Islamic Republic of Pakistan Punjab Clean Air Program: P508222 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Negotiated Version DRAFT February 28, 2025 1 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. Government of the Punjab will implement the Punjab Clean Air Program - IPF Component (the Project), with the involvement of the Planning & Development Board (P&D), Environmental Protection & Climate Change Department (EP&CCD), Transport & Masstransit Department (T&MD), Industries, Commerce & Investment Department and Agriculture Department. The International Development Association (the Association), has agreed to provide financing for the Project, as set out in the Financing Agreement (Agreement). 2. The Implementing Entity (IE) 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 Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the Agreement. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the IE 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 Agreement, the IE shall ensure that there are sufficient funds available to cover the costs of implementing the ESCP. 4. As agreed by the Association and the IE, 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 IE agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the IE’s Representative specified in the IE Agreement. The IE 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 1 A ORGANIZATIONAL STRUCTURE a. Establish and maintain an Environmental and Social Management team within the Program a. Hire or appoint an environment PCAP-CMU,P&D and Coordination & Monitoring Unit (PCAP-CMU) at P&D and Program Implementation Unit (PIU) at specialist and a social and gender PIU T&MD T&MD with qualified staff and resources to support management of environmental, social, health specialist to the PCAP-CMU and and safety (E&S) risks and impacts of the Project including Environment Specialist and PIU (total two positions each) no Secretaries of Social/Gender Specialist. later than sixty (60) days after the Environmental & Effective Date of the Loan Climate Change Agreement and maintain these Department, positions throughout Project Industries, Commerce implementation. & Investment b. Nominate E&S focal points at Department, b. Nominate E&S focal points at other agencies responsible for Project activities including, other agencies no later than sixty Agriculture Environmental & Climate Change Department, Commerce & Investment Department, , Punjab (60) days after the Effective Date Department, and Mass Transit Authority, and Punjab Transport Company. of the Loan Agreement T&MD (for Punjab Mass Transit Authority, and Punjab Transport Company) B Prepare and implement the following capacity building measures: At the start of project PCAP-CMU, P&D and a. Training for relevant PCAP-CMU, PIU and other agencies staff on: implementation and annual PIU, T&MD • World Association ESF policy refreshers. • Stakeholder engagement and grievance mechanism (GM), including GM for Sexual Exploitation and Abuse/Sexual Harassment (SEA/SH) • Gender Based Violence (GBV)/SEA/SH • Labor Management Procedures • Community and occupational health and safety aspects especially related to T&MD activities • E-waste management • Battery waste management • E&S Screening MONITORING AND REPORTING C REGULAR REPORTING Prepare and submit to the Association regular monitoring reports on the environmental, social, PCAP-CMU, P&D in health and safety (E&S) performance of the Project. The reports shall include: coordination with concerned • Status of preparation and implementation of E&S documents required under the ESCP. departments 1 For all actions, consult with the country lawyer to ensure consistency with the legal agreement in cases where some actions need to be completed before the project becomes effective (effectiveness condition) or before certain disbursements can occur (disbursement condition). 3 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY • Summary of stakeholder engagement activities carried out as per the Stakeholder Engagement Submit bi-annual reports to the Plan. Association throughout Project • Complaints submitted to the grievance mechanism(s), the grievance log, and progress made in implementation, commencing after resolving them. the Effective Date. Submit each • Number and status of resolution of incidents and accidents reported. report to the Association no later than 15 days after the end of each reporting period. D INCIDENTS AND ACCIDENTS Notify the Association of any incident or accident relating to the project which has, or is likely to have, Notify the Association no later than PCAP-CMU, P&D in a significant adverse effect on the environment, the affected communities, the public or workers, 48 hours after learning of the coordination with including those resulting in death or significant injury to workers or the public; acts of violence, incident or accident. Provide concerned discrimination or protest; unforeseen impacts to cultural heritage or biodiversity resources; pollution available details upon request. departments of the environment; forced or child labor; displacement without due process (forced eviction); allegations of SEA, or SH; or disease outbreaks. Provide available details of the incident or accident Provide review report and to the Association upon request. Corrective Action Plan to the Association no later than 10 days Arrange for an appropriate review of the incident or accident to establish its immediate, underlying following the submission of the and root causes. Prepare, agree with the Association, and implement a Corrective Action Plan that initial notice, unless a different sets out the measures and actions to be taken to address the incident or accident and prevent its timeframe is agreed to in writing by recurrence. the Association. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 TECHNICAL ASSISTANCE Carry out the technical assistance and assessments required to facilitate Program implementation Throughout Project PCAP-CMU, P&D, PMA, including design interventions to support air quality improvements in accordance with terms of implementation PPTA and PIU, T&MD reference acceptable to the Association, that are consistent with the ESSs. Thereafter prepare and finalize the outputs of such activities in compliance with the terms of reference. The TA will include assessments on i) Buyback scheme; ii) Battery waste management; iii) E-bus Business Models study ; iv) Electric two- and three-wheeler adoption; v) Carbon credits (Transport); vi) Transport surveys and public perception studies; vii) Industrial detailed study; and any other studies conducted during the life of the project. 1.2 USE OF BORROWER ENVIRONMENTAL AND SOCIAL FRAMEWORK a. Ensure that the E&S risks and impacts of the Project, are managed in accordance with this ESCP a. Throughout Project PCAP-CMU, P&D and and the Borrower’s E&S Framework, which includes, inter alia, the national and provincial implementation. PIU, T&MD relevant policy, legal and institutional framework, including national, departmental, or local implementing institutions and applicable laws, regulations, procedures, and implementation capacity. 