FEDERAL REPUBLIC OF NIGERIA WORLD BANK PROGRAM-FOR-RESULTS FINANCING NIGERIA HOPE for QUALITY BASIC EDUCATION FOR ALL (HOPE-EDU) PROGRAM-FOR-RESULTS ENVIRONMENT AND SOCIAL SYSTEMS ASSESSMENT (ESSA) Final March 10, 2025 Prepared by the World Bank TABLE OF CONTENTS TABLE OF CONTENTS ....................................................................................................................1 LIST OF ACRONYMS ......................................................................................................................3 EXECUTIVE SUMMARY .................................................................................................................5 SECTION I: PROGRAM DESCRIPTION AND SCOPE......................................................................... 13 1.1 Introduction ............................................................................................................................ 13 1.2 Program Description................................................................................................................ 14 1.3 Program Implementation and Institutional Arrangements ............................................................. 16 1.4 Program Boundaries and Result areas ........................................................................................... 17 1.5 Excluded Activities ........................................................................................................................ 21 1.6 Scope of the Environmental and Social Management System Assessment (ESSA) ........................... 22 1.7 Objectives of this ESSA ............................................................................................................ 24 1.8 Approach of ESSA ......................................................................................................................... 25 SECTION II: STAKEHOLDER CONSULTATION ................................................................................. 26 SECTION III: DESCRIPTION OF EXPECTED PROGRAM ENVIRONMENTAL AND SOCIAL IMPACTS ..... 28 3.1 Overview of Program Risks and Benefits ....................................................................................... 28 3.2 Expected Environmental Benefits .................................................................................................. 28 3.3 Expected Environmental Risks and Impacts .............................................................................. 28 3.4 Expected Social Benefits .......................................................................................................... 28 3.5 Social Risks and Impact............................................................................................................ 30 SECTION IV: OVERVIEW OF RELEVANT BORROWERS ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEMS ........................................................................................................... 32 4.1 The Constitution of the Federal Republic of Nigeria (1999) ............................................................. 32 4.2 Policies Relevant to the HOPE-Edu Program ............................................................................. 32 4.3 Relevant Nigerian National Laws ............................................................................................. 34 4.4 Relevant Nigerian National Environmental Regulations ............................................................ 36 4.5 Nigeria’s Institutional Framework ................................................................................................. 36 4.5.1 Nigeria’s Institutional Framework .......................................................................................................... 36 4.5.2 State Ministries Relevant to HOPE-Edu PforR......................................................................................... 37 4.6 Management of Land Acquisition in Nigeria ............................................................................. 37 4.7 Grievance Redress Mechanism ................................................................................................ 38 SECTION V: ASSESSMENT OF THE CLIENT’S ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEMS .................................................................................................................................... 39 5.1: Summary of Systems Assessment ................................................................................................. 40 Core Principle 1: General Principle of Environmental and Social Management ..................................... 40 Core Principle 2: Natural Habitats and Physical Cultural Resources ...................................................... 42 1 Core Principle 4: Land Acquisition ....................................................................................................... 45 SECTION VI: PROGRAM ACTION PLAN (PAP) AND RECOMMENDATIONS...................................... 50 6.1 Environmental Summary and Recommendations .................................................................... 50 6.2 Social Summary and Recommendations ........................................................................................ 50 SECTION VII. SUPPORTING ANNEXES AND REFERENCE DOCUMENTS ........................................... 53 Annex 1: Applicability of Core Environmental and Social Principles (CP) to the HOPE-Edu Program Result Area and Disbursement Linked Indicators (DLIs) .................................................................................. 53 Annex 2: Key Environmental & Social Risks and Benefits Associated with Program Activities ................ 57 Annex 3: Attendance at Stakeholder Consultation Held on December 5, 2024...................................... 66 2 LIST OF ACRONYMS ASC Annual School Census BLP Basic Literacy Program CST Coordination Support Team DLI Disbursement-Linked Indicator DLR Disbursement-Linked Result ECE Early Childhood Education E&S Environment and Social ENB Environment, Natural Resources and Blue Economy ESSA Environmental and Social Systems Assessment ESMP Environment and Social Management Plan FMEnv Federal Ministry of Environment FMFBNP Federal Ministry of Finance Budget and National Planning GBV Gender-Based Violence GDP Gross Domestic Product GoN Government of Nigeria GRM Grievance Redress Mechanism HCI Human Capital Index HOPE Human Capital Opportunities for Prosperity and Equality ICT Information Communications Technology IDPs Internal Displaced Persons IPF Investment Project Financing ISR Implementation Status and Results Report JONAPWD Joint National Association of Persons with Disabilities LGA Local Government Area LGEA Local Government Education Authority MDA Ministries, Departments and Agencies MICS Multiple Indicator Cluster Survey NCT National Coordination Team NERDC National Education Research and Development Council NFLC Non-Formal Learning Centres NGF Nigeria Governor’s Forum NIN National Identification Number NPMT National Policy and Monitoring Team OOSC Out-of-School Children PAP Program Action Plan PCU Program Coordinating Unit PDO Program Development Objective PforR Program-For-Results PLP Post Literacy Program RA Result Area RANA Reading and Numeracy Activity SABER State Action and Business Enabling Reforms SAME State Agency for Mass Education SFTAS State Fiscal Transparency Accountability and Sustainability SMEnv State Ministry of Environment SMoF State Ministry of Finance SPP Structured Pedagogy Program 3 SUBEB State Universal Basic Education Board TA Technical Assistance TaRL Teaching at the Right Level TLM Teaching and Learning Material TSO Teacher Support Officer UBE Universal Basic Education UBEC Universal Basic Education Commission 4 EXECUTIVE SUMMARY 1. Nigeria’s human development outcomes are among the lowest in the world. Nigeria’s human capital index (HCI), according to the World Bank's Human Capital Index (HCI), is 0.36, positioning it substantially below the average for Sub-Saharan Africa (0.40) and lower-middle- income countries worldwide (0.48). Nigeria’s HCI of 0.36 implies that a child born in Nigeria can be expected to achieve only 36 percent of her or his potential productivity if current levels education services remain unchanged. In education, a child who starts school at age four can expect to complete 10.2 years of school by her 18th birthday; but if one factors in what is actually learned, the expected years of school are only five. 2. In addition, Nigeria has the world’s largest population of out-of-school children (OOSC). Children who attend non-formal education only or do not attend any form of education are both categorized as being out-of-school. Of the estimated 60.3 million children aged 5-14 years, there are an estimated 14.8 million OOSC (or 27 percent). Importantly, an estimated 45.8 million children aged 5-14 years are unable to read and understand a simple text even as the quality of teaching is poor. At the pre-primary level, only 28 percent of students have access to instructional materials for English studies, and 24 percent for mathematics. 3. Majority of Children with disabilities are OOSC in Nigeria. Studies have revealed that up to 3.5 million children with disabilities are currently out-of-school, while a study done by the Joint National Association of Persons with Disabilities (JONAPWD) indicated that 95 per cent of children with disabilities are out of school. They are often neglected, and there are no deliberate approaches to integrate them into development programs. 4. To deal with these problems and more under basic education in Nigeria, the World Bank is proposing to support the Government of Nigeria (GoN) with a Program for Results (PforR) instrument referred to as Nigeria Human Capital Opportunities for Prosperity and Equality Program-For-Results (HOPE)- Quality Basic Education for All Program-For-Results (HOPE-Edu PforR) (hereafter, the Program). The proposed operation is a hybrid that will include a part allocated to technical assistance (TA), which uses an Investment Project Financing (IPF) instrument. The HOPE-Education operation will be financed by a World Bank IDA credit of US$500 million and a GPE grant of US$52.2 million. 5. The Program is expected to directly benefit 29 million children enrolled at public primary schools; 500,000 public primary teachers; and more than 65,000 public primary schools as well as their school-based management committees (SBMCs) who will cater to their students and teachers. Program beneficiaries will also include another 1.5 million children who will enroll in accelerated non-formal basic education program in 10,000 non-formal learning centers. In addition, the program will benefit government agencies at the federal, the state and the local governments through enhanced capacities to plan, implement and monitor basic education service delivery. 6. The Program Development Objectives are to improve foundational learning outcomes, increase access to basic education and to enhance education systems in participating States. The following PDO level indicators will measure the achievement of the result: a) Percentage of children in Grade 3 who are proficient in reading, disaggregated by gender 5 b) Percentage of children in Grade 3 who are proficient in mathematics, disaggregated by gender c) Number of out-of-school children aged 5-14 years who have been brought into a formal or non-formal literacy and numeracy program d) Number of states that digitally publish complete Annual School Census Database and Report on time. 7. The operation will be structured around three results areas: a) Improving quality : This area aims to ensure that foundational literacy and numeracy are taught to primary students using a Structured Pedagogy Program (SPP) in participating States. The SPP is a coherent package of four integrated elements, which together are designed to improve classroom instruction and subsequently student performance: (i) teaching-learning materials (TLMs); (ii) teacher capacities; (iii) teacher support; and (iv) action-oriented evaluation of learning. b) Increasing access : This area aims to increase access to, and enrollment in, primary education in participating States through the community-supported creation of new classrooms and learning opportunities in the public formal and non-formal sectors c) Enhancing key systems : This area aims to strengthen the allocation and management of UBEIF, school management, governance and accountability; and to generate information essential for system management. 8. There are eight DLIs as follows: a) DLI 1: Number of schools with sufficient TLMs for literacy and numeracy b) DLI 2: Number of primary teachers with improved structured pedagogy practices (SPP) c) DLI 3: Percentage of children proficient in literacy and numeracy DLI 4: Number of new primary classrooms created through community participation d) DLI5: Number of children who complete NFBE program. e) DLI 6: Percentage of core UBE funds managed at decentralized level. f) DLI 7: Percentage of public primary schools using annual school grant (ASG). g) DLI 8: Percentage of schools included in current-year Annual School Census (ASC) report. 9. The Program will exclude activities that do not meet the World Bank’s Policy on eligibility for PforR financing (September 2020). The borrower shall ensure that the Program excludes any activity that, in the opinion of the World Bank, is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented and/or requires significant land acquisition, displacement, and/or resettlement of affected people. Any Program activity that entails land acquisition, negative impact on natural habitat and cultural resources, public and worker’s health and safety will not be funded under the PforR without adequate environmental and social management. For example, the program will support the procurement of civil works, and materials only when an adequate e-waste management plan is in place of the bidding document and monitored and reported regularly. 10. The Environmental and Social Systems Assessment (ESSA) examines the extent to which the Federal and State Government’s existing environmental and social management systems operates within, an adequate legal and regulatory framework to guide environmental and social impact assessments, mitigation, management and monitoring at the PforR Program level. It assesses their consistence with the six ‘core principles’ of Program for Results Policy and recommends actions to address the gaps and to enhance performance during Program implementation. This ESSA incorporates recognized elements of good practice in environmental 6 and social assessment and management and thereafter defines measures to strengthen the system and recommends measures that will be integrated into the overall Program. The ESSA is undertaken to ensure consistency with six core principles and key planning elements of PforR ESSA. 11. The World Bank team prepared the ESSA through a combination of detailed reviews of existing program materials and available technical literature, including policies, regulations, guidelines and examples of due diligence and design documents, interviews and extensive consultations with government staff, non-governmental organizations, regulatory agencies, private sector organizations and sector experts associated with public revenue generation. 12. In line with the six core principles above, the relevant risks associated with the HOPE Program and within the proposed Result Areas (RAs) under the PforR covers environmental and social issues and include: a) Increased generation of e-waste due to the deployment of digital devices for recording observations by trained observers in DLI 2 and, digitization of school-based data collection and digital submission and publication of Annual School Census data in DLI8, which will involve the use of ICT systems. b) The procurement and delivery of civil works, equipment, and materials, including construction of twelve thousand new public primary classrooms in areas where there are no schools and the establishment or strengthening of Non-formal learning centers (NFLCs) to enable OOSC to complete a literacy and numeracy program through government-community partnerships arrangements in DLIs 4 could lead to negative environmental and social impacts associated with these activities, such as the generation of solid waste, noise, and air pollution. c) Potential exclusion of vulnerable groups, e.g. children with disabilities, those in conflict zones, nomadic households, internally displaced persons (IDPs), etc., where there are no targeted approaches to mainstream them into the educational system. d) Potential discrimination of vulnerable groups due to ethnic considerations and sexual abuse or harassment of children and women in the appointment and training of a qualified teacher in DLI 2, and DLI 4 and the hiring and training the instructors in Non-Formal Learning Centers (NFLC) in DLI 5. e) Conflicts and security risks could disrupt the Program implementation. Schools and teacher can be targeted by insurgents and bandits. f) Resistance by member of the community who may view the Program especially for girls, as conflicting with cultural beliefs. On the contrary exclusion of stakeholders can also lead to mistrust and resistance of the Program. g) The procurement and delivery of civil works, equipment, and materials could also impact workers’ health and safety. h) Creation of new public primary classrooms for schools and the establishment or strengthening of Non-formal learning centers (NFLCs) could result in land acquisition for building more classrooms. This could result in social risks associated with land acquisition. i) Potential risk of child abuse and child labor. 13. The overall environmental and social risks have been assessed and deemed to be Substantial. Although the program activities are not likely to require significant changes to the borrower’s 7 overall environmental and social systems, the program was generally assessed as substantial because of the procurement of civil works and material in DLI4 , possible community land acquisition for building of classrooms, e-waste as a result of the deployment of learning packages to teachers in the form of digital devices in DLI2, deployment of digital devices for recording observations by trained observers in DLI3 and, digitization of school-based data collection and transmission in DLI8 and the envisaged social risks associated with recruitment qualified teachers in DLI4 and DLI5. 14. The ESSA process includes stakeholder consultations and disclosure of the ESSA Report, in accordance with the World Bank Policy and Directive for Program for-Results Financing and Access to Information Policy. At present, the ESSA consultation process is embedded in the Program consultation process. 15. Some analysis was carried out to determine the range of environmental and social risks and benefits that are associated with the PforR program based on each of the DLIs. 16. The PforR program will deliver minimal direct environmental benefits. Environment benefits will accrue through the use of school-based management grants for cleaning and maintaining school premises as outlined in DLI7. 17. The HOPE-Edu PforR has some activities that are expected to impact the environment. The procurement of civil works, construction, rehabilitation, classroom expansion, and the establishment of classrooms by communities in DLI4 could significantly impact the environment. The procurement of civil works, construction, rehabilitation and classroom expansion is associated with significant direct and indirect environmental risks such as solid waste generation, noise, land degradation, air pollution and destruction of flora and fauna, which could lead to biodiversity loss. 18. The delivery of a foundational learning package and essential teaching-learning materials (TLMs) associated with DLI1 will involve printing textbooks, especially to facilitate literacy and numeracy. This will consume a large amount of paper, thus impacting forests and trees used to manufacture paper. The digitization of the learning packages could reduce this. 19. In addition, the deployment of learning packages to teachers in the form of digital devices, the deployment of digital devices for recording observations by trained observers, the digitization of school-based data collection and transmission, procurement of digital devices, and adoption of a standardized and automated reporting format associated with DLIs 1, 2, and 8 could result in the generation of e-waste. 