Project ESMF to be updated. activities that may pose significant risks and have adverse If need for Biodiversity Management Plans (BMP) is determined through the screening impact on biodiversity, and process where significant risks and adverse impacts on biodiversity have been identified, thereafter implement the BMPs the Project and AF will prepare, adopt and implement the plans as part of the site specific throughout Project ESMPs. implementation. Ensure that Forest and Protected Area Management Plans prepared under the Project and the AF adequately incorporate biodiversity considerations, consistent with the provisions of ESS6. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES 7.1 INDIGENOUS PEOPLES [FRAMEWORK] [PLAN] or [PLANS] Not relevant since there are no known Indigenous People in Ghana ESS 8: CULTURAL HERITAGE 8.1 CULTURAL HERITAGE RISKS AND IMPACTS Prepare and adopt relevant EPA and MLNR CHMPs prior to commencement PCUs. Prepare and implement Cultural Heritage Management Plans (CHMPs), if required as part of any activities that would have of an ESIA/ ESMP under the Project or AF, consistent with ESS8. significant impact on cultural, and thereafter implement the CHMP throughout Project implementation. 8.2 CHANCE FINDS The chance-find procedures have EPA and MLNR Describe and implement the chance finds procedures, as part of the ESMF for the Project. already been described in the PCUs. ESMF. Implement the procedures throughout Project The procedures will also be included in relevant procurement and contract documents for implementation. contractors to ensure implementation. Prior to signing contractor contracts, and thereafter ESS 9: FINANCIAL INTERMEDIARIES [This standard is only relevant for Projects involving Financial Intermediaries (FIs).] 9.1 ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEM (ESMS) This standard is not relevant since neither the Project nor the AF involves FIs. ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN 9 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Update and implement the Stakeholder Engagement Plan (SEP) for the Project, consistent Update the SEP prior to Appraisal EPA and MLNR with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, of the AF, and thereafter PCUs relevant, understandable and accessible information, and consult with them in a culturally implement the SEP throughout appropriate manner, which is free of manipulation, interference, coercion, discrimination Project implementation. and intimidation. The update of the SEP shall include new stakeholders and additional engagements relevant to the AF. 10.2 PROJECT GRIEVANCE MECHANISM Accessible grievance mechanisms (GMs) have been established, publicized, maintained, GMs established under the EPA and MLNR and being operated in all project areas. Under the AF, similar GMs this will be established, parent Project shall continue to PCUs publicized maintained, and operated in the new areas, to receive and facilitate resolution of be maintained. In the new areas concerns and grievances in relation to the Project and the AF, promptly and effectively, in under the AF, GMs will be a transparent manner that is culturally appropriate and readily accessible to all Project- established prior to start of affected parties, at no cost and without retribution, including concerns and grievances filed implementation of activities, and anonymously, in a manner consistent with ESS10. thereafter maintain and operate The existing grievance mechanisms under the Project are equipped to receive, register, the mechanism throughout and facilitate the resolution of GBV/SEA/SH complaints, including through the referral of Project implementation. survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. Similarly, GMs to be established under the AF shall be equipped with GBV/SEA/SH referral pathways. INDICATORS FOR IMPLEMENTATION READINESS The following actions are indicators for implementation readiness: These will include actions related to: (1) Update of required instruments such as the ESMF, SEP, Gender and SEA/SH Action Plan, etc., (2) Identification and engagement with new stakeholders relevant to the AF, and (3) Appointment of regional and district E&S focal points in new areas, by relevant implementing agencies. 10