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) [For Negotiation] 03/24/2025 1 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. 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), as set out in the Financing Agreement and the Project Agreement (the Agreements). The International Development Association (the Association) has agreed to provide the financing for the Project, as set out in Agreements. 2. The Recipient shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Association. The ESCP is a part of the Agreements. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the Agreements. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Recipient shall carry out or cause to be carried out, including, as applicable, their respective timeframes; institutional, staffing, training, monitoring and reporting arrangements; and grievance management. The ESCP also sets out the environmental and social (E&S) documents that shall be prepared or updated, consulted, disclosed and implemented under the Project, consistent with the ESSs, in form and substance acceptable to the Association. Said E&S documents may be revised from time to time with prior written agreement by the Association. As provided for under the referred Agreements, the Recipient shall ensure that there are sufficient funds available to cover the costs of implementing the ESCP. 4. As agreed by the Association and the Recipient, this ESCP will be revised from time to time, if necessary, to reflect adaptive management of Project changes or unforeseen circumstances or in response to Project performance. In such circumstances, the Association and the Recipient agree to update the ESCP to reflect these changes through an exchange of letters signed between the Association and the Recipient’s Representative specified in the Agreements. The Recipient shall promptly disclose the updated ESCP. 5. The subsection on “Indicators for Implementation Readiness� below identifies the actions and measures to be monitored to assess Project readiness to begin implementation in accordance with this ESCP. Nevertheless, all actions and measures in this ESCP shall be implemented as set out in the “Timeframe� column below irrespective of whether they are listed in the referred subsection. 2 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY IMPLEMENTATION ARRANGEMENTS AND CAPACITY SUPPORT A ORGANIZATIONAL STRUCTURE a. Establish the PIU no later than SIRAT one (1) month after the Effective a. Establish and maintain within the SIRAT a PIU with qualified staff and resources to support Date and thereafter maintain the management of environmental, social, health and safety (E&S) risks and impacts of the Project PIU and staffing positions including an environmental specialist with strong background in health and safety and a social and throughout Project gender specialist who will also handle stakeholder engagement and SEA/SH, all with qualifications implementation. and terms of reference acceptable to the Association. b. Finalize and start implementing b. Enter into collaboration arrangements with Agence Beninoise de l’Environnement (ABE) to the collaboration arrangements manage E&S risks and impacts of the Project. prior to the start of project activities. B CAPACITY BUILDING PLAN/MEASURES PIU within SIRAT The capacity building plan shall be Prepare and implement the capacity building plan including the following capacity building prepared, approved before the end measures: Training of PIU staff, stakeholders, affected community members, project workers and of each year and implemented consultants on, but not limited to, the following subjects: annually throughout Project • Project Management (scope, implementation, monitoring and reporting) implementation. • 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 PIU within 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 PIU within SIRAT Association 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 PIU within 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 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 PIU within SIRAT 1. Finalize and disclose the ESIA and 1. Finalize, consult, adopt, disclose and implement the Environmental and Social Impact Assessment ESMP of ATC 1 under Part 3.2 of (ESIA), and corresponding Environmental and Social Management Plan (ESMP) of the improvement the Project prior to the start of the of access routes and traves of Cotonou (ATC) Lot 1 under Part 3.2 of the Project , for which a draft, civil works, and thereafter consistent with the relevant ESSs, was disclosed on March 20, 2024. implement the ESIA/ESMP throughout Project 2. Prepare, disclose, consult, adopt and implement Environmental and Social Assessments (ESAs), implementation. and corresponding Environmental and Social Management Plans (ESMPs) for Parts 2, 3 and 4 of the Project respectively, consistent with the relevant ESSs. 2. Prepare the relevant ESA and ESMP prior to the start of the 3. Implement the Environmental and Social Management Framework (ESMF) for the Project, which relevant works, and thereafter was prepared, adopted and disclosed on January 20, 2025, consistent with the relevant ESSs. implement the ESA and ESMP throughout Project 4. Prepare, disclose, consult, adopt and implement the Strategic Environmental and Social implementation. Assessment (SESA) to accompany the urban mobility strategy under Part 1, consistent with ESSs. 3. Implement the ESMF throughout 