REPUBLIC OF BENIN Société des Infrastructures Routières et de l’Aménagement du Territoire (SIRAT SA) Grand Nokoué Sustainable Urban Mobility Project (GN-SUMP) (P180579) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) [Appraisal Version] 03/13/2025 1 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of the Republic of Benin (the Recipient) will implement the Grand Nokoué Sustainable Urban Mobility Project (the project), with the involvement of the Société des Infrastructures Routières et de l’Aménagement du Territoire (SIRAT SA), as set out in the Financing Agreement (the Agreement). The International Development Association (the Association) has agreed to provide original financing for the Project, as set out in Agreement. 2. The Recipient shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Association. The ESCP is a part of the Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the Agreement. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Recipient shall carry out or cause to be carried out, including, as applicable, their respective timeframes; institutional, staffing, training, monitoring and reporting arrangements; and grievance management. The ESCP also sets out the environmental and social (E&S) documents that shall be prepared or updated, consulted, disclosed and implemented under the Project, consistent with the ESSs, in form and substance acceptable to the Association. Said E&S documents may be revised from time to time with prior written agreement by the Association. As provided for under the referred Agreement, the Recipient shall ensure that there are sufficient funds available to cover the costs of implementing the ESCP. 4. As agreed by the Association and the Recipient, this ESCP will be revised from time to time, if necessary, to reflect adaptive management of Project changes or unforeseen circumstances or in response to Project performance. In such circumstances, the Association and the Recipient agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient’s Representative specified in the Agreement. The Recipient shall promptly disclose the updated ESCP. 5. The subsection on “Indicators for Implementation Readiness” below identifies the actions and measures to be monitored to assess Project readiness to begin implementation in accordance with this ESCP. Nevertheless, all actions and measures in this ESCP shall be implemented as set out in the “Timeframe” column below irrespective of whether they are listed in the referred subsection. 2 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY IMPLEMENTATION ARRANGEMENTS AND CAPACITY SUPPORT A ORGANIZATIONAL STRUCTURE a. Establish the pool PMUD-GN no SIRAT later than 03 months after the a. Establish and maintain within the SIRAT a pool of Experts (pool PMUD-GN) with qualified staff board approval, and thereafter and resources to support management of environmental, social, health and safety (E&S) risks and maintain the pool PMUD-GN and impacts of the Project including an environmental specialist with strong background in health and staffing positions throughout safety, a social and gender specialist who will also handle stakeholder engagement and SEA/SH. Project implementation. b. Enter into collaboration arrangements with Agence Beninoise de l’Environnement (ABE) to b. Finalize and start implementing manage E&S risks and impacts of the Project. the collaboration arrangements prior to the start of project activities. B CAPACITY BUILDING PLAN/MEASURES SIRAT The capacity building plan shall be Prepare and implement the capacity building plan the following capacity building measures: Training prepared, approved and of PIU staff (pool PMUD-GN and SIRAT), stakeholders, affected community members, project implemented annually throughout workers and consultants on, but not limited to, the following subjects: Project implementation. • Project Management (scope, implementation, monitoring and Reporting) • World Bank Environmental and Social Framework (including the Environmental, Social Standards (ESSs) • Grievance Redress Mechanism • Community health and safety • Occupational Health and Safety • Environmental and Social Monitoring and Reporting • GBV/SEA risk management and child rights protection • Gender and Disability inclusion • Information on World Bank’s Safeguards Incidents Reporting Tool (ESIRT) provided. MONITORING AND REPORTING C REGULAR REPORTING Submit quarterly reports to the SIRAT Association throughout Project Prepare and submit to the Association regular monitoring reports on the environmental, social, implementation, commencing after health and safety (E&S) performance of the Project. The reports shall include: the Effective Date. Submit each report to the World • Status of preparation and implementation of E&S documents required under the ESCP. Bank no later than 15 days after the end of each reporting period. 3 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY • Summary of stakeholder engagement activities carried out as per the Stakeholder Engagement Plan. • Complaints submitted to the grievance mechanism(s), the grievance log, and progress made in resolving them. • E&S performance of contractors and subcontractors as reported through monthly contractors’ and supervision firms’ reports. • Number and status of resolution of incidents and accidents reported under action E below. • Monitoring of environmental and social indicators, labor management, taking into account vulnerable people. D CONTRACTORS’ MONTHLY REPORTS Submit monthly reports to the SIRAT Association and as annexes to the Require contractors and supervising firms to provide monthly monitoring reports on E&S reports to be submitted under performance in accordance with the metrics specified in the respective bidding documents and action C above. contracts and submit such reports to the Association. E INCIDENTS AND ACCIDENTS Notify the Association no later than SIRAT 48 hours after learning of the Notify the Association of any incident or accident relating to the project which has, or is likely to incident or accident. Provide have, a significant adverse effect on the environment, the affected communities, the public or available details upon request. workers, including those resulting in death or significant injury to workers or the public; acts of violence, discrimination or protest; unforeseen impacts to cultural heritage or biodiversity Provide review report and resources; pollution of the environment; dam failure; forced or child labor; displacement without Corrective Action Plan to the due process (forced eviction); allegations of sexual exploitation or abuse (SEA), or sexual Association no later than 10 days harassment (SH); or disease outbreaks. Provide available details of the incident or accident to the following the submission of the [Bank/Association] upon request. initial notice, unless a different timeframe is agreed to in writing by Arrange for an appropriate review of the incident or accident to establish its immediate, underlying the Association. and root causes. Prepare, agree with the Association, and implement a Corrective Action Plan that sets out the measures and actions to be taken to address the incident or accident and prevent its recurrence. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 4 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.1 ENVIRONMENTAL AND SOCIAL ASSESSMENTS AND/OR PLANS SIRAT 1. Implement the ESIA and ESMP of 1. Implement an Environmental and Social Impact Assessment (ESIA), and corresponding ATC 1prior to the start of the works Environmental and Social Management Plan (ESMP) of the improvement of access routes and and throughout Project traves of Cotonou (ATC) Lot 1, consistent with the relevant ESSs. implementation. 2. Prepare and implement Environmental and Social Assessments (ESAs), and corresponding 2. Prepare the ESA and ESMP prior Environmental and Social Management Plans (ESMPs) for Components 2, 3 and 4 of the Project to the start of the works, and respectively, consistent with the relevant ESSs. thereafter implement the ESA and ESMP throughout Project 3. Implement the Environmental and Social Management Framework (ESMF) for the Project, implementation. consistent with the relevant ESSs. 3. Implement the ESMF throughout 4. Require ADELAC to prepare and implement the environmental and social assessments of the lake Project implementation. transport, as set out in the ESMF. 4. Prepare the ESA and ESMP prior 5. Assess the implementation of contractors ESMPs (C-ESMPs). to the start of the works and thereafter implement the ESA and ESMP throughout Project implementation and operation. 5. Assess the implementation of the C-ESMPs periodically from the commencement of the civil works and throughout Project implementation. 1.2 MANAGEMENT OF CONTRACTORS As part of the preparation of SIRAT procurement documents and Incorporate the relevant aspects of the ESCP, including, inter alia, the ESIAs and corresponding respective contracts. ESMPs, the Waste Management Plan (WMP), the Occupational Health and Safety (OHS) Management Supervise contractors throughout Plan, the Labor Management Procedures, and code of conduct, into the E&S specifications of the Project implementation. procurement documents and contracts with contractors and supervising firms. Thereafter ensure Copies of relevant contracts that the contractors and supervising firms comply and that they require their subcontractors to provided to the Association upon comply with the E&S specifications of their respective contracts. Provide copies of the relevant request. contracts with contractors/subcontractors and supervision firms to the Association. 1.3 TECHNICAL ASSISTANCE Throughout Project SIRAT implementation. Carry out the consultancies, feasibility studies, capacity building, training, and any other technical assistance activities under the Project in accordance with terms of reference acceptable to the 5 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Association, that are consistent with the ESSs. Thereafter prepare and finalize the outputs of such activities in compliance with the terms of reference. 1.5 ASSOCIATED FACILITIES Throughout Project SIRAT implementation and operation. Ensure that the dredging of the lake Nokoue are carried out by ADELAC in accordance with the applicable requirements of this ESCP and the ESSs , including, inter alia, the ESMF, LMP, management of contractors, RAP, SEP, etc. 1.6 USE OF RECIPIENT’S ENVIRONMENTAL AND SOCIAL FRAMEWORK Throughout Project SIRAT implementation and operation. Ensure that management of issues related to gender-based violence in Investment Project Financing involving Major Civil Worksare consistent with this ESCP and with the Recipient’s GBV framework, which includes, inter alia, the country´s relevant policy, legal and institutional framework, including its national, departmental, or local implementing institutions, and the applicable laws, regulations, procedures, and implementation capacity. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Implement the LMP throughout SIRAT and Project Project implementation. contractors and Implement the Labor Management Procedures (LMP) for the Project. subcontractors 2.2 OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT PLAN Prepare the OHS Management Plan SIRAT and Project prior to the commencement of civil contractors and Require contractors and subcontractors to prepare and implement OHS Management Measures or works, and thereafter implement subcontractors Plan in accordance with ESMF, ESIAs and the World Bank Group Environmental, Safety and Health the plan throughout Project Guidelines. implementation. 2.3 GRIEVANCE MECHANISM FOR PROJECT WORKERS Establish grievance mechanism SIRAT and Project prior engaging Project workers and contractors and Establish and operate a grievance mechanism for Project workers, as described in the LMP and thereafter maintain and operate it subcontractors consistent with ESS2. throughout Project implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 6 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 3.1 WASTE MANAGEMENT PLAN Prepare the WMP prior to the SIRAT and Project Prepare and implement a Waste Management Plan (WMP), as part of the ESMPs to be prepared commencement of any activities contractors and under action 1.1 above to manage hazardous and non-hazardous wastes, consistent with ESS3. and thereafter implement the subcontractors WMP throughout Project implementation. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the SIRAT and Project Incorporate resource efficiency and pollution prevention and management measures in the ESMPs preparation and implementation of contractors and to be prepared under action 1.1 above. the ESMPs. subcontractors ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY a. Same timeframe as for the SIRAT a. Incorporate measures to manage traffic and road safety risks as required in the ESMPs to be preparation and implementation of prepared under action 1.1 above. the ESMP. b. Implement the Road Safety Plan (RSP) of the ATC 1 sub project. b. Implement the RSP throughout Project implementation. 4.2 COMMUNITY HEALTH AND SAFETY Same timeframe as for the SIRAT Assess and manage specific risks and impacts to the community arising from Project activities, preparation and implementation of including, inter alia, behavior of Project workers, risks of labor influx, response to emergency the ESMPs. situations, and include mitigation measures in the ESMPs to be prepared in accordance with the ESMF. 4.3 SEA AND SH RISKS Prepare the SEA/SH Action Plan SIRAT prior to the commencement of Prepare and implement a SEA/SH Action Plan as part of the LMP or ESMPs, to assess and manage activities, and thereafter the risks of SEA and SH. implement the SEA/SH Action Plan throughout Project implementation.] 4.4 SECURITY MANAGEMENT 1 Prior to engaging security SIRAT Assess and implement measures to manage the security risks of the Project, including the risks of personnel, and thereafter engaging security personnel to safeguard project workers, sites, assets, and activities as set out in throughout the Project the ESMF. implementation. 1 Depending on security risks and details of the project, the Borrower may retain or engage public security personnel, including military, to provide security for the project. Such cases may require a specific security management assessment and/or security management plan and setting out specific measures and actions in the ESCP. See Annex to the “Tip Sheet: Drafting the Environmental and Social Commitment Plan” for further guidance. 7 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT [FRAMEWORK] [PLAN] or [PLANS] 1. Implement the RPF throughout SIRAT Project implementation. 1. Implement a Resettlement Policy Framework (RPF) for the Project, consistent with ESS5. 2. Prepare and implement the 2. Prepare and implement a Resettlement Plan (RP) for each activity as set out in the RPF and respective RP prior to carrying out consistent with ESS5. the relevant works, including ensuring that before taking 3. Implement the RAP of ATC 1 subproject. possession of the land and related assets, full compensation has been provided and as applicable displaced people have been resettled and moving allowances have been provided. 3. Implement the RAP prior to carrying out the relevant work on the ATC 1. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS 1. Same timeframe as for the SIRAT preparation and implementation of 1. Incorporate measures consistent with ESS6 to manage biodiversity risks and impacts as required the ESMP. in the ESMPs to be prepared under action 1.1 above. 2. Finalize and start implementing the collaboration arrangements ABE 2. Enter into collaboration arrangements with Agence Beninoise de l’Environnement (ABE) to prior to the start of project support the management E&S risks and impacts of the Project on the Ramsar site 1018. activities. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES Not applicable ESS 8: CULTURAL HERITAGE 8.1 CULTURAL HERITAGE RISKS AND IMPACTS Prepare the CHMP as part of the SIRAT ESMP prior to commencement of Prepare and implement a Cultural Heritage Management Plan (CHMP) as part of the ESMP, in any activities that would have accordance with the guidelines of the ESMF prepared for the Project, and consistent with ESS8. significant impact on cultural heritage, and thereafter implement the CHMP throughout Project implementation. 8 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 8.2 CHANCE FINDS Implement the procedures SIRAT Apply the chance finds procedures describe in the ESMF in the case of any encounter with cultural throughout Project heritage during the works. implementation]. ESS 9: FINANCIAL INTERMEDIARIES Not applicable ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN Update the [SEP] prior to carrying SIRAT out activities, and thereafter Update and implement a Stakeholder Engagement Plan (SEP) for the Project, consistent with ESS10, implement the (SEP] throughout which shall include measures to, inter alia, provide stakeholders with timely, relevant, Project implementation. understandable and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM Establish the grievance mechanism SIRAT no later than 3 months after Establish, publicize, maintain, and operate an accessible grievance mechanism, to receive and Effective Date, and thereafter facilitate resolution of concerns and grievances in relation to the Project, promptly and effectively, maintain and operate the in a transparent manner that is culturally appropriate and readily accessible to all Project-affected mechanism throughout Project parties, at no cost and without retribution, including concerns and grievances filed anonymously, in implementation following the date a manner consistent with ESS10. of installation and continue to maintain and run it for the duration The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of of the project. SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. INDICATORS FOR IMPLEMENTATION READINESS The following actions are indicators for implementation readiness: i) Establishment of pool PMUD-GN in SIRAT and frequent reporting on the E&S performance of the project; ii) E&S Training of staff within Specialized Implementing Agencies, such as MCVT’s DGDU and DAPMF, MEF’s USMEF, ANaTT, CNSR, ADELAC, etc. ; iii) Implementation of agreements/conventions between SIRAT and ABE; iv) Memorandums of Understanding or other written agreements/arrangements between Project Implementation Entities and other concerned agencies to ensure proper coordination of E&S risk management activities; v) E&S effectiveness or disbursement conditions, if deemed warranted; vi) E&S assessments and plans to be prepared by the Recipient at the onset of implementation of any activity; vii) other project-specific requirements related to E&S readiness for implementation. 9