20. Furthermore, the HOPE-Edu PforR has many social benefits that will result from achieving the DLIs. These benefits include increased school enrollment, enhanced literacy and numeracy among school children, reduced out-of-school children (OOSC), enhanced performance of pupils and students in basic education, enhanced economic development, and poverty reduction, especially among the most vulnerable. 8 21. Availability of essential teaching-learning materials (DLI1), and activities associated with enabling teachers to effectively teach foundational literacy and numeracy and ensuring fidelity of the structured pedagogy practices (DLI2), will result in significant social benefits. Activities which include the delivery of TLM, including accessible textbooks in literacy and numeracy and building of Grades 1-3 teacher capacity to effectively use the teaching-learning materials and apply the structured pedagogical approach for literacy and numeracy roach, including observation, feedback, and support to teachers as well as regular assessment of learning, enhancing literacy and numeracy programs in non-formal learning centres (NFLCs) and increased completion rate of pupils in these NFLCs and their advancement into formal education will result in increased enrollment in basic education, reduction in OOSC, improved literacy and numeracy, enhanced performance of pupils and students in basic education as will be manifested in their end of year results and other performance assessment measures. 22. Also, activities associated with increased access to primary education (DLI4) which include the construction of public primary classrooms and recruitment of qualified teachers for primary schools by communities and the establishment or strengthening of Non-formal learning centers (NFLCs) in DLI5 to enable OOSC to complete a literacy and numeracy program will enhance access to education by people without access to education, guarantee that qualified and competent teachers are available in primary schools in rural communities and at the NFLCs thus increasing enrollment of pupils in schools, reduction in OOSC, and improved literacy and numeracy of pupils in primary education and NFLCs. 23. The HOPE-Edu PforR is also associated with some social risks. The procurement of civil works, classroom construction, and expansion by communities in DLI4 and the establishment or strengthening of Non-formal learning centers (NFLCs) in DLI5 to enable OOSC to complete a literacy and numeracy program could potentially impact workers' health and safety for workers involved in rehabilitation works related to these DLIs. The workers may be exposed to pollution caused by dust and noise at the work site. There could also be an influx of workers to the communities where rehabilitation work will occur and child labor issues. This may affect the communities as there could be cases of sexual abuse and other vices, for example, drug abuse. Where the schools are not accessible for children and staff with disabilities, it may further create more exclusion. It is critical that the construction activities adhere to the National Accessibility Regulation1 that provides the standards to ensure public infrastructures are accessible for all, including Persons with Disabilities. 24. There could be potential exclusion of children with disabilities where they are no targeted approaches to include them into the program as beneficiaries or make the schools inclusive. Other vulnerable groups that may be potentially excluded include children in conflict zones, nomadic households IDPs, exclusions due to ethnic considerations, etc. Child labour may occur, as most OOSC are already engaged in various forms of labour. There could be potential issues of child abuse, SEA/SH on children and sexual abuse or harassment of women in the recruitment and hiring of qualified teachers and instructors at Non Formal Learning Centres (NFLC) associated with DLI5 and 6. In addition, although social conflict as envisaged by ESSA, especially regarding armed conflict, is not applicable, exclusion of vulnerable groups and discrimination along the 1 ncpwd.gov.ng/pdfs/44document.pdf 9 lines of ethnicity and religion in the recruitment and hiring of teachers can result in complaints, social unrest and demonstrations. 25. Following the identification of environmental and social risks, the E&S management system in place to manage the identified risks was assessed. The assessment was done using the following criteria: strengths of the system, or where it functions effectively and efficiently and is consistent with Bank Policy and Directive for Program-for-Results Financing; inconsistencies and gaps between the principles espoused in Bank Policy and Directive for Program-for-Results Financing and capacity constraints; actions to strengthen the existing system. Information from this analysis, identification of gaps and opportunities/actions, was used to inform the recommendations and Program Action Plan (PAP). 26. Given the environmental impact of this project, some recommendations are made as follows: a) Strengthening the E&S capacity under the project is needed. To facilitate this, E&S specialists should be recruited for the Program. b) E-waste waste management strategies must also be developed specifically for the program to facilitate their management. The requirements for e-waste management and EPRON should be included in the bidding document under HOPE-Edu PforR. c) Also, E&S management procedures and requirements should be included in the documents for the procurement of civil works, materials and school expansion. d) There is a need to develop an environmental management strategy or manual and OHS guidelines for schools. 27. Given the identified social issues and weaknesses in the federal system, the following recommendations are made: a) Ensure that the recruitment of teachers to reduce staffing gap and application of mechanisms to reduce absenteeism are carried out transparently to avoid ethnic or religious bias. Also, there is a need to ensure gender inclusion in the recruitment, deployment and management of teachers. b) Ensure a select number of teachers are trained on environmental management and safety in the school environment. c) Establish a robust grievance redress mechanism specific to the Program to ensure that complaints from different stakeholders are well addressed. d) Strengthen provisions regarding gender-based violence (GBV) prevention and response, including clear protocols for identifying, reporting, and addressing instances of GBV within the school environment. This will include reviewing and, where appropriate, updating the Code of Conduct for teaching and non-teaching staff in the education sector. e) Develop and implement guidelines to make school accessible for vulnerable children, including those with disabilities, nomadic, IDPs, and ethnic considerations. f) Implement a whole-school approach to make schools safer for learning. g) Develop a land donation protocol for donating community land to be used for the construction and classroom expansion. 28. Following the recommendations, the breakdown of actions to be included in the Program Action Plan (PAP) with indicative timeline, responsibility for implementation and indicators for measuring the completion of such actions are detailed in the Table 6.1 below. 10 Table 6.1: Program Action Plan (PAP) s/n Action Description Due Date Responsible Party Completion Measurement 1 Dedicate officials Prior to UBEC, National Inclusion of the listed responsible for Effectiveness Program Steering specialist in the team and ensuring E&S PAP Committee (NPSC), maintained throughout the implementation National Program Program implementation, and Coordinator (NPC), Training Module and National Deputy Implementation Support Program Coordinator Supervision Report of World (NDPC) Bank Task team 2 Hire qualified No later than 3 SUBEC, State Program Assist the E&S PAP Environmental and months after Steering Committee implementation official to Social Officers and effectiveness (SPSC), State Program execute the above provide capacity (will be Coordinator (SPC), responsibilities. building/system- reported during State Deputy Program strengthening the first mission Coordinator (SDPC) program to ISR) strengthen their skills 3 Develop e-waste Within one year UBEC, NPSC, NPC, E-waste and healthcare waste management of effectiveness NDPC, SUBEC, SPSC, management strategy strategies for or before the SPC, and SDPC document. managing e-waste first bidding result from the document for program equipment procurement, whichever is earlier. 4 Strengthen Within two SUBEC, State Program School management provisions on years of Steering Committee guidelines to include gender-based effectiveness (SPSC), State Program provisions on GBV prevention violence (GBV) Coordinator (SPC), and response prevention and State Deputy Program response in the Coordinator (SDPC), school management Ministry of Education, Code on Conduct is reviewed guidelines, including Teachers Training, and updated for GBV clear protocols for Civil Service prevention where necessary identifying, Commission and reporting, and Teaching Service addressing instances Commission, the of GBV within the Teachers Registration school environment. Council of Nigeria This will include (TRCN). reviewing and, where appropriate, updating the Code of Conduct for 11 s/n Action Description Due Date Responsible Party Completion Measurement education officers, teaching and non- teaching staff in the education sector. 5 Develop a GRM Within one year UBEC, NPSC, NPC, Copies of GRM outlining specific to the of effectiveness NDPC, SUBEC, SPSC, details of implementation Program SPC, and SDPC 6 Develop guidelines Within two UBEC, NPSC, NPC, Guidelines developed and and implement years of NDPC, SUBEC, SPSC, under implementation them to make effectiveness SPC, and SDPC school accessible for vulnerable children, including those with disabilities, nomadic, IDPs, and ethnic considerations. 7 Implement a whole- Within two UBEC, NPSC, NPC, Whole school approach school approach to years of NDPC, SUBEC, SPSC, guidelines developed and make schools safer effectiveness SPC, and SDPC under implementation for learning. 8 Develop a community Prior to SUBEC, SPSC, SPC, and Copies of land donation land donation Effectiveness SDPC protocol outlining details of protocol specifically implementation for the Program. 12 SECTION I: PROGRAM DESCRIPTION AND SCOPE 1.1 Introduction 1. Nigeria’s human development outcomes are among the lowest in the world. Nigeria’s human capital index (HCI), according to the World Bank's Human Capital Index (HCI), of is 0.36, positioning it substantially below the average for Sub-Saharan Africa (0.40) and lower-middle- income countries worldwide (0.48). Nigeria’s HCI of 0.36 implies that a child born in Nigeria can be expected to achieve only 36 percent of her or his potential productivity if current levels education services remain unchanged.2 In education, a child who starts school at age four can expect to complete 10.2 years of school by her 18th birthday; but if one factors in what is actually learned, the expected years of school are only five. 2. In addition, Nigeria has the world’s largest population of out-of-school children (OOSC). Children who attend non-formal education only or do not attend any form of education are both categorized as being out-of-school. Of the estimated 60.3 million children aged 5-14 years, there are an estimated 14.8 million OOSC (or 25 percent). In the primary school age range, of every four OOSC, one is a drop-out, one attends a non-formal Islamic school, and the remaining two have never attended any school at all.3 Non-formal education through Qur’anic schools is widespread in the Northern zones. The majority of Children with disabilities are OOSC in Nigeria. Studies have revealed that up to 3.5 million children with disabilities are currently out-of-school, while a study done by JONAPWD indicated that 95 per cent of children with disabilities are out of school. They are often neglected, and there are no deliberate approaches to integrate them into development programs. NLSS 2018-2019 finds that 44 per cent of girls with disabilities of primary school age were out of school.4 3. Also, an estimated 45.8 million children aged 5-14 years are unable to read and understand a simple text. This corresponds to an overall learning deprivation rate of 76 per cent, and is higher for boys (78) than for girls (74). The rate ranges from 47-64 per cent in the Southern zones to 82-93 per cent in the Northern zones; from 15 per cent in Lagos to 99 per cent in Jigawa. The primary school completion rate is 73.1 percent, and the junior secondary completion rate is 67.7 percent.5 Among students attending Grade 3, 22.5 percent and 21.5 percent demonstrate foundational (Grade Two level) reading and numeracy skills, respectively; the rates among students attending Grade 6 are 39.2 and 35.4 percent, respectively; and among students attending the final year of JSS are 71.1 and 60.2 percent, respectively. Only 3.5 percent of children aged 7-14 years who are not in school demonstrate foundational reading skills and 3.9 percent demonstrate foundational numeracy skills. Overall, only about 1 in 4 children aged 7-14 years demonstrate foundational literacy, and even among children who attend school in these age-corresponding grades, only 4 in 10 demonstrate foundational literacy.6 While the country 2 World Bank, 2022. Human Capital Index database. https://www.worldbank.org/en/publication/human-capital#Briefs 3 National Education Data Survey (NEDS) 2020. The net attendance rates for formal education reported here are somewhat higher than those reported in MICS 2021. 4 Nigeria National Bureau of Statistics. Living Standards Survey (NLSS) 2018/19. 5 MICS, 2021. The National Personnel Audit (NPA) 2002 estimates that the primary completion rate is 82.9 percent, and the junior secondary completion rate is 45.1 percent (p. 19). 6 The same Grade Two level questions were administered regardless of age, indicating that learning increases with the number of grades attended. Children ‘not in school’ includes those in non-formal education. 13 does not yet have official learning poverty figures, estimates using available data suggests that more than 75 percent of Nigerian children are unable to read and understand a simple text by age 10. The share is slightly higher for males when compared to females. 4. The quality of teaching is also poor. In public primary and JSS schools, the subject in which textbooks are the most available is mathematics, yet in all grades there is on average only one textbook for every five students.7 Visual teaching aids needed to support language learning are commonly unavailable.8 Besides, there is shortage of qualified teachers. The national average pupil-teacher ratio (PTR)for primary education is 49:1; and for JSS is 29:1. If one takes into account teacher qualifications at the primary level it is 98 (without one state having a ratio below 44:1); and at JSS, it is 75:1. 5. The national EMIS team has a minimal budget and can only issue guidance to states, who must finance data collection from limited resources. Several aid programmes have managed to provide assistance to improve the analysis of annual school census and out-of-school survey data, establishing a more reliable picture of where education investment should be prioritized. i In addition to the lack of adequate data for planning, several indicators have been identified as impediments to the education of learners with disabilities in Nigeria. These include lack of facilities and learning aids, including assistive technologies, due to their high cost; inadequate and unskilled human resources; an absence of legislation that guarantees inclusive education; inade-quate funding to meet the learning and teaching needs for children with disabilities; inadequate implementation of existing education policies; discriminatory attitudes; and a dearth of early identification and intervention programsii. 1.2 Program Description 6. To deal with these problems and more under basic education in Nigeria, the World Bank is proposing to support the Government of Nigeria (GoN) with a Program for Results (PforR) instrument referred to as Nigeria Human Capital Opportunities for Prosperity and Equality Program-For-Results (HOPE)- Quality Basic Education for All Program-For-Results (HOPE-Edu PforR) (hereafter, the Program). The proposed operation is a hybrid that will include a part allocated to technical assistance (TA), which uses an Investment Project Financing (IPF) instrument. The IDA and the GPE contributions to the HOPE-EDU PforR PEF will be US$473.66 million and US$46.09 million respectively. Together, the IDA/GPE financing of US$519.75 million for the PforR component is about 14.0 percent of the total program financing requirements estimated at US$3,722.63 million. When the IPF component financing of US$32.44 million – IDA US$26.34 million and GPE US$6.10 million - is included, the IDA/GPE contribution totals US$552.18 million, accounting for 14.7 percent of total financing requirement of US$3,755.06 million for the operation. 7. The Program is expected to directly benefit 29 million children enrolled at public primary schools; 500,000 public primary teachers; and more than 65,000 public primary schools as well as their school-based management committees (SBMCs) who will cater to their students and teachers. 7NPA 2022, pp. 273-278. 8 See e.g. American Institutes for Research, 2024. Early-grade literacy instruction in Edo. A review of the lesson plans and its implementation. Draft Report, p. 20. 14 Program beneficiaries will also include another 1.5 million children who will enroll in accelerated non-formal basic education program in 10,000 non-formal learning centers. In addition, the program will benefit government agencies at the federal, the state and the local governments through enhanced capacities to plan, implement and monitor basic education service delivery. 8. The Program Development Objectives are to improve foundational learning outcomes, increase access to basic education and to enhance education systems in participating States. The following PDO level indicators will measure the achievement of the result: a) Percentage of children in Grade 3 who are proficient in reading, disaggregated by gender b) Percentage of children in Grade 3 who are proficient in mathematics, disaggregated by gender c) Number of out-of-school children aged 5-14 years who have been brought into a formal or non-formal literacy and numeracy program d) Number of states that digitally publish complete Annual School Census Database and Report on time 9. The operation will be structured around three results areas: improving quality; increasing access; and enhancing key systems. There are 8 DLIs. The DLIs/DLRs proposed under the HOPE-EDU are captured in Table 1.1 below. Table 1.1: Summary Table of DLIs across three results-areas DLI DLR Results Area 1: Improving Quality 1: Number of schools with sufficient 1.0: TLMs quality-assured and needs-estimated, and track-trace system approved TLMs for literacy and numeracy 1.1: Primary schools have sufficient TLMs for literacy and numeracy 1.2: Textbooks usage guidelines approved 2: Number of primary teachers with 2.0: SPP training packages approved improved structured pedagogy 2.1: All primary teachers and mentors enabled to improve SPP practices (SPP) 2.2: All Grades 1-3 teachers regularly mentored on SPP 2.3: All primary teachers regularly mentored on SPP 2.4: Number of primary teachers with improved SPP 3: Percentage of children proficient in 3.0: Baseline percentages of children proficient in literacy and numeracy established literacy and numeracy 3.1: Learning evaluation mechanisms for Grades 1-2 literacy and numeracy approved 3.2: Number of LGEAs acting on early learning evaluations 3.3: Number of LGEAs acting on early learning evaluations 3.4: Increased percentage of children proficient in literacy and numeracy Results Area 2: Increasing Access 4.1: Government-community agreements signed to create new classrooms 15 DLI DLR 4: Number of new primary classrooms 4.2: 13,000 new classrooms created created through community participation 5: Number of children who complete 5.1: 10,000 NFLCs have Management Committee, teacher, and TLMs NFBE program 5.2: 1,500,000 children complete NFBE program Results Area 3: Enhancing Key Systems 6: Percentage of core UBE funds 6.1: Increased number of states accessing UBE matching funds managed at decentralized level 6.2: 50% of core UBE funds de-centrally managed 6.3: 80% of core UBE funds de-centrally managed 7: Percentage of public primary schools 7.1: ASG amount and management regulations approved using annual school grant (ASG) 7.2: 70 percent of public primary schools use ASG 7.3: 80 percent of public primary schools use ASG 7.4: 90 percent of public primary schools use ASG 8: Percentage of schools included in 8.0: National digital ASC system accessible current-year Annual School Census 8.1: State digital ASC system operational (ASC) Report 8.2: 90% of schools included in current-year State ASC Report 8.3: 90% of schools included in current-year National ASC Report 8.4: 95% of schools included in current-year State ASC Report 1.3 Program Implementation and Institutional Arrangements 10. The Program will use the government systems and implementation structure for implementation, fiduciary, safeguards, M&E, and reporting arrangements. The program will use and strengthen existing implementation arrangements deployed by government for basic education in which the FME is mandated to formulate and coordinate policy while UBEC (federal) and SUBEB (state level) are responsible for UBE program implementation. At FME, a National Program Steering Committee (NPSC) will be established to provide oversight of the HOPE-EDU Program. UBEC will be responsible for DLIs 1-7, working through SUBEBs which have the main implementation responsibility at state level. The FME will be responsible for DLRs 3.0 and 3.4 and DLI 8, working in collaboration with UBEC/SUBEBs and State Ministries of Education (SMEs). The FME will provide oversight of the HOPE-Education program. The Minister of FME will appoint a National Program Coordinator (NPC). The NPC will report to the Minister of Education. The NPC at FME will oversee the program across the relevant departments/agencies; provide regular oversight of national learning assessments and ASC implementation (pertaining to DLRs 3.0 and 3.4, and DLI 8) through the relevant FME department/unit; and oversee any IPF component activities related to DLRs 3.0 and 3.4, and DLI 8. The UBEC Executive Secretary (ES) will designate or hire a Program Manager (PM), who will report to the ES. Acting under the delegated authority of the ES, the PM will be responsible for the daily coordination and supervision of program 16 activities pertaining to RA1 (DLIs 1-3; providing support to FME as needed for DLRs 3.0 and 3.4), RA2 (DLIs 4-5) and RA3 (DLI 6-7), working in close collaboration with the Directors and Deputy Directors of the UBEC Departments. The PM will also be responsible for all IPF component activities related to these DLIs; as well as for the verification of all DLIs. The Directors of relevant departments at UBEC will be responsible for overseeing the delivery of respective RA activities at the state level and will report on progress through regular UBEC channels. Technical experts will be hired using IPF funds and placed at UBEC to provide implementation support for RA1-RA3 and IPF-related activities; as well as to assist with fiduciary and social and environment safeguard functions. These experts will report to the PM. The NPC and PM will work closely together and hold quarterly meetings with the relevant directors of departments across FME and UBEC. 11. At the state level, each State will establish a State Program Steering Committee (SPSC) to provide program oversight. The SPSC will approve annual work plans and the strategic approaches adopted; ensure that applicable annual eligibility criteria are met, including the establishment of adequately resourced budget lines for the activities need to achieve DLI results; and facilitate effective coordination across agencies, states, development partners and other stakeholders. The SPSC will meet at least twice per year. The SUBEB Chairperson will be responsible for the daily coordination and supervision of activities related to DLIs 1-7 (excepting DLRs 3.0 and 3.4). Heads of relevant departments at SUBEB will have responsibility for ensuring the delivery of DLI-related activities. The SUBEBs will collaborate closely with SMEs in each RA as needed, as well as with the LGEAs; the LGEAs will in turn assist implementation working in cooperation with SBMCs and School Principals. The preparation of the annual state education budget and state UBE plan will be jointly led by the SME/SUBEB, particularly as it relates to ensuring adequate resources are allocated to achieve DLIs, with support and guidance from UBEC. UBEC will hire technical experts using IPF funds who will be placed at the SUBEBs, including at least one expert per Results Area in which the state is participating. Each of these state-level technical experts will support and work in close collaboration with the relevant SUBEB/SME departments and agencies, and will report to the SUBEB Chairperson as well as their counterpart technical expert at UBEC. The SUBEBs and state governments will take responsibility for the experts’ working conditions and non-salary operating costs. With respect to DLI 8 (ASC), the SME Commissioner will be responsible for the coordination and oversight of activities, with daily supervision and implementation management being the delegated responsibility of the head of the SME department responsible for education management information systems. 1.4 Program Boundaries and Result areas 12. The government’s Universal Basic Education (UBE) Program will provide the program boundary. The proposed PforR would be mapped to pillars of UBEC’s 10-Year Roadmap. Five of the Roadmap’s seven pillars are supported by the operation; while the other two are supported under another operation in this series, HOPE-Governance (P181476). The HOPE-EDU Program works in three results areas (RAs). RA1 supports improving the quality of education through the introduction of structured pedagogy focused on foundational literacy and numeracy. This is aligned to Pillar 3 (Quality and Learning Outcomes), particularly the strategies to introduce best pedagogical practices supporting learner literacy and numeracy, including the provision of teacher guides and textbooks; as well the Roadmap’s strategy to provide regular teacher professional development. RA2 supports increasing equitable access through the creation of new public primary classrooms and making non-formal basic education programs available to 17 out-of-school children. This is aligned to Pillar 1 (Access and Equity), particularly the strategies to provide quality learning environments including WASH facilities and to make basic education programs more widely accessible through both formal and non-formal providers. RA3 supports enhancing key systems for decentralized funding, school management and governance, and management information. This is aligned to Pillar 5 (System Strengthening), particularly the strategies to make school-based management committees (SBMCs) functional and scale up community involvement, and to build capacities in education management information; as well as the strategy to identify learning gaps through learning assessments. Pillars 2 (Crisis and Emergency Response) and 7 (Sector Coordination, Partnership and Collaboration) will be incorporated on a cross-cutting basis into all RAs. The specific boundaries of the operation will also be defined by the geographical participation of states in this operation. The program boundary is summarized in Table 1.2. Table 1.2: HOPE-Education Program Boundary Government’s UBE Program HOPE-Education PforR Extent of alignment Program Objective Accelerated, sustained, To improve foundational Aligned inclusive & equitable learning outcomes, increase provision of quality basic access to basic education and education for all children enhance key education systems in participating states Duration 2021-2030 2025-2029 Aligned, HOPE-Education is a time-slice Geographi National Open to states that meet Aligned c coverage eligibility criteria Results Pillar 1: Access and equity RA1: Improving quality RA1 aligned to Pillar 3, with focus on strategies areas 2: Crisis & emergency to introduce best practices promoting RA2: Increasing access response foundational learning. RA2 aligned to Pillar 1, 3: Quality & learning RA3: Enhancing key systems with focus on strategies to provide equitable outcomes and accessible learning environments in formal 4: Teacher quality & and non-formal settings. RA3 aligned to Pillars management 5 and 6, with focus on strategies to strengthen 5: System strengthening decentralized funding, school autonomy, 6: Education financing and community involvement, and strengthen EMIS. resourcing Pillars 2, 7 incorporated on cross-cutting basis. 7: Sector coordination, Parts of Pillars 4, 6, 7 under HOPE-GOV. partnership & coordination Overall US$11,280.70 million for PforR Total: US$3,722.63 HOPE-Education PforR financing accounts for Financing 2025-2029 million approximately 33% of the total UBE program Borrower: US$3,202.88 financing. Remainder, largely teacher salaries, million is under HOPE-GOV PforR. IDA: US$473.664 million GPE: US$46.086 million Results Area 1: Improving Quality. This area aims to ensure that literacy and numeracy are taught to primary students using a Structured Pedagogy Program (SPP) in participating States. The SPP is a coherent package of four integrated elements, which together are designed to improve classroom instruction and subsequently student performance: (i) teaching-learning materials (TLMs); (ii) teacher capacities; (iii) teacher support; and (iv) action-oriented evaluation of learning. 18 13. Using structured pedagogical materials that have been evaluated for effectiveness in a public school system, the participating States will develop, adapt or revise student textbooks and teacher’s guides for literacy and numeracy for each of Primary Grades P1-P6, in the applicable national language of instruction. The materials will follow detailed language- and numeracy- specific scope and sequences, with clear skills progressions that progressively build toward higher order skills e.g. beginning students learn the foundations of alphabet knowledge, and decoding skills, on the road toward increasingly automatic reading of words, adequate oral reading fluency, and eventually full reading comprehension. The teacher’s guides will provide structured lesson plans, as well as guidance on maximizing instructional time, evidence-based learning activities, appropriate sequencing and pacing, checks for learning, engaging students, and the use of low-cost materials to develop visual teaching aids. The TLMs will be quality assured and audited for gender, inclusion and climate awareness. The textbooks will be supplied to schools on a 1:1 student to book ratio; participating states may also include workbooks to complement the textbooks. To strengthen the textbook supply chain and enhance textbooks management and usage, the federal and participating state governments will operationalize a system to track and trace (TnT) the TLMs from the publisher/printer to the school; and after three years will evaluate textbooks usage, physical state and inventory, in order to develop textbooks management guidelines and improved physical specifications. 14. Teachers will be provided with professional development in support of the SPP . Teachers delivering the SPP will be trained on how to effectively use the lesson plans and instructional guidance in the teacher’s guide; the training will also include such themes as low -cost TLMS production, gender considerations in student participation and learning, and climate awareness. To ensure the SPP is implemented in the classroom as per design and to strengthen teaching- learning practices, teachers will also be periodically observed and mentored. The federal and state governments will build on existing SPP models to develop valid observation instruments that provide simple, meaningful measures aligned with the TLMs. The mentors will be trained on the correct use of the instrument and good coaching practices, for which purpose they will also be provided with pedagogical support resources. Participating States will ensure that observers are experienced pedagogues, and that their observation and mentoring work is sustainably supported; and will promote increasing the proportion of female mentors. In this latter regard, and depending on local resource availability, the mentor may be for example an LGEA School Support Officer (SSO) or the School Principal. 15. To strengthen the effectiveness of the SPP, LGEAs will conduct annual sample-based evaluations of learning in literacy and numeracy for Grades 1 and 2 . These rapid evaluation tools will be aligned with critical sub-skills in both reading and mathematics that form the early building blocks in both subjects. To ensure sustainability, and depending on the particular institutional, resource and capacity circumstances of each participating state, the evaluations may be administered by the coaches, an office of the LGEA or other suitable agent. The evaluation results will be analyzed each year by the mentors and education authorities at the level of each LGEA, and used to drive adjustments in the SPP design and delivery for better impact, including through advice given to teachers. To reliably assess the overall effectiveness of the SPP, two national sample-based assessments of learning in basic education will be also be conducted, at baseline and in Year 4, covering at least one grade in each of lower primary, upper primary and JSS. The assessments will be representative at the state level, and benchmark learning against clearly articulated proficiency levels. The results will be discussed by high-level decision makers to review and strengthen education sector strategies and policies, including the 19 SPP. All learning evaluations and assessments will be disaggregated by sex, and where gaps are identified will be used to take remedial action particularly at the local and school levels. Results Area 2: Increasing Access. This area aims to increase access to, and enrollment in, primary education in participating States through the community-supported creation of new classrooms and learning opportunities in the public formal and non-formal sectors. 16. Government-community partnership agreements will be developed and implemented to create twelve thousand new public primary classrooms in areas where there are no schools within safe walking distance, or where accessible schools have a SCR exceeding 50 and adding an extra shift is not a solution. The partnership agreements between the Community Management Committee (CMC) and the LGEA/SUBEB/SME will detail each party’s contributions, including the appointment of a qualified teacher. The agreements will adhere to certain process and end-result standards. The process standards will include the CMC ensuring a minimum community contribution to, and community management and monitoring of, the construction project; as well as the transparent processing of procurements, with information made publicly available. With respect to end results, the construction works must adhere to applicable infrastructural and social-environmental standards; and must include (if absent) a secure perimeter, physical disability access, and adequate gender-segregated WASH facilities. To promote climate resilience, adaptation and mitigation, constructions will need to meet certain standards. These will include designs and materials that: (a) prioritize resilience to extreme weather events and compliance with EDGE Certificate standards (or equivalent); (b) incorporate sustainable power sources and energy-efficient devices; (c) mitigate against extreme heat conditions; and (d) use sustainable building materials. The CMC will plan to use the school as a refuge for persons displaced by extreme climate events; and develop emergency evacuation plans. Partnership agreements will incorporate these standards, and their adherence throughout the design, site selection and construction process will be monitored and verified. (See Annex 2). 17. Non-formal learning centers (NFLCs) will be established or strengthened to enable OOSC to complete a literacy and numeracy program. The NFLC may be a traditional faith-based school or a community non-formal learning center. It will have a Centre-Based Management Committee (CBMC) that has been trained on the essential duties of NFLC management, including instructor selection, enabling access, climate awareness and response, child protection, and security awareness and response. The CBMC will also be responsible for community mobilization to identify and attract OOSC. The mobilization process will filter out-of-school children to enroll only those for whom non-formal basic education (NFBE) is appropriate, encouraging enrollment in the formal primary system of those who are able to integrate directly into, and have access to, a public school. In areas where there is an accessible formal primary school that is overcrowded, or where there is no formal primary school, the community will be encouraged to create new primary classrooms using the partnership agreements explained above. The program will be delivered in the relevant national language of instruction, using TLMs that have been formally approved; and may be any of the non-formal basic education programs that provide equivalency to the formal curriculum, such that a child who successfully completes a program and passes the formal evaluation may transition into the formal system. The program will be taught by a qualified and paid instructor. 20 Results Area 3: Enhancing Key Systems. This area aims to strengthen the allocation and management of UBEIF, and school management, governance and accountability; and to generate information essential for system management. 18. The operation will support enhancing States’ access to, and the decentralized management of, UBE funds. As part of the HOPE-GOV operation, the Intervention Fund Guidelines (IFG) will be revised to enhance states’ access to the UBE matching funds, to allow for greater decentralization in the management of UBE funds, and to strengthen gender-based planning, climate awareness and response, and support for vulnerable groups. Under this operation, the states will operationalize and strengthen systems to de-centrally manage UBE funds, particularly pertaining to core funds for: i) SUBEBs, to manage TLMs procurement and distribution; and ii) LGEAs and community-based organizations, to manage teacher continuous professional development, the monitoring and quality assurance of education services, and community- based civil works (CBCW). 19. The federal and participating state governments will sustainably finance an annual operating grant for public primary schools in participating States; to be managed by the school in accordance with strengthened grant and school management guidelines. The amount of the grant will be established and inscribed in the state annual education budget, in line with available state and federal resources; automatically disbursed each year in regular tranches; and allocated across schools within any given state according to a transparent formula. The strengthened guidelines will cover inter alia the process for developing the grant budget and expending the funds, including fiduciary obligations and requirements pertaining to community participation and monitoring; and a positive list of eligible (including mandatory) expenditures, including resources to monitor and encourage attendance, particularly of children who have dropped out or are at-risk of dropping out; for TLMs; and cleaning, maintenance and small repairs. The guidelines will also strengthen the school’s governance and accountability functions, with greater reporting to the community on school activities, and on teacher and student performance; an enhanced attention to child safety and protection, security awareness and response, climate change and resilience, and support to vulnerable groups; and more parental involvement in the school community including to establish developmental priorities and monitor school performance. 20. The education management information system will be strengthened in all states and the Federal Capital Territory (FCT), to ensure that the annual school census (ASC) database and statistical report are digitally published using current-year data from at least 95 percent of schools. The digital annual school census (ASC) form maintained by Nigeria Education Management Information System (NEMIS) will be adopted in all states/FCT, which will follow one standard schedule and set of procedures for data collection, transmission and reporting. To this end, the federal and state/FCT governments will cooperate to ensure that the ASC data template and platform are fully accessible, and capacities are in place to operate the system at all levels; states will ensure that SMEs and LGEAs have adequate IT infrastructure for data collection, processing and validation. Digital platforms will be upgraded as needed to enable the publication and downloading of disaggregated ASC results down to the school level. Further, data requirements and school codes will be aligned across the ASC and National Personnel Audit (NPA) platforms, to ensure their interoperability. 1.5 Excluded Activities 21 21. The Program will exclude activities that do not meet the World Bank’s Policy on eligibility for PforR financing (September 2020). The borrower shall ensure that the Program excludes any activity that, in the opinion of the World Bank, is likely to have significant adverse environmental impacts that are sensitive, diverse, or unprecedented and/or requires significant land acquisition, displacement, and/or resettlement of affected people. 22. Any Program activity that entails land acquisition, negative impact on natural habitat and cultural resources, public and worker’s health and safety will not be funded under the PforR without adequate environmental and social management. For example, the program will support the procurement of civil works, and materials only when an adequate e-waste management plan is in place of the bidding document and monitored and reported regularly. 1.6 Scope of the Environmental and Social Management System Assessment (ESSA) 23. The ESSA for the program examines the extent to which the Federal and State Government’s existing environmental and social management systems: operates within, an adequate legal and regulatory framework to guide environmental and social impact assessments, mitigation, management and monitoring at the PforR Program level; It evaluates how the system incorporates recognized elements of good practice in environmental and social assessment and management, via due diligence including: (i) early screening of potential impacts; (ii) the consideration of strategic, technical, and site alternatives (including the “no action” alternative); (iii) explicit assessment of potential induced, cumulative, and transboundary impacts; (iv) the identification of measures to mitigate adverse environmental or social risks and impacts that cannot be otherwise avoided or minimized; (v) clear articulation of institutional responsibilities and resources to support implementation of plans; and (vi) responsiveness and accountability through stakeholder consultation, timely dissemination of the PforR Program information, and responsive grievance redress mechanisms; among others. Based on these findings, the ESSA thereafter defines measures to strengthen the system and recommends measures that will be integrated into the overall Program. 24. This ESSA has been prepared for the HOPE-Education Program to ensure consistency with the “core principles” outlined in the World Bank’s policy for the PforR instrument to effectively manage the Program’s risks and impacts while promoting sustainable development. These six core principles are: a) Environment: To promote environmental and social sustainability in the Program design; avoid, minimize, or mitigate adverse impacts, and promote informed decision-making relating to the Program’s environmental and social impacts. b) Natural Habitats and Cultural Resources: To avoid, minimize, or mitigate adverse impacts on natural habitats and physical cultural resources resulting from the Program. c) Public and Worker Safety: To protect public and worker safety against the potential risks associated with: (a) construction and/or operations of facilities or other operational practices under the Program; (b) exposure to toxic chemicals, hazardous wastes, and other dangerous materials under the Program; and (c) reconstruction or rehabilitation of infrastructure located in areas prone to natural hazards. d) Land Acquisition: To manage land acquisition and loss of access to natural resources in a way that avoids or minimizes displacement and assist the affected people in improving, or at the minimum restoring, their livelihoods and living standards. 22 e) Vulnerable Groups: To give due consideration to the cultural appropriateness of and equitable access to Program benefits, giving special attention to the rights and interests of Indigenous Peoples and to the needs or concerns of vulnerable groups. f) Social Conflict: To avoid exacerbating social conflict, especially in fragile states, post-conflict areas, or areas subject to territorial dispute. 25. In line with the six core principles above, the relevant risks associated with the HOPE Program and within the proposed Result Areas (RAs) under the PforR covers environmental and social issues and include: a) Increased generation of e-waste due to possible use of digital devices in monitoring the effectiveness of structured pedagogical program (SPP) materials in DLI 3 and, digitization of annual school census (ASC) and digital submission and publication of validated data in DLI8 , which will involve the use of ICT systems. b) The procurement and delivery of civil works, equipment, and materials, including the construction of twelve thousand new public classrooms through government-community partnerships in DLIs 4 and the creation of new public primary classrooms through government-community partnerships in DLI 5 could lead to adverse environmental and social impacts associated with these activities, such as the generation of solid waste, noise, and air pollution. c) Potential exclusion of vulnerable groups, e.g. children with disabilities, those in conflict zones, nomadic households, internally displaced persons (IDPs), etc., where there are no targeted approaches to mainstream them into the educational system. d) Potential discrimination of vulnerable groups due to ethnic considerations, sexual abuse or harassment of children in the provision of teaching and learning materials (TLM) in DLI 1 and women in the recruitment of a qualified teacher and instructors in Non-Formal Learning Centres (NFLC) in DLI 5. e) Conflicts and security risks could disrupt the Program's implementation. Insurgents and bandits can target schools and teachers. f) Resistance by members of the community who may view the Program, especially for girls, as conflicting with cultural beliefs. On the contrary exclusion of stakeholders can also lead to mistrust and resistance of the Program. g) The procurement and delivery of civil works, equipment, and materials in DLI4 could also impact workers’ health and safety. h) Construction of twelve thousand new classrooms in public primary under DLI4 could result in land acquisition for building more classrooms. This could result in social risks associated with land acquisition. i) Potential risk of child abuse and child labour during the construction of new public primary classrooms 26. The details of the applicability of Core Environmental and Social Principles (CP) to HOPE PforR Result Area and Disbursement Linked Indicators (DLIs) are presented in Annex 1. A summary of DLI applicability by Core Principle is presented in the table below. Table 1.3: Summary of DLIs Applicability by Core Principle DLI No DLI Applicability by Core Principle 23 Environment Social 1 1: Number of schools with sufficient CP1 CP5 TLMs for literacy and numeracy 2 2: Number of primary teachers with CP5 improved structured pedagogy practices 3 3: Percentage of children proficient in C5 literacy and numeracy 4 4: Number of new primary classrooms CP1, CP2 CP3, CP4, CP5, C6 created through community participation 5 5: Number of children who complete CP1, CP2 CP3, CP4, CP5, C6 NFBE program 8 8: Percentage of schools included in CP1 current-year Annual School Census report 1.7 Objectives of this ESSA 27. The specific objectives of this ESSA are to: a) Identify the potential environmental and social impacts/risks applicable to the Program’s interventions. b) Review all relevant Nigerian policy and the legal framework of the Government of Nigeria (GoN) and relevant State Governments related to the management of environmental and social impacts of the Program’s interventions. c) Review the environmental and social due diligence management procedures and institutional responsibilities that the GoN is using for the HOPE-Education program. d) Assess capacity within domestic revenue generation institutions and Environmental and Social management within the public sector operating systems of the GoN put in place for environmental and social impact management within the Program system. e) Assess the Program’s system performance concerning the core principles of the Program- for-Results (PforR) instrument, as well as identify gaps in the Program’s performance. f) Recommended actions to fill gaps identified that will be embedded into the Program Action Plan (PAP) to strengthen the Program’s performance with respect to the core principles on Environment and Social of the PforR instrument to ensure sustainable implementation via good due diligence 28. The overall environmental and social risks have been assessed and deemed to be Substantial. Although the program activities are not likely to require significant changes to the borrower’s overall environmental systems, the program was generally assessed as substantial because of the procurement of civil works and material in DLIs 4 , possible community land acquisition for building of classrooms, e-waste as a result of possible deployment of learning packages to teachers in the form of digital devices in DLI 1, and, digitization of annual school census and database and publishing of statistical report digitally in DLI8 and the envisaged social risks associated with recruitment qualified teachers and instructors DLI5. 24 1.8 Approach of ESSA 29. The World Bank team prepared the ESSA through a combination of detailed reviews of existing program materials and available technical literature, including policies, regulations, guidelines and examples of due diligence and design documents, interviews and extensive consultations with government staff, non-governmental organizations, regulatory agencies, private sector organizations and sector experts associated with public revenue generation. Based on the analysis conducted, the findings, conclusions and opinions expressed in the ESSA are those of the Bank. 30. An environmental and social risk screening of proposed activities was undertaken at the concept stage. The purpose of the screening was to: • Confirm that there are no activities which meet the defined exclusion criteria included in the PforR in line with the Bank Guideline for the ESSA; and • Establish the initial scope of the ESSA. This includes identification of relevant systems under the PforR and relevant stakeholders for engagement and consultations. 31. System Assessment (September 2020). The guidance sets out core principles (See Section I.5) and planning elements used to ensure that PforR operations are designed and implemented in a manner that maximizes potential environmental and social benefits while avoiding, minimizing or mitigating environmental and social harm. 32. Following the initial screening, the system review was conducted using a two-step approach: • Identification of relevant systems that are pertinent to the ESSA was addressed in Section IV which presents an overview of relevant government environmental and social management systems; and • Assessment of CLIENT’S environmental and social management systems for consistency with the applicable Core Principles, including capacity and enforcement of certain environmental and social measures, was addressed in Section V, while environmental and social recommendations were addressed in Section VI. 25 SECTION II: STAKEHOLDER CONSULTATION 33. This section summarizes the stakeholder consultation activities undertaken for the ESSA. The ESSA process includes extensive stakeholder consultations and disclosure of the ESSA Report, in accordance with the World Bank Policy and Directive for Program for-Results Financing and Access to Information Policy. Currently, the ESSA consultation process is embedded in the Program consultation process. Feedback from stakeholders have been instrumental in designing and revising the Program Action Plan, indicators, and program operations manuals and appraisal documents via providing data and details on the existing situation, management status and government priorities regarding primary health care and basic education. 34. Initial consultations with the government and a large group of stakeholders over a period led to the formulation of the HOPE PforR. The outcomes of those consultations are embedded in this program and have influenced its design. Further consultations were held with State government stakeholders on the 22 nd and 24th of April 2024 for states in Northern Nigeria and Southern Nigeria, respectively targeted at HOPE-GOV which also included education. 35. The stakeholders consulted include the Directors from the State Ministry of Budget and Economic Planning, State Ministry of Education, SUBEB, State Ministry of Health, State Primary Health Care Development Boards, and State Health Insurance Agencies. 36. Three states from Northern Nigeria, namely Kwara, Borno and Nasarawa on the 22 nd of April and Taraba on the 24th of April. On the other hand, five states from Southern Nigeria, namely Anambra, Enugu, Osun, Rivers and Ogun participated in the discussion. The attendance list is presented in Annex 3. 37. During the discussion, the stakeholders received detailed information about the purpose of the consultation and the HOPE program, including the project development objectives, the result areas, and the DLIs. The World Bank team also inquired from the stakeholders about the capacity of the states to handle E&S issues. Several questions based on the result areas were raised by the World Bank team, to which representatives from the states responded. The questions centered on the capacity of the states to handle E&S issues in procurement, availability of legislations and regulations and procedures for handling ESIA, ESMP, e-waste management, solid waste management, hospital waste management, grievance redress mechanism, gender-based violence and sexual harassment, OHS procedures, social inclusion, among others. 38. Specific consultation was also held for HOPE-Edu on 5th December 2024. The summary of the stakeholder’s concerns and responses from the bank team is in Table 2.1 below. The detailed report of the stakeholder consultation is in the Annex. 26 Table 2.1: Summary of the stakeholder’s concerns and responses from the bank team Comments and Concerns of Stakeholders Responses There were concerns about the lack of explicit The was noted. mention of key agencies such as the Universal Basic Education Commission (UBEC) and State Universal Basic Education Boards (SUBEB) in the program action plan, despite their important roles in education. Despite their inclusion in vulnerable groups, the It was noted that vulnerable groups also action plan did not specifically mention children include children with disabilities and others with disabilities. The alignment with Nigeria's but none was explicitly mentioned in the PAP. National Inclusive Education Policy raised questions There were also concerns about the lack of It was noted that all stakeholders were involvement of relevant stakeholders, such as the involved in the formulation of the Program by National Commission for Persons with Disabilities the World Bank Technical Team for Education. (NCPWD) and organizations representing persons The team noted that the disability act will be with disabilities (OPDs), as well as the omission of included as part of institutional framework for key legislative references, like the Disability Act vulnerable people. and the UN Convention on the Rights of Persons with Disabilities For long-term sustainability, there was a strong The team indicated that it was already the emphasis on the program's full integration into case as the technical took account of the Nigeria's educational ecosystem Nigeria educational ecosystem in Program design. Engaging all stakeholders at federal, state, and It was observed that the technical team has local levels, such as national education boards, made effort to engage all the stakeholders local authorities, state assemblies, and and that consultation with stakeholders is a development partners, was a concern to ensure continuous process. effective participation and prevent weak links in the program Need for capacity building for new environmental This was noted and is already part of the PAP and social safeguard (ESS) teams, particularly in emerging rural communities and areas with empty classrooms Stakeholders in attendance recommended a Noted holistic approach to program implementation, involving all levels of government and stakeholders and leveraging local partnerships to strengthen accountability and inclusion 27 SECTION III: DESCRIPTION OF EXPECTED PROGRAM ENVIRONMENTAL AND SOCIAL IMPACTS 3.1 Overview of Program Risks and Benefits 39. The PforR component of HOPE-Edu will generate some E&S benefits and risks. The environmental risks include e-waste, which could result from possible deployment of learning packages to teachers in the form of digital devices and digitization of annual school census and database and publishing of statistical report digitally. Also, construction and classroom expansion, would pose some environmental risks associated with construction. On the other hand, the environmental benefits are minimal and limited to the benefits of maintaining and cleaning school compounds. The detailed range of key environmental and social risks and benefits associated with specific DLI in HOPE- Edu PforR is presented in Annex 3. 3.2 Expected Environmental Benefits 40. The PforR program will deliver minimal direct environmental benefits. Environment benefits will accrue through the use of school-based management grants for cleaning and maintaining school premises as outlined in DLI 7. 3.3 Expected Environmental Risks and Impacts 41. The HOPE-Edu PforR has some activities that are expected to impact the environment. The construction, and classroom expansion associated with DLI 4 and DLI 5, could significantly impact the environment. The procurement of civil works, construction, and classroom expansion is associated with significant direct and indirect environmental risks such as solid waste generation, noise, land degradation, air pollution and destruction of flora and fauna, which could lead to biodiversity loss. 42. The supply of teaching-learning materials (TLMs) associated with DLI1 and printing and distribution of Non-Formal Basic Education (NFBE) TLMs will involve printing textbooks and teacher guides with structured lesson plans. This will consume a large amount of paper, thus impacting forests and trees used to manufacture paper. Digitizing the learning packages could reduce the impact. 43. In addition, the possibility of deploying learning packages to teachers in the form of digital devices, digitizing teacher observation instruments, possible use of digital means in the evaluation of learning in literacy and numeracy by Local Government Education Authorities (LGEAs) the digitization of annual school census and transmission, , and adoption of a standardized and automated reporting format associated with DLIs 1, 2, 3 and 8 could result in the generation of e-waste. 3.4 Expected Social Benefits 44. The HOPE -Edu PforR has many social benefits that will result from achieving the DLIs. These benefits include increased school enrollment, enhanced literacy and numeracy among school children, reduced out-of-school children (OOSC), enhanced performance of pupils and students in basic education, enhanced economic development, and poverty 28 reduction, especially among the most vulnerable. The pathway for the social benefit of the intervention is shown in Figure 3.1 below Reduced unemployment, Intervention Increased Increase Increased productivity, Enhanced s in basic education d ability Increased income, economic growth education outcomes to work reduced vulnerability to and development shocks Figure 3.1: Pathway of social benefits of interventions under the Program. 45. Activities associated with ensuring the availability of essential teaching-learning materials (DLI1), enhancing teachers’ competencies in teaching foundational literacy and numeracy through professional development support and mentoring of teachers on SPP (DLI2) will result in significant social benefits. Activities which include the supply of teaching-learning materials (TLMs) that are designed to foster mastery of foundational literacy and numeracy, including textbooks and teacher guides with structured lesson plans, professional development of teachers to effectively use the teaching-learning materials and apply the structured pedagogical approach for literacy and numeracy, mentoring of teachers and training of mentors on the correct use of the instrument and good coaching practices, enhancing literacy and numeracy programs in non-formal learning centres (NFLCs) by OOSC in DLI 5 will result in enhanced performance of pupils and students in basic education as will be manifested in their end of year results and other performance assessment measures, increased enrollment in basic education, reduction in OOSC, and their improved literacy and numeracy,. 46. Furthermore, activities associated with increased access to primary education (DLI 4), which include the establishment of twelve thousand public primary classrooms specially in areas where they do not exist and recruitment of qualified teachers and instructors for NFLCs will enhance access to education by people without access to education, guarantee that qualified and competent teachers are available in in NFLCs and primary schools in rural communities thus increasing enrollment of pupils in schools, reduction in OOSC, and improved literacy and numeracy of pupils in primary education. 47. Also, achieving DLI 7 (strengthened school management, governance, and financial autonomy) will ensure that schools receive and properly manage school grants, which will, in turn, encourage school attendance, particularly for children who have dropped out or are at risk of dropping out, and enable school management to purchase materials for teaching-learning purposes. This will ultimately reduce the number of OOSCs and improve the literacy and numeracy of pupils in primary education. Also, ensuring that school management committees are well constituted and own bank or other financial accounts that can be accessed and managed transparently will equally facilitate financial inclusion in Nigeria. Although formal financial inclusion has grown significantly in Nigeria 29 from 52 percent in 2020 to 64 percent in 2023, over 28.9 million adult Nigerians (26.0 percent) are still financially excluded9. 48. In addition, enhancing the availability of information for education system management, especially through digitizing school-based data collection and transmission, as detailed in DLI8, will facilitate the availability of data for basic education management in the states and Nigeria. Effective management of basic education will facilitate improved education outcomes, reduction in unemployment, and enhanced economic development. 3.5 Social Risks and Impact 49. The HOPE-Edu PforR is also associated with some social risks. The construction and establishment of twelve thousand classrooms by communities in DLI 4 could potentially impact workers' health and safety for workers involved in construction works related to these DLI. The workers may be exposed to pollution caused by dust and noise at the work site. There could also be child labour, and influx of workers to the communities where rehabilitation work will occur which could lead to complaints from the host communities. This may affect the communities as there could be cases of sexual abuse and other vices, for example, drug abuse. Where the schools are not accessible for children and staff with disabilities, it may further create more exclusion. It is critical that the construction activities adhere to the National Accessibility Regulation10 that provides the standards to ensure public infrastructures are accessible for all, including Persons with Disabilities. 50. There could be potential exclusion of children with disabilities where they are no targeted approaches to include them into the program as beneficiaries or make the schools inclusive. Other vulnerable groups that may be potentially excluded include children in conflict zones, nomadic households IDPs, exclusion due to ethnic considerations, etc. Child labour may occur, as most OOSC are already engaged in various forms of labour. There could be potential issues on child abuse, SEA/SH on children and sexual abuse or harassment of women in the hiring and appointment of qualified instructors, in DLI 5. In addition, although social conflict as envisaged by ESSA, especially regarding armed conflict, is not applicable, exclusion of vulnerable groups and discrimination along the lines of ethnicity and religion in the distribution of TLMs, training of teachers in the use of structured pedagogy materials, coaching of mentors on the correct use of the instrument and good coaching practices, recruitment and hiring of trained instructors and teachers can result in complaints, social unrest and demonstrations. Conflicts and security risks could disrupt the Program, as schools and teacher can be targeted by insurgents. Resistance by member of the community who may view the Program especially for girls, as conflicting with cultural beliefs. On the contrary exclusion of stakeholders can also lead to mistrust and resistance of the Program. 51. In addition, the acquisition of land for civil works, construction and expansion of classrooms in communities associated with activities of DLI 4 could result in conflict among community members if not well handled, especially through an acceptable land donation protocol. 9 EflnA (2023) Access to financial services in Nigeria, 2023 report. 10 ncpwd.gov.ng/pdfs/44document.pdf 30 52. In addition, the constitution of the School-Based Management Committee (SBMC) and the disbursement of grants and school-based management of grant may potentially be open to corruption and mismanagement of funds not withstanding the recommendation that a bank account should be used for transparent management. 31 SECTION IV: OVERVIEW OF RELEVANT BORROWERS ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEMS 53. The government of Nigeria (GON) has several policies, instruments, and laws that support environmental and social management and environmental and social impact assessment processes. There are a number of sectoral policies which provide directives to integrate environmental and social considerations in the decision-making process to avoid or minimize impacts associated with program implementation. This section summarizes the policy, regulatory, institutional and legal frameworks for environmental management Nigeria. 4.1 The Constitution of the Federal Republic of Nigeria (1999) 54. The basis of environmental policy in Nigeria is contained in the 1999 Nigerian Constitution of the Federal Republic of Nigeria. Pursuant to section 20 of the Constitution, the State is empowered to protect and improve the environment and safeguard the water, air and land, forest, and wildlife of Nigeria. Similarly, social policy in Nigeria also originates from the 1999 Nigerian Constitution of the Federal Republic of Nigeria. Section 17 encourages the state to pursue equality of rights, equal pay for equal work, obligations, opportunities and human dignity for all citizens. In addition, the state shall avoid social exclusion and discrimination of any form, including gender, protection of children and vulnerable from any exploitation and moral and material neglect. The state will also promote equal access to facilities, including basic education. 4.2 Policies Relevant to the HOPE-Edu Program 55. The national policies relevant to the HOPE PforR is presented in Table 4.1. Table 4.1: Nigerian Policies Relevant to the HOPE Program Policy Objectives National Policy Overall Policy Goal on the To define a new holistic framework for guidance, management and protection of the Environment environment as well as the conservation of natural resources for sustainable development’ of (Revised 2016) the country. Objectives ▪ Ensuring and securing the quality of Nigeria’s environment to support good health and well - being; ▪ Promoting efficient and sustainable use of Nigeria’s natural resources and the restoration and maintenance of the biological diversity of ecosystems; ▪ Promoting understanding of essential linkages between the environment, social and economic developmental issues; ▪ Encouraging individual and community participation in environmental improvement initiatives; ▪ Raising public awareness and engendering a national culture of environmental preservation; and ▪ Building partnership among all stakeholders, including government at all levels, international institutions and governments, non-governmental agencies and communities on environmental matters. National Policy Overall Policy Goal on Education Nigeria’s national education policy aims to standardize education across all levels, as outlined in the Constitution of the Federal Republic of Nigeria, 1999. 32  Objectives Philosophy: fostering national unity, promoting social mobility, and developing the individual’s potential.  Universal Basic Education: Ensuring equal access to quality education for all citizens, regardless of background or socio-economic status.  Science & Technology Education: Developing a skilled workforce and promoting technological advancement.  National Development: Preparing students to contribute to Nigeria’s economic, social, and cultural development.   To Achieve These, the policy emphasizes:  Accessibility: Expanding educational opportunities to underserved populations.  Relevance: Aligning education with Nigeria’s development needs.  Quality: Improving teaching standards, curriculum, and infrastructure.  Efficiency: Optimising resources utilization and management. The Federal Ministry of Education oversees the implementation of these policies, ensuring consistencies and progress towards Nigeria’s educational objectives. National Gender Overall Policy Goal Policy (2006) The goal of the gender policy is to “build a just society devoid of discrimination, harness the dull potentials of all social groups regardless of sex or circumstance, promote the enjoyment of fundamental human rights and protect the health, social , economic and political well- being of all citizens in order to achieve equitable rapid economic growth, evolve an evidence based planning and governance system where human, social, financial and technological resources are efficiently deployed for sustainable d evelopment”. One of the principles of the gender policy is a general recognition that gender issues are central and critical to the achievement of national development goals and objectives and by extension water, sanitation and hygiene programs. Objectives  Establish the framework for gender responsiveness in all public and private spheres and strengthen capacities of all stakeholders to deliver their component mandate of the gender policy and National Strategic Framework  Develop and apply gender mainstreaming approaches, tools and instruments that are compatible with the macro- policy framework of the country at any given time towards national development.  Adopt gender mainstreaming as a core value and practice in social transformation, organisational cultures and in the general polity in Nigeria.  Incorporate the principles of CEDAW and other global and regional frameworks that support gender equality and women empowerment in the country’s laws, legislative processes, judicial and administrative systems  Achieve minimum threshold of representation for women in order to promote equal opportunity in all areas of political social and economic life of the country for women as well as for men.  Undertake women and men- specific projects as a means of developing the capabilities of both women and men, to enable them take advantage of economic and political opportunities towards the achievement of gender equality and women’s empowerment.  Educate and sensitize all stakeholders on the centrality of gender equality and women’s empowerment to the attainment of overall national development. 33 4.3 Relevant Nigerian National Laws 56. The national laws relevant to HOPE-Edu PforR are presented in Table 4.2. Table 4.2: Nigerian Laws that are Relevant to the HOPE-Edu Program S/N Law Description/Summary of Objectives Environmental Acts ▪ The main aim of the Act is to ensure environmentally sound and sustainable development EIA Act - CAP. projects. 1 E12 L.F.N. ▪ To carry out an EIA on all projects likely to have significant impact on the environment 2004 ▪ Encourage information exchange and consultation between all stakeholders when proposed activities are likely to have significant impact on the environment. ▪ Enforce compliance with national (and international) laws, legislations, guidelines, policies and standards on environmental matters; ▪ Coordinate and liaise with, stakeholders, within and outside Nigeria on matters of environmental standards, regulations and enforcement; ▪ Ensure that environmental projects funded by donor organizations and external support agencies adhere to regulations in environmental safety and protection; ▪ Enforce environmental control measures through registration, licensing and permitting Systems other than in the oil and gas sector; and ▪ Conduct environmental audit and establish data bank on regulatory and enforcement National mechanisms of environmental standards other than in the oil and gas sector. Environmental Standards and Some relevant sections include Regulations, 2 Section 7: Authority to ensure compliance with all of Nigeria’s environmental laws and treaty Enforcement obligations; and Agency Act, ▪ Section 8 (1) K and Section 27: Authority to make and review regulations on air and water (NESREA) 2007 quality, discharge of effluents and other harmful substances as well as control of other forms of environmental pollution. ▪ The Agency has powers to: ▪ prohibit processes and use of equipment or technology that undermine environmental quality; ▪ conduct field follow-up of compliance with set standards and take procedures prescribed by law against any violator; ▪ subject to the provision of the Constitution of the Federal Republic of Nigeria, 1999, and in collaboration with relevant judicial authorities establish mobile courts to expeditiously dispense cases of violation of environmental regulation. Social Acts ▪ Makes provisions with respect to the formation, registration and organization of trade unions, and the Federation of Trade Unions ▪ It states, "notwithstanding anything to the contrary in this Act, membership of a trade union Trade Union by employees shall be voluntary and no employee shall be forced to join any trade union or 5 Amended Act be victimized for refusing to join or remain a member”. The amended Act , to ensure the 2005 funding of trade unions, empowers employers to make deduction from the wages of every worker who is a member of any of the trade unions for the purpose of paying contributions to the trade union so registered; ▪ This Act repeals the Workmen Act of 1980. ▪ The objectives of the Act include Provide for an open and fair system of guaranteed and adequate compensation for all employees or their dependents for any death, injury, disease Employees or disability arising out of or in the course of employment; 6 Compensation ▪ provide rehabilitation to employees with work-related disabilities as provided in this Act; Act (2010) ▪ establish and maintain a solvent compensation fund managed in the interest of employees and employers; ▪ provide for fair and adequate assessments for employers; 34 ▪ provide an appeal procedure that is simple, fair and accessible, with minimal delays; and ▪ combine efforts and resources of relevant stakeholders for the prevention of workplace disabilities, including the enforcement of occupational safety and health standards. ▪ The Act makes provisions for the settlement of trade disputes and other matters ancillary thereto. The Act established the National Industrial Court. The Act provides for procedure of settling dispute before it is reported; apprehension of trade dispute by the Minister; reporting of dispute if not amicably settled; appointment of conciliator, etc. Regarding the Trade Dispute procedure before dispute is reported, the Act provides that parties to the dispute shall first 7 Act CAP. T8 attempt to settle it by an agreed means for settlement of the dispute apart from the Act. It LFN 2004 is only when this procedure fails or does not exist that the parties report within seven days and come together to settle the dispute under a conciliator. Notwithstanding this provision, the Minister can apprehend the dispute and decide on the cause of action for the settlement of the dispute. ▪ Act provides for the protection of wages, contracts of employment and terms and conditions of employment as well as recruiting guidelines. It provides for special classes of worker and miscellaneous special provisions. The Act in the different parts made a lot of provisions to ensure that the interest of the worker is protected. For example, under protection of wages Labor Act CAP the Act made provisions to ensure that the worker's dignity regarding wages is maintained. 8 L1 LFN 2004 For example, the Act provides in part 1No 2 that no employer shall impose in any contract for the employment of any worker any terms as to the place at which, or the manner in which, or the person with whom any wages paid to the worker are to be expended; and every contract between an employer and a worker containing any such terms shall be illegal, null and void ▪ Incorporate into its laws all the rights guaranteed in the United Nations’ Convention on the Rights of the Child. The U.N. convention, adopted in 1989, states that: “The child shall be protected against all forms of neglect, cruelty and exploitation. He shall not be admitted to Child Right Act 9 employment before an appropriate minimum age; he shall in no case be caused or permitted 2003 to engage in any occupation or employment which would prejudice his health or education, or interfere with his physical, mental or moral develop ment.” The Act must be ratified by each state to become law in its territory.  The Act was passed into law in a bid to eliminate violence in private and public life; prohibit all forms of violence, including physical, sexual, psychological, domestic, harmful traditional practices; discrimination against persons and to provide maximum protection and effective remedies for victims and punishment of offenders  The content of the Act is rich in its provisions as it covers most of the prevalent forms of violence in Nigeria today ranging from physical violence; psychological violence; sexual violence; harmful traditional practices; and socio-economic violence.  The National Agency for the Prohibition of Trafficking in Persons (NAPTIP) is named as the service provider.  Under the VAPP Act, the following offences are punishable offences.; Violence o rape, Against o spousal battery, 10 Persons o forceful ejection from home, (Prohibition) o forced financial dependence or economic abuse, VAPP Act 2015 o harmful widowhood practices, o female circumcision or genital mutilation, o abandonment of children, o harmful traditional practices, o harmful substance attacks such as acid baths, o political violence, o forced isolation and separation from family and friends, o depriving persons of their liberty, o incest,  indecent exposure and violence by state actors (especially government security forces). Education Act 35 • This Act which took effect from 26th May 2004 was to ensure the Federal Government intervention for uniform and qualitative basic education in Nigeria, as assistance to states and local government areas which are constitutionally responsible for primary education. As stated in the Act, “without prejudice to the provisions of item 30 of Part II of the Second Schedule and item 2 (a) of the Fourth Schedule to the 1999 Constitution dealing with primary school education, the Federal Government's intervention under this Act shall only be an assistance to the States and Local Government in Nigeria for the purposes of uniform and qualitative basic education throughout Nigeria” . Compulsory, • The Act provides that every government in Nigeria shall provide free and compulsory free Free and 11 basic education for every child of primary and junior secondary school age and that parents Universal Basic shall send their children to school and ensure that their wards complete primary and junior Education Act secondary education. The government and stakeholders are to ensure that parents take their wards to school. The Act provides that services in public schools for primary and junior secondary education are free of charge. • The Act also established the Universal Basic Education Commission (UBEC) charged with the responsibility of policy formulation regarding basic education in Nigeria, receive block grant from federal government and allocate to states, among others. The Act also established the State UBEC and the local government education authority. 4.4 Relevant Nigerian National Environmental Regulations 57. The national environmental regulations relevant to HOPE-Edu PforR are presented in Table 4.3. Table 4.3: Relevant Nigerian National Environmental Regulations S/N Regulation Objectives National Environmental (Permitting The provisions of this Regulation enable consistent application of 1 and Licensing System) Regulations, environmental laws, regulations and standards in all sectors of the economy 2009. S. I. No. 29. and geographical regions. National Environmental (Sanitation To provide the legal framework for the adoption of sustainable and 2 and Wastes Control) Regulations, environment friendly practices in environmental sanitation and waste 2009. S.I. No. 28 management to minimize pollution. 4.5 Nigeria’s Institutional Framework 4.5.1 Nigeria’s Institutional Framework 58. The Federal Ministries whose functions and responsibilities are relevant to the HOPE-Edu PforR is presented in Table 4.4. Table 4.4: Relevant Ministries and Agencies and Their Functions at the Federal Level S/N Ministry Relevant Functions and Responsibilities Federal Ministry of Finance, Iin collaboration with the World Bank controls disbursement of funds. 1 Budget and National Program funds will be channeled through the Federal Ministry of Finance. Planning The focal ministry of environmental issues in Nigeria. They will lead in Federal Ministry of implementing environmental actions at the federal level as recommended in 2 Environment (FMEnv) the PAP. They are also responsible for oversight and disclosure regarding EIA at the federal level. ▪ Development and promotion of productive employment policies and The Federal Ministry of 3 programs for employment generation and actualization of national Labor and Employment employment policies of the Federal Government. 36 ▪ Skills Development, upgrading, certification, placement and empowerment of artisans, tradesmen, and applicants in various areas of national needs ▪ Provision of Social Security Coverage, Welfare and Employee’s Compensation to the nation’s workforce ▪ Provision of Labor Protection Services, supervision, enforcement, Education, Promotion of Social Justice, Ratification, Implementation and Review of National Labor Laws and Policies including collective bargained agreements. ▪ Trade Unions Education and Training ▪ International Labor Diplomacy ▪ Promotion of Occupational Safety and Health under the Occupational Safety and Health Department ▪ Enforcement of the Labor Laws under the Inspectorate Department (INSP) Federal Ministry of Women ▪ The focal ministry of social issues in Nigeria. They will lead in implementing 4 Affairs, Community and and monitoring environmental and social actions at the federal level as Social Development recommended in the PAP ▪ The Federal Ministry of Education (FME) is responsible for policy formulation, coordination and management of education at the federal level. It has a mission to “to use education as a tool for fostering the Federal Ministry of development of all Nigerian citizens to their full potentials, in the promotion 5 Education of a strong, democratic, egalitarian, prosperous, indivisible and indissoluble sovereign nation under God”. The ministry in collaboration with its agencies, especially UBEC, is the focal ministry responsible for the Implementation of the education aspects of the Program at the federal level. 4.5.2 State Ministries Relevant to HOPE-Edu PforR 59. The State Ministries whose functions and responsibilities are relevant to the HOPE-Edu PforR is presented in Table 4.5. S/N Ministry Relevant Functions and Responsibilities State Ministry of ▪ In collaboration with the World Bank controls disbursement of funds. Program funds 1 Finance, Budget and will be channeled through the State Ministry of Finance.. Economic Planning The focal ministry of environmental issues at the state level. All the states have a ministry responsible for environmental issues. The will lead in implementing environmental State Ministry of actions at the state level as recommended in the PAP. They are also responsible for 2 Environment (SMEnv) oversight and disclosure regarding EIA at the state level. Some states have environmental protection and waste management agencies responsible for waste management and other environmental protection activities in the states. State Ministry of Women Affairs, ▪ The focal ministry of social issues in states. They will lead in implementing and 3 Community and Social monitoring d social actions at the state level as recommended in the PAP Development ▪ The State Ministries of Education (SME) are responsible for policy formulation and management of education at the state level. Each of the 36 states and FCT has a State Ministry of 4 ministry or department as in the case of FCT, responsible for education. The SME is the Education focal ministry in conjunction with UBEC is responsible for the implementation of the education aspect of the Program at the State level. 4.6 Management of Land Acquisition in Nigeria 60. Land holdings in Nigeria can be broadly classified into public/government, private, and communal. Public/government lands are lands owned by the government comprising federal, state and local governments and their agencies. Private lands are defined as those whose ownership is vested in private individuals, families, and lands under 37 customary tenancies. Communal lands are lands which have their ownership vested in communities. These lands are usually administered by community leaders with the assistance of their councils of elders. 61. The legal basis for land acquisition and resettlement in Nigeria is the Land Use Act of 1978 which was modified in 1990. The critical sections regarding land acquisition are as follows: a) Section 1: Subject to the provision of this Act, all land comprised in the territory of each state in the Federation is hereby vested in the Governor of each state and such land shall be held in trust and administered for the use and common benefit of all Nigerians in accordance with the provision of this Act. b) Section 2: (a) All land in urban areas shall be under the control and management of the Governor of each State, and (b) all other land shall be under the control and management of the local government within the area of jurisdiction in which the land is situated. 62. Therefore, according to the Land Use Act, all land in Nigeria is vested in the Governor of each State and shall be held in trust for the use and common benefit of all people. The administration of land area is divided into urban land which is directly under the control and management of the Governor is each State; and non-urban land, which is under the control and management of the Local Government. The Governor of each State has the right to grant statutory rights of occupancy to any person or any purpose; and the Local Government will have the right to grant customary rights of occupancy to any person or organization for agricultural, residential and other purposes. 4.7 Grievance Redress Mechanism 63. In Nigeria, there are different approaches, (but often specific to issues, institutions involved or projects), to make complaints and get redress. First, the justice system provides for courts where aggrieved persons can seek redress. Also there is the Public Complaints Commission where individuals and groups can lodge complaints against administrative injustice and get redress. Besides, the Ministry of Justice has the Legal Aids Council established under the law (Legal Aids CAP L9, 2011) which provides legal aid and advice to people with low income, among others. Some state governments also have different institutional arrangements for providing free legal services to the poor and vulnerable, for example, Public Defender Law and Multidoor Courthouse Law in Delta State Nigeria; and the Special People’s Law in Lagos State Nigeria. 38 SECTION V: ASSESSMENT OF THE CLIENT’S ENVIRONMENTAL AND SOCIAL MANAGEMENT SYSTEMS 64. This section describes the E&S management systems in place to manage all identified E&S risks associated with the program interventions detailed in Section III, especially adverse impacts and risks. It describes the main elements of applicable client’s systems and provides an analysis of the acceptability of these systems, considering the level of risk and the extent to which Borrower systems and practices are aligned with the World Bank’s 6 core principles on E&S on Performance-for-Results financing. That is, the analysis will show the extent to which the applicable systems are consistent with the core principles and key planning elements expressed in the PforR Guidance Document. It also reviews aspects where gaps exist between the two systems. The assessment was done using the following criteria: a) An analysis of the strengths of the existing environmental and social due diligence system, or where it functions effectively and efficiently and is consistent with Bank Policy and Directive for Program-for-Results Financing; b) Identification of inconsistencies and gaps between the principles espoused in Bank Policy and Directive for Program-for-Results Financing and capacity constraints and gaps in existing capacity; and c) Based on the above findings, recommendations to fill gaps and proposed mitigation measures and actions to strengthen the existing system to ensure environmental and social soundness and long-term sustainability in line with the design and implementation and operation of program interventions across the project areas. 65. The summary of the assessments of Federal Government systems in line with the core principles is presented in section 5.1. Information from this analysis and the resulting identification of gaps and opportunities/actions were used to inform the recommendations presented for the program in terms of managing E&S aspects and have informed the preparation of the Program Action Plan (PAP). 39 5.1: Summary of Systems Assessment Core Principle 1: General Principle of Environmental and Social Management Table 5.1: Assessment Core Principle 1: General Principle of Environmental and Social Management Bank Policy for Program-for-Results Financing: Environmental and social management procedures and processes are designed to (a) promote environmental and social sustainability in Program design; (b) avoid, minimize or mitigate against adverse impacts; and (c) promote informed decision-making relating to a program’s Bank Directive for Program-for-Results Financing: Program procedures will: ▪ Operate within an adequate legal and regulatory framework to guide environmental and social impact assessments at the program level. ▪ Incorporate recognized elements of environmental and social assessment good practice, including: ▪ early screening of potential effects; ▪ consideration of strategic, technical, and site alternatives (including the “no action” alternative); ▪ explicit assessment of potential induced, cumulative, and trans-boundary impacts; ▪ identification of measures to mitigate adverse environmental or social impacts that cannot be otherwise avoided or minimized; ▪ clear articulation of institutional responsibilities and resources to support implementation of plans; and ▪ Responsiveness and accountability through stakeholder consultation, timely dissemination of program information, and responsive grievance redress measures. Applicability: YES / NO The E&S team has conducted a screening of initial risks of the PforR. Environmental and social risks are posed due to ensuring the availability of essential teaching-learning materials (DLI1) ensure fidelity of the structured pedagogy (DLI3), increased access to quality pre-primary education (DLI4), and increased access to primary education (DLI5) , promote literacy and numeracy programs through non-formal basic education (DLI6) and enhanced availability of information for education system management (DLI8). Suggestions to Fill Gaps/Proposed Applicable RA/DLIs Systems Assessment Gaps Mitigation Measures FEDERAL LEVEL  Support should be provided at specific FEDERAL LEVEL DLI 1: Number of schools project levels and a technical assistance  At the Federal level, National Policies, Acts, with sufficient TLMs for  The EIA Act only focuses on the environmental component be used to fill capacity gaps Regulations for environmental management as literacy and numeracy DLI3: standards. The World Bank standards on social and establish E&S risk management well as institutional system’s identifying Percentage of children issues is not addressed by the EIA particularly systems. environment procedures, roles and legislation to proficient in literacy and requirements on stakeholder engagement, labor,  There is also a need to strengthen the be followed in the country (See Chapter 4) are numeracy. DLI 4: Number of resettlement and land acquisition or ecosystem E&S capacity at the agencies, especially well defined and are consistent with Core new primary classrooms services. UBEC, responsible for the program Principle 1 of the Bank Policy and Directives on  At the national level there is no direct/ single implementation at the federal level. created through community PforR Operation. ministry that is responsible for the totality of the  There is a need to strengthen the E&S participation.  The national EIA system (EIA Act No. 86 of 1992) social sustainability components, that is required management capacities of the Federal provides a comprehensive legal and regulatory by the World Bank Standards. What we have are Government in terms of management of framework for environmental and social impact 40 DLI 5: Number of children assessment that is broadly consistent with the isolated ministries performing isolated roles e-waste, and provision of adequate who complete NFBE Core Principle 1 of the Bank Policy and Directive. related to social concerns. See Chapter 4. skilled human resources. program.  Environmental Assessment (EA) Department of  There is no requirement for consulting with local  Need to strengthen the capacities of the the Federal Ministry of Environment is communities or vulnerable people in EIA process. E&S officers that will be involved in the responsible for ensuring that the environmental  The capacity of the ministry and responsible program. risks are assessed, and adequate measures are agency to monitor and enforce environmental DLI8: Percentage of schools taken to mitigate and or manage potential assessments is weak.  Need for e-waste management included in current-year project impacts in line with the Federal Republic  procedure for the program to ensure that Annual School Census report. of Nigerian EIA Act of 1992. e-waste disposal is well covered under  E-waste regulation compels all the Program. manufacturers and importers of electrical equipment, e-waste collection centres, and STATE LEVEL recycling facilities to register with the E-  There are weak infrastructural and human waste Producer Responsibility Organization resources capacities in delivering a robust ESIA Nigeria (EPRON) process at the State level  There is a need to strengthen the E&S  NESREA is also empowered to enforce non-  The State environment ministries have weak management capacities of the states compliance with environmental laws and capacities and mirror gaps in the federal involved in terms of OHS, and provision of regulations. environmental regulation and laws adequate skilled human resources to  The corresponding ministries to E&S thematic tackle E&S issues especially at SUBEB. STATE LEVEL areas at the state level do not interface well with the Ministry of Education and Health. o Most States in the federation have their own state environment Ministry or agency. o Most of the sample states have robust framework regarding environmental assessment and management, for example, Delta State has environmental sanitation law, ecology law and waste management law. Lagos State has environmental protection law, etc. o States also have strong coordination with Federal Ministry of Environment and NESREA. 41 Core Principle 2: Natural Habitats and Physical Cultural Resources Table 5.2: Assessment Core Principle 2: Natural Habitats and Physical Cultural Resources Bank Policy for Program-for-Results Financing: Environmental and social management procedures and processes are designed to avoid, minimize and mitigate against adverse effects on natural habitats and physical cultural resources resulting from program. Bank Directive for Program-for-Results Financing: As relevant, the program to be supported: ▪ Includes appropriate measures for early identification and screening of potentially important biodiversity and cultural resource areas. ▪ Supports and promotes the conservation, maintenance, and rehabilitation of natural habitats; avoids the significant conversion or degradation of critical natural habitats, and if avoiding the significant conversion of natural habitats is not technically feasible, includes measures to mitigate or offset impacts or program activities. ▪ Takes into account potential adverse effects on physical cultural property and, as warranted, provides adequate measures to avoid, minimize, or mitigate such effects Applicability: YES / NO It is t expected that the Program will have any impact on natural habitats and physical cultural resources since it will involve new construction as twelve thousand new primary school classrooms will be constructed. Suggestions to Fill Gaps/Proposed Applicable DLIs Systems Assessment Gaps Mitigation Measures FEDERAL LEVEL FEDERAL LEVEL  The federal and state governments should update their forest laws to o The Government of Nigeria also has o Most of the forest laws and edits reflect current realities. introduced a number of forest policies, are old and outdated even dating  Federal and State UBEC should ensure programmes and instruments (e.g., the back to colonial times and needs to that new primary school classrooms are National Forest Policy 2006 revised in 2020, be updated. not established in community forests or DLI 4: Number of new primary sacred groves and important National Biodiversity Strategy and Action o Although strategies were classrooms created through community biodiversity sites in the communities. Plan, Nigeria REDD+ Strategy) in an effort to developed, the have not been participation  . reverse the deforestation trend and operationalized. facilitate natural resources management and biodiversity conservation STATE LEVEL DLI 5: Number of children who complete STATE LEVEL  Most of the state forest laws and edits NFBE program are old and outdated even dating back  Most of the State Governments have forest to colonial times and needs to be commissions or forest departments in their updated. Ministry of Environment that are  Most states have not implemented responsible for forest management and community forestry initiatives thus, biodiversity conservation. most communities rarely conserve  their forest resources 42 Core Principle 3: Public and Worker Safety Table 5.3: Assessment Core Principle 3: Public and Worker Safety Bank Policy for Program-for-Results Financing: Environmental and social management procedures and processes are designed to protect public and worker safety against the potential risks associated with (a) construction and/or operations of facilities or other operational practices developed or promoted under the program; (b) exposure to toxic chemicals, hazardous wastes, and otherwise dangerous materials; and (c) reconstruction or rehabilitation of infrastructure located in areas prone to natural hazards. Bank Directive for Program-for-Results Financing: ▪ Promotes community, individual, and worker safety through the safe design, construction, operation, and maintenance of physical infrastructure, or in carrying out activities that may be dependent on such infrastructure with safety measures, inspections, or remedial works incorporated as needed. ▪ Promotes use of recognized good practice in the production, management, storage, transport, and disposal of hazardous materials generated through program construction or operations; and promotes use of integrated pest management practices to manage or reduce pests or disease vectors; and provides training for workers involved in the production, procurement, storage, transport, use, and disposal of hazardous chemicals in accordance with international guidelines and conventions. ▪ Includes measures to avoid, minimize, or mitigate community, individual, and worker risks when program activities are located within areas prone to natural hazards such as floods, hurricanes, earthquakes, or other severe weather or climate events. Applicability: YES / NO It is expected that the Program will have impact on pubic and worker safety since it may involve construction, rehabilitation and expansion of classrooms through increased access to quality pre-primary education (DLI4) and increased access to primary education (DLI5). Suggestions to Fill Gaps/Proposed Applicable DLIs Systems Assessment Gaps Mitigation Measures FEDERAL LEVEL FEDERAL LEVEL  The Federal Ministry of Environment should work towards improving the EIA DLI 4: Number of new primary classrooms  The legal/regulatory system of the  The national EIA system does not system to incorporate important created through community participation country includes provisions for protecting comprehensively encompass aspects of aspects lacking in the system, for worker, community and public safety. public and worker safety. example, issues relating to public and Some of these include, Labour Act of  There is limited awareness by the workers’ safety and broader ESHS. 2004, the Trade Union Amended Act of general public, especially farmers, on Meanwhile, they should ensure that DLI 5: Number of children who complete 2005, and the Employees Compensation public health and safety issues, EIA reports submitted for review cover NFBE program Act of 2010. See Table III.5 particularly in relation to exposure to social issues especially relating to  NESREA has regulations to protect the hazardous materials, fertilizers and public and worker safety. public from hazardous chemicals, pesticide handling and safety  States and Federal Ministry of pesticides, and agrochemicals (National precautions. Environment, States and Federal 43 Environmental (Hazardous Chemicals and  Lack of awareness of relevant Ministry of Labour and States and Pesticides) Regulations, S.I. No 65, 2014). authorities’ staff to appreciate the need Federal Ministry of Education should  The country also has some legal statutes to ensure occupational health and collaborate and build the capacity of and provisions to protect workers. Some safety. The FME have little experience the leaders in the different institutions of these include, Labour Act of 2004, the in OHS in a project environment. in the sector in order for them to Trade Union Amended Act of 2005, and  The enforcement of national labor laws become knowledgeable on issues the Employees Compensation Act of is weak. relating to occupational health and 2010.  The national EA Department of the hazard and how to deal prevent and  The federal government has the Ministry FMEnv and NESREA have not deal with it. of Labor and their responsibilities include comprehensively incorporated OHS  State governments should ensure that the protection of the rights of workers. management into civil works. government and employers of labour in  The Federal Child’s Right Act (CRA) (2003) the state enroll or cover their workers codifies the rights of children in Nigeria. It under the Workers Compensation has penalties on the use of child labour STATE LEVEL Insurance.  The Nigerian Labor Law requires  Provide on-site training to workers and  Some States lack OHS guidelines and compliance with all national and laborers that will be involved in international labor laws on occupational procedures to be adopted by construction, rehabilitation and health and safety. The law requires contractors, firms (especially MSEs), classroom expansion so that they will routine inspection of workplaces, employers of labour and workers in be familiar with OHS issues at their accident investigation, preparation of most of the States workplace.  Lack of awareness of relevant safety and health regulations, code of  Provide training supply chain practice, guidelines and standards for authorities’ staff to appreciate the need laborers/employers various operations, processes and to ensure occupational health and  State governments should ensure that hazards. safety. contractors, and other employers of  There is limited awareness and lack of labour especially those involving interest by the general public, on public construction, rehabilitation, and waste STATE LEVEL health and safety issues, management provide personal  Inadequate awareness of relevant protective equipment for their  Most state governments also have authorities’ staff to appreciate the need workers. Ministries of Labor and these ministries to ensure OHS.  Ensure that all workers engaged under also work to protect the rights of workers medical waste collection are provided at the state level. with a relevant personal protective and  Some of the states have standalone laws safety equipment. and regulations to protect the rights of  Put in place a Grievance redress children and workers, e.g. Plateau State mechanism to handle workers conflicts. Child’s Right Law 2005 was gazette in the  State governments should ensure that state in 2017. first aid facilities are provided in  schools. 44 Core Principle 4: Land Acquisition Table 5.4: Assessment Core Principle 4: Land Acquisition Bank Policy for Program-for-Results Financing: Land acquisition and loss of access to natural resources are managed in a way that avoids or minimizes displacement, and affected people are assisted in improving, or at least restoring, their livelihoods and living standards. Bank Directive for Program-for-Results Financing: As relevant, the program to be supported: ▪ Avoids or minimizes land acquisition and related adverse impacts; ▪ Identifies and addresses economic and social impacts caused by land acquisition or loss of access to natural resources, including those affecting people who may lack full legal rights to assets or resources they use or occupy; ▪ Provides compensation sufficient to purchase replacement assets of equivalent value and to meet any necessary transitional expenses, paid prior to taking of land or restricting access; ▪ Provides supplemental livelihood improvement or restoration measures if taking of land causes loss of income-generating opportunity (e.g., loss of crop production or employment); and ▪ Restores or replaces public infrastructure and community services that may be adversely affected. Applicability: YES / NO The Program could involve land acquisition for the civil works including construction and expansion of classrooms for increased access to quality pre-primary education (DLI∞) and increased access to primary education (DLI6). Suggestions to Fill Gaps/Proposed Applicable DLIs Systems Assessment Gaps Mitigation Measures DLI 4: Number of FDERAL LEVEL  The Land Use Act vests the Governor of a state with the  There is need for each state to new primary control and management of urban lands while the non-urban establish a framework/protocol for classrooms created  Nigeria has the Land Use Act of 1978 lands are under the control of the local government. Given voluntary land donation under the through community which was modified in 1990 is the legal this, the Act does not provide for equitable resettlement of program. participation basis of land acquisition and land owners when taken over by government for possible use administration but doesn’t include based on what the Act refers to as overriding public interest. anything with regards land donation  Although community members can freely donate their lands DLI 5: Number of STATE LEVEL under customary practices, there is no provision for voluntary children who land donation in the Land Use Act. complete NFBE  States have Ministry of Land responsible program for land acquisition, and documentation  Given that there is no framework or legislation regarding including issuing of right of occupancy voluntary land donation, there could be coercion for land and certificates of occupancy. In some donation leading to impoverishment of the people. states, the process has been digitized. 45 Core Principle 5: Social Considerations - Indigenous Peoples and Vulnerable Groups Table 5.5: Assessment Core Principle 5: Social Considerations - Indigenous Peoples and Vulnerable Groups Bank Policy for Program-for-Results Financing: Due consideration is given to cultural appropriateness of, and equitable access to, program benefits giving special attention to rights and interests of Indigenous Peoples and to the needs or concerns of vulnerable groups. Bank Directive for Program-for-Results Financing: • Undertakes free, prior, and informed consultations if Indigenous Peoples are potentially affected (positively or negatively) to determine whether there is broad community support for the program. • Ensures that Indigenous Peoples can participate in devising opportunities to benefit from exploitation of customary resources or indigenous knowledge, the latter (indigenous knowledge) to include the consent of the Indigenous Peoples. • Gives attention to groups vulnerable to hardship or disadvantage, including as relevant the poor, the disabled, women and children, the elderly, or marginalized ethnic groups. If necessary, special measures are taken to promote equitable access to program benefits. Applicability: YES / NO It is expected that vulnerable people may be impacted through discrimination based on gender and disability, ethnic bias, complaints given that the Program will involve recruitment and hiring of teachers and instructors in NFLC (DLI 3, 4 and 5). Note that there are no groups in Nigeria that meet the World Bank's criteria for Indigenous Peoples. However, we followed the third point on Bank Directive for indigenous peoples and vulnerable groups to look at the systems that address the needs of groups vulnerable to hardships, including women, youths and people with disabilities. The applicability in terms of specific DLIs is indicated below. Suggestions to Fill Gaps/Proposed Mitigation Applicable DLIs Systems Assessment Gaps Measures DLI 1: Number of schools with FDERAL LEVEL FFEDERAL LEVEL  Deliberate efforts to strengthen multi-agency sufficient TLMs for literacy and coordination e.g. between the National numeracy  Chapter IV of the Nigerian Constitution  There is a serious lack of trust in government Orientation Agency, Federal Ministry of contains a variety of fundamental rights set and government ministries and agencies Information and Culture and the Federal DLI2: Number of primary out in Sections 33 - 44. of particular responsible for effective communication and Ministries of Women Affairs and Social teachers with improved relevance is Section 42, which prohibits engaging with the people, for example, the Development to facilitate effective structured pedagogy practices. discrimination on the grounds of ethnic National Orientation Agency, Federal Ministry of communication of government policies to the origin, sex (gender), religion, or linguistic Information and Culture and the Federal citizens, build trust in government and to affiliation. Ministries of Women Affairs and Social strengthen the social contract, such as actions  There is a Federal Ministry of Women Development lack the requisite capacity and to tackle corruption and improve the delivery DLI 4: Number of new primary Affairs and Social Development that deals trust to build social contract. of services. Although these agencies are not classrooms created through with all gender related issues especially as  There is lack of information and weak directly involved in the implementation of community participation it concerns the vulnerable especially knowledge of the public especially vulnerable HOPE. women youths and People living with groups regarding the issues relating to the 46 Disabilities (PWDs). They have a unit that economy, the need for effective tax system and deals with GBV and discrimination. payment of tax and the benefits of petroleum  There is also a need to strengthen the DLI 5: Number of children who subsidy removal. capacities of the technical staff of these complete NFBE program  There is weak of capacity in Ministries of agencies to enhance communication of  The Federal Ministry of Information and Women Affairs and Social Development to government programs and build trust with the Culture has some institutions and agencies tackle the issues of GBV and other issues relating citizens. under it, for example, Radio Nigeria, to gender and youths  States without Gender Policy should set in Nigeria Television Authority and the motion the process of developing their gender National Orientation Agency that are policy which will contain guidelines and responsible for communicating  There is no coordinated strategy for processes of preventing discrimination against government programs and building trust implementing a broad social inclusion agenda vulnerable groups and PWDs. with citizens. across public services in Nigeria.  States without a gender-based violence STATE LEVEL response team should quickly set up Domestic and Gender-based (Sexual) Violence Response  Also, most state governments have STATE LEVEL Team (DSVRT) to for quick response to issues Ministry of Women Affairs/Gender Affairs of GBV in the states. and Social Development. These ministries  Many States are yet to adopt the Violence Against Persons (Prohibition) Law.  Sates should carryout regular enlightenment help to address the issues of GBV and discriminations of vulnerable people. programs for the public and capacity building  Many states do not have adequate framework programs for staff of gender/women Specifically, the Law in Ekiti State provides and institutional arrangement for combating ministries. welfare package (cash/in-kind) to the GBV or prosecuting and punishing those elderly. involved in GBV thus offenders often do not get  The program's implementing agencies should punished. ensure that there is no discrimination in the  Many States have robust legal framework recruitment of teachers and also put in place for Gender considerations, youths’ affairs  Many of the states do not have policy to ensure an effective GRM to ensure that people’s and social exclusions and discrimination. inclusion of minority/ ethnic groups at local level complaints, especially regarding recruitment,  Many states have laws and frameworks in or the extreme poor in programs are addressed effectively. . dealing with violence and discrimination while some states, in addition, some have  Also, many of the States do not have gender response teams to deal with GBV for policy or guidelines for dealing with vulnerable  example Kaduna State GBV Response people and PWDs to ensure that they are not Team. treated with contempt and partiality  Few States have adopted the Violence  against persons Law, e.g Kaduna State (adopted in 2018) and Ekiti State (adopted in 2019) 47 Core Principle 6: Social Conflict Table 5.6: Assessment Core Principle 6: Social Conflict Bank Policy for Program-for-Results Financing: Avoid exacerbating social conflict, especially in fragile states, post-conflict areas, or areas subject to territorial disputes. • Bank Directive for Program-for-Results Financing: Considers conflict risks, including distributional equity and cultural sensitivities. Applicability: YES / No Armed conflicts are not expected during the implementation of the Program, however, there could be disagreements, complaints, demonstrations and grievances may arise during the Program implementation due to lopsided or biased recruitment and deployment of teachers and possible conflict in land acquisition for construction and expansion of classrooms. Suggestions to Fill Gaps/Proposed Applicable DLIs Systems Assessment Gaps Mitigation Measures DLI 4: Number of new primary classrooms FEDERAL LEVEL  Strengthened stakeholder engagement created through community participation FEDERAL LEVEL and grievance redress mechanisms and  The constitution of the Federal Republic of increased transparency to provide Nigeria 1999 (as amended) provides in  Lack of a Grievance Redress information and communication Section 17 (3) (g) that “the State shall direct Mechanism (GRM) for the poor and avenues for complaints and their DLI 5: Number of children who complete its policy towards ensuring that provision is vulnerable. Although Nigeria has a resolutions. NFBE program made for public assistance in deserving cases, justice system with courts where  Build social contract with the people to or other conditions of need. people can seek justice, poor and facilitate success of proposed reforms.  Federal throughout the country with well- vulnerable people do not have the  States without a framework to provide trained police and security forces who capacity to seek justice in courts. free legal services/legal aid and advice maintain the rule of law and also provides  The available GRM are weak and ad- to the citizens should work towards security against bandits and other forms of hoc and not properly providing that. violent crimes and attacks. institutionalized. This is a need to  The military also provides security against ensure that people’s grievances are  States without an agency responsible armed insurgency and terrorism. properly redressed even when there for grievance redress and peaceful  There is also a justice system with courts is need to seek further redress if the resolution of disputes should make where people can seek redress. individual is not satisfied with the effort to provide one.  The federal government also has the public outcome of existing arrangements. complaints commission where people can   States should strengthen their GRM to make complaints regarding administrative STATE LEVEL facilitate resolution of conflicts. injustices.   48 STATE LEVEL  Most of the states do not have a GRM where poor and vulnerable can  State presence is strong throughout the make complaints and get redress. country with well-trained police and security  Although some states have ways of forces who maintain the rule of law and also settling grievances, these provides security against bandits and during arrangements are ad-hoc and needs clashes between farmers and herders. There to be properly institutionalized. is also a justice system with courts where  Available GRM frameworks are not people can seek redress. formalized and not well recognized.   Some state government also have different  Most of the states do not have GRM institutional arrangements, e.g. Multidoor Courthouse Law and Public defender Law in mechanisms where poor and Delta State. vulnerable can make complaints and get redress.  49 SECTION VI: PROGRAM ACTION PLAN (PAP) AND RECOMMENDATIONS 66. This section recommends measures that will be taken to strengthen system performance in line with the gaps and risks identified in section iv of the system assessment section to ensure that the Program interventions are aligned with the Core Principles 1, 3, 4, 5 and 6 of Bank Policy for Program-for-Results financing as stated below: a) Core Principle 1: General Principle of Environmental and Social Management: b) Core Principle 3: Public and Worker Safety c) Core Principle 4: Land Acquisition d) Core Principle 5: Social Considerations - Indigenous Peoples and Vulnerable Groups: e) Core Principle 6: Social Conflict. 67. These actions may be further refined and adjusted during the consultation process and the implementation of the Program. 6.1 Environmental Summary and Recommendations 68. Although Nigeria has a well-defined environmental system that is close to the core principle of environmental assessment, some gaps remain. For example, the monitoring of EIA implementation is weak, as there is no tracking system to monitor environmental and social risks and performance. At the State and local levels, there is a weak capacity to deliver a robust environmental assessment process. OHS framework is also lacking, especially in schools. There is equally weak monitoring and evaluation of environmental and social systems at the state level, and enforcement is weak. 69. Given the environmental impact of this project, some recommendations are made as follows: e) Strengthening the E&S capacity under the project is needed. To facilitate this, E&S specialists should be recruited and trained for the Program. f) E-waste waste management strategies must also be developed specifically for the program to facilitate their management. The requirements for e-waste management and EPRON should be included in the bidding document under HOPE-Edu PforR. g) Also, E&S management procedures and requirements should be included in the documents for the procurement of civil works, materials and school expansion. h) There is a need to develop an environmental management strategy or manual and OHS guidelines for schools. 6.2 Social Summary and Recommendations 70. Given the identified social issues and weaknesses in the federal system, the following recommendations are made: a) Ensure that the recruitment of teachers and health workers to reduce the staffing gap and application of mechanisms to reduce absenteeism are carried out transparently to avoid ethnic or religious bias. Also, there is a need to ensure gender inclusion in the recruitment, deployment and management of teachers and health personnel. b) Ensure a select number of teachers are trained on environmental management and safety in the school environment. c) Establish a robust grievance redress mechanism specific to the Program to ensure that complaints from different stakeholders are well addressed. 50 d) Strengthen provisions regarding gender-based violence (GBV) prevention and response, including clear protocols for identifying, reporting, and addressing instances of GBV within the school environment. This will include reviewing and, where appropriate, updating the Code of Conduct for education officers, teaching and non- teaching staff in the education sector. e) Develop guidelines and implement guidelines to make school accessible for vulnerable children, including those with disabilities, nomadic, IDPs, and ethnic considerations. f) Implement a whole-school approach to make schools safer for learning. g) Develop a land donation protocol for donating community land to be used for the construction and classroom expansion. 71. Following the recommendations, the breakdown of actions to be included in the Program Action Plan (PAP) with indicative timeline, responsibility for implementation and indicators for measuring the completion of such actions are detailed in the Table 6.1 below. Table 6.1: Program Action Plan (PAP) s/n Action Description Due Date Responsible Party Completion Measurement 1 Dedicate officials Prior to UBEC, National Inclusion of the listed responsible for Effectiveness Program Steering specialist in the team and ensuring E&S PAP Committee (NPSC), maintained throughout the implementation National Program Program implementation, and Coordinator (NPC), Training Module and National Deputy Implementation Support Program Coordinator Supervision Report of World (NDPC) Bank Task team 2 Hire qualified No later than 3 SUBEC, State Program Assist the E&S PAP Environmental and months after Steering Committee implementation official to Social Officers and effectiveness (SPSC), State Program execute the above provide capacity (will be Coordinator (SPC), responsibilities. building/system- reported during State Deputy Program strengthening the first mission Coordinator (SDPC) program to ISR) strengthen their skills 3 Develop e-waste Within one year UBEC, NPSC, NPC, E-waste and healthcare waste management of effectiveness NDPC, SUBEC, SPSC, management strategy strategies for or before the SPC, and SDPC document. managing e-waste first bidding result from the document for program equipment procurement, whichever is earlier. 4 Strengthen Within one year SUBEC, State Program School management provisions on of effectiveness Steering Committee guidelines to include gender-based (SPSC), State Program provisions on GBV prevention 51 s/n Action Description Due Date Responsible Party Completion Measurement violence (GBV) Coordinator (SPC), and response prevention and State Deputy Program response in the Coordinator (SDPC), school management Ministry of Education, Code on Conduct is reviewed guidelines, including Teachers Training, and updated for GBV clear protocols for Civil Service prevention where necessary identifying, Commission and reporting, and Teaching Service addressing instances Commission, the of GBV within the Teachers Registration school environment. Council of Nigeria This will include (TRCN). reviewing and, where appropriate, updating the Code of Conduct for education officers, teaching and non- teaching staff in the education sector. 5 Develop a GRM Within one year UBEC, NPSC, NPC, Copies of GRM outlining specific to the of effectiveness NDPC, SUBEC, SPSC, details of implementation Program SPC, and SDPC 6 Develop guidelines Within two UBEC, NPSC, NPC, Guidelines developed and and implement a years of NDPC, SUBEC, SPSC, under implementation whole school effectiveness SPC, and SDPC approach to make school accessible for vulnerable children, including those with disabilities, nomadic, IDPs, and ethnic considerations. 7 Develop a community Prior to SUBEC, SPSC, SPC, and Copies of land donation land donation Effectiveness SDPC protocol outlining details of protocol specifically implementation for the Program. 52 SECTION VII. SUPPORTING ANNEXES AND REFERENCE DOCUMENTS Annex 1: Applicability of Core Environmental and Social Principles (CP) to the HOPE-Edu Program Result Area and Disbursement Linked Indicators (DLIs) CP3 CP4 CP5 CP1 CP2 CP6 Result Area DLI Public & Worker Land Vulnerable Environment Natural Habitats groups Social Conflict Safety Acquisition RA 1: Improving DLI 1: Number of Applicable as the Not Applicable Not Applicable Not Applicable Applicable as Not Applicable Quality schools with DLI will involve the vulnerable sufficient TLMs for printing and people may literacy and distribution of be numeracy books which may discriminated impact on the against in the environment distribution through the forest and use of destruction given TLMs the use of wood in paper production. DLI 2: Number of Not Applicable, Not Applicable Not Applicable Not Applicable Applicable as Not applicable. primary teachers device (including works supported vulnerable with improved the lesson plans and by the DLI people may structured pedagogy other materials), be practices (SPP) which will be linked discriminated to a computer back- against in end platform. training of teachers in SPP. 53 CP3 CP4 CP5 CP1 CP2 CP6 Result Area DLI Public & Worker Land Vulnerable Environment Natural Habitats groups Social Conflict Safety Acquisition DLI3: Percentage of Applicable, as there Not Applicable Not Applicable as Not Applicable This is not Not Applicable children proficient in could be e-waste as there are no there are as there are no applicable literacy and given possible use of physical works construction and physical works numeracy of digital devices for supported by rehabilitation supported by evaluating of the DLI works supported the DLI learning in literacy by the DLI. and numeracy. RA 2: Increasing DLI4: Number of This is Applicable as This is This is applicable This is This is Social conflict as access. new primary there are applicable as as procurement applicable as applicable as envisaged by classrooms created procurement of civil civil works of civil works, there could be the hiring of ESSA especially through community works, construction procurement construction land acquisition qualified regarding armed participation and expansion of and activities may in communities teachers may conflict is not classrooms construction impact public to facilitate be biased applicable. supported by the may impact and workers construction against However, there DLI natural habitats. health and and expansion vulnerable could be safety. of classrooms. people conflicts over especially land acquisition women. and in the hiring of qualified teachers. DLI 5: Number of This is Applicable as This is This is applicable This is This is Social conflict as children who there are applicable as as procurement applicable as applicable as envisaged by procurement of civil civil works of civil works, there could be the hiring of ESSA especially works, construction procurement construction and land acquisition instructors for regarding armed 54 CP3 CP4 CP5 CP1 CP2 CP6 Result Area DLI Public & Worker Land Vulnerable Environment Natural Habitats groups Social Conflict Safety Acquisition complete NFBE and expansion of and rehabilitation in communities NFLCs may be conflict is not program classrooms for construction activities may to facilitate biased against applicable. NFLCs supported by may impact impact public construction vulnerable However, there the DLI natural habitats and workers and expansion people could be health and safety of classrooms especially conflicts over able women. Risk the hiring and of exclusion training of of Persons instructors for with NFLC. Disabilities. RA 3: Enhancing DLI6: Percentage of Not Applicable as Not Applicable Not Applicable as Not Applicable Not Not Applicable key systems core UBE funds there are no as there are no there are no as there are no Applicable as as there are no managed at physical works physical works physical works physical works there are no physical works decentralized level supported by the supported by supported by the supported by physical supported by DLI the DLI DLI the DLI works the DLI supported by the DLI DLI7: Percentage of Not Applicable as Not Applicable Not Applicable as Not Applicable Not Not Applicable public primary there are no as there are no there are no as there are no Applicable as schools using annual physical works physical works physical works physical works there are no school grant supported by the supported by supported by the supported by physical DLI the DLI DLI the DLI works supported by the DLI 55 CP3 CP4 CP5 CP1 CP2 CP6 Result Area DLI Public & Worker Land Vulnerable Environment Natural Habitats groups Social Conflict Safety Acquisition DLI8: Percentage of Applicable, as there Not Applicable Not Applicable as Not Applicable Not Not Applicable schools included in could be e-waste as there are no there are no as there are no Applicable as as there are no current-year Annual due to digitization physical works physical works physical works there are no physical works School Census report of annual school supported by supported by the supported by physical supported by census (ASC) the DLI DLI the DLI works the DLI database and digital supported by publication of the DLI statistical report 56 Annex 2: Key Environmental & Social Risks and Benefits Associated with Program Activities Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits 1: Improve quality 1. Number of Negligible The delivery of The delivery of teacher Potential exclusion schools with essential teaching- guides (lesson plans if textbooks or sufficient TLMs for learning materials and other material) learning materials literacy and (TLMs) associated and text books in are not accessible numeracy with this DLI will literacy and involve printing mathematics and the textbooks, training of teachers on especially to these materials under facilitate literacy this DLI will result in and mathematics. increased enrollment This will consume a in basic education, large amount of reduction in OOSC, paper, thus improved literacy and impacting forests numeracy, enhanced and trees used to performance of pupils manufacture and students in basic paper. The education. digitization of the learning packages could reduce this. 2. Number of Negligible Negligible .Negligible primary teachers 57 Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits with improved The building of Grades structured 1-3 teacher capacity to pedagogy effectively use the practices (SPP) teaching-learning materials and apply the structured pedagogical approach for literacy and numeracy will result in increased enrollment in basic education, reduction in OOSC, improved literacy and numeracy, enhanced performance of pupils and students in basic education, thus enhancing education outcome and subsequent poverty reduction and economic development impact. DLI 3: Percentage Negligible The evaluations of Negligible of children learning in literacy and proficient in numeracy for Grades 1 literacy and and 2 could be done using numeracy digital devises and thus may lead to the generation of e-waste. 58 Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits RA 2: Increasing 4. Number of new Negligible The construction and The establishment of The establishment of Access. primary classrooms establishment of new public primary classrooms by created through classroom is associated classrooms and will communities especially community participation with significant direct and enhance access to for NFLC could indirect environmental education by people potentially impact risks such as solid waste without access to workers' health and generation, noise, land degradation, air pollution education, guarantee safety The workers and destruction of flora that qualified and may be exposed to and fauna, which could competent teachers are pollution caused by lead to biodiversity loss available in pre-primary dust and noise at the and primary schools in work site. There could rural communities thus also be child labour increasing enrollment of issues, influx of pupils in schools, workers to the reduction in OOSC, and communities where improved literacy and rehabilitation work will numeracy of pupils in occur. This may affect pre-primary and primary the communities as education. there could be cases of sexual abuse and other vices, for example, drug abuse. There could be potential exclusion and discrimination of vulnerable 59 Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits groups, ethnic considerations and sexual abuse or harassment of children and women in the hiring of qualified teachers. Discrimination along the lines of ethnicity and religion in the recruitment and hiring of teachers can result in complaints, social unrest and demonstrations. In addition, the acquisition of land for construction and expansion of classrooms in communities could result in conflict among community members. 5. Number of children Negligible The construction and The establishment of The establishment of who complete NFBE establishment of new public primary classrooms by program classroom is associated classrooms and will communities especially with significant direct and enhance access to for NFLC could indirect environmental 60 Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits risks such as solid waste education by people potentially impact generation, noise, land without access to workers' health and degradation, air pollution education, guarantee safety The workers and destruction of flora that qualified and may be exposed to and fauna, which could competent teachers are pollution caused by lead to biodiversity loss available in pre-primary dust and noise at the and primary schools in work site. There could rural communities thus also be child labour increasing enrollment of issues, influx of pupils in schools, workers to the reduction in OOSC, and communities where improved literacy and rehabilitation work will numeracy of pupils in occur. This may affect pre-primary and primary the communities as education there could be cases of sexual abuse and other vices, for example, drug abuse. There could be potential exclusion and discrimination of vulnerable groups, ethnic considerations and sexual abuse or harassment of 61 Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits children and women in the hiring of qualified teachers. Discrimination along the lines of ethnicity and religion in the recruitment and hiring of teachers can result in complaints, social unrest and demonstrations. In addition, the acquisition of land for construction and expansion of classrooms in communities could result in conflict among community members. Result Area 3: DLI 6: Percentage of Environment Negligible Achievingthis DLI will The constitution of the Enhancing key core UBE funds benefits will acre ensure that schools School-Based systems managed at through the use of receive and properly Management decentralized level school-based manage school grants, Committee (SBMC) management which will, in turn, and the disbursement 62 Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits grants for cleaning encourage school of grants and school- and maintaining attendance, particularly based management of school premises. for children who have grants may potentially dropped out or are at risk be open to corruption of dropping out, and and mismanagement enable school of funds, management to purchase notwithstanding the materials for teaching- recommendation that learning purposes. This a bank account should will ultimately reduce the be used for number of OOSCs and transparent improve the literacy and management. numeracy of pupils in Also, there could be primary education. discrimination of vulnerable people in the Also, ensuring that school use and management of the grants. management committees are well constituted and own bank or other financial accounts that can be accessed and managed transparently will equally facilitate financial inclusion in Nigeria DLI7: Percentage of Environment Negligible Achieving this DLI will The constitution of the public primary schools benefits will acre ensure that schools School-Based using annual school through the use of receive and properly Management grant 63 Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits school-based manage school grants, Committee (SBMC) management which will, in turn, and the disbursement grants for encourage school of grants and school- cleaning and attendance, particularly based management of maintaining for children who have grants may potentially school premises. dropped out or are at risk be open to corruption of dropping out, and and mismanagement enable school of funds, management to purchase notwithstanding the materials for teaching- recommendation that learning purposes. This a bank account should will ultimately reduce the be used for number of OOSCs and transparent improve the literacy and management. numeracy of pupils in primary education. Also, there could be discrimination of Also, ensuring that school vulnerable people in the use and management of management committees the grants. are well constituted and own bank or other financial accounts that can be accessed and managed transparently will equally facilitate financial inclusion in Nigeria 64 Result DLIs Environmental Environmental Risks Social Benefits Social Risks Areas Benefits DLI 8: Percentage of Negligible The digitization of Enhancing the availability Negligible schools included in annual school census of information for current-year Annual and data collection and education system School Census report transmission could management, especially result in the generation through digitizing annual of waste from electrical school census and electronic equipment school-based data (WEEE) or e-waste. collection and transmission will facilitate the availability of data for basic education management in the states and Nigeria. Effective management of basic education will facilitate improved education outcomes, reduction in unemployment, and enhanced economic development. 65 Annex 3: Attendance at Stakeholder Consultation Held on December 5, 2024 Name Organization Designation State Felicia Vanessa Ango SUBEB DPRS Kebbi Hussaina Bello UBEB Principal Project FCT Officer Tracy Onabis Inclusive Friends Association (IFA) Program Officer FCT (Inclusive Education) Obanla Akindele SUBEB M&E Officer Lagos Inyingi Irimagha Gender and Development Action Senior Programme Lagos Officer Florence Nene Ugwu PAV Southeast Regional Rep Maina Tata Adams SUBEB Gombe Agbo Christian Obiora The Qualitative Magazine ED (Editor) Oluwakemi Odusanya Andrew Orlando BudgIT Foundation with PAV Stakeholder Manager Oaikhena Greg Chijioke Partnership Amplified Voices (PAV), Anyaegbudike a society partnership that supports accountability and social inclusion in Nigeria, with significant support from the World Bank Vahyala Kwaga Florence Jide Rejoice Asoloko Manasseh Rasak Adekoya Judith Nwokoro Akindele Obanla Adams Maina Tata Olufunmilola Temitayo Social Development specialist WB Nnaemeka Chukwuone Consultant WB Cindy Ijeoma Ikeaka Senior Social Development WB specialist Elijah Abiodun Siakpere Senior Social Development WB specialist Lucky Erhaze Environmental Specialist WB§ Halima Femi Pat Natson Social Development consultant WB Stella Nneka Eze WB Samson Thomas WB Oluwafunmilayo R WB Aladesuyi i Paper commissioned for the 2020 Global Education Monitoring Report, Inclusion and education ii World Bank. 2016. Disability Inclusion in Nigeria. A Rapid Assessment 67