4 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY b. Promptly notify the Association of any changes to the Borrower’s E&S Framework that may b. Notify the Association materially adversely affect the Borrower’s ability to manage the E&S risks and impacts of the immediately after taking notice Project in line with the ESSs and the immediate measures taken or that are planned to be taken of the change to the Borrower’s to address said changes and ensuing potential risks and impacts of the Project. If, in the opinion E&S Framework. Subsequent of the Association, such changes adversely affect relevant ESHS risk management aspects of the actions, if requested by the Project, the Borrower shall agree to implement measures and actions to address them in a Association, shall reflect in an manner acceptable to the Association. The ESCP shall be updated to reflect such agreed actions. updated ESCP as indicated in paragraph 4 of the Initial Section of this ESCP. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Ensure that Project workers are engaged in the implementation of the Project in accordance with Measures to be put in place no later PCAP-CMU, P&D PIU, ESS2. To this end, implement the following measures: than ninety (90) days after Project T&MD Effectiveness, and thereafter ensure a) Provide direct and contracted workers with information and documentation that is clear and implementation throughout Project understandable regarding their terms and conditions of employment through written contracts implementation setting out their rights, including, inter alia, rights related to hours of work, wages, overtime, compensation, and benefits, as well as written notice of termination of employment, and details of severance payments, as applicable; b) Implement occupational health and safety (including emergency preparedness and response) measures, taking into account the General Environmental, Health and Safety Guidelines (EHSGs), and other Good International Practice (GIP), as relevant; c) Implement measures, as applicable, to, inter alia: (i) prevent the use of all forms of forced labor and child labor; (ii) enable workers to benefit from, inter alia, access to grievance mechanisms without fear of retaliation; and (iii) provide effective freedom to form and join workers organizations or alternative mechanisms for expressing their concerns and protect their rights related to labor and working conditions; d) Develop a code of conduct for workers, which shall include measures to prevent and respond to sexual exploitation and abuse, and sexual harassment (SEA/SH) cases; and e) Incorporate the relevant requirements above in the E&S specifications of the procurement documents and contracts with third parties that engage contracted workers in the implementation of the studies. 5 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS Ensure access to a grievance PCAP-CMU, P&D and mechanism within 90 days of PIU, T&MD Ensure access to a grievance mechanism for all project workers. Project Effectiveness and thereafter maintain and operate it throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN i. Adopt E-Waste Management Standard Operating Procedures (SOPs) within IAs. i. Within 6 months of projecti. SOP to be provided commencement. by EP&CCD and implementation enabled by PCAP- ii. Include environmentally safe disposal options for solid waste, e-waste and battery waste in the CMU, P&D studies conducted under TA (as mentioned in section 1.1 above) where relevant, consistent ii. At the time of finalization of ii. PCAP-CMU, P&D with ESS3. each relevant study and PIU, T&MD 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT TORs of all relevant TAs will be screened to ensure ESS3 requirements, including resource efficiency At the time of finalizing the TORs PCAP-CMU, P&D and and pollution prevention and mitigation, are taken into consideration. PIU, T&MD ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 COMMUNITY HEALTH AND SAFETY TORs of all relevant TAs will be screened to ensure ESS4 requirements are taken into consideration. At the time of finalizing the TORs PCAP-CMU, P&D and PIU, T&MD 4.2 SEA AND SH RISKS TORs of all relevant TAs will be screened to ensure SEA and SH risks are taken into consideration. At the time of finalizing the TORs PCAP-CMU, P&D and PIU, T&MD Adopt and implement SEA/SH risk mitigation measures At the time of finalizing of the SEA/SH Action Plan (to be prepared under PforR) ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT – NOT CURRENTLY RELEVANT ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES – NOT CURRENTLY RELEVANT ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES – NOT CURRENTLY RELEVANT ESS 8: CULTURAL HERITAGE – NOT CURRENTLY RELEVANT ESS 9: FINANCIAL INTERMEDIARIES – NOT CURRENTLY RELEVANT ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 6 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 10.1 STAKEHOLDER ENGAGEMENT PLAN Update the SEP as needed no later Update as needed and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent than sixty (60) days from Project PCAP-CMU, P&D and with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, relevant, Effectiveness and thereafter PIU, T&MD understandable and accessible information, and consult with them in a culturally appropriate implement the SEP throughout manner, which is free of manipulation, interference, coercion, discrimination and intimidation. Project implementation. 10.2 PROJECT GRIEVANCE MECHANISM Adopt, publicize, maintain, and operate an accessible grievance mechanism building on existing Establish the grievance mechanism PCAP-CMU, P&D and mechanisms, to receive and facilitate resolution of concerns and grievances in relation to the no later than sixty (60) days from PIU, T&MD Project, promptly and effectively, in a transparent manner that is culturally appropriate and readily Project Effectiveness, and accessible to all Project-affected parties, at no cost and without retribution, including concerns and thereafter maintain and operate the grievances filed anonymously, in a manner consistent with ESS10. mechanism throughout Project implementation The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. INDICATORS FOR IMPLEMENTATION READINESS The following actions are indicators for implementation readiness: A. Establish E&S Management Teams no later than sixty (60) days from Project Effectiveness 2.1 Adopt Labor Management Measures no later than ninety (90) days from Project Effectiveness 10.1 Update as needed Stakeholder Engagement Plan (SEP) no later than sixty (60) days from Project Effectiveness 10.2 Establish the grievance mechanism no later than sixty (60) days from Project Effectiveness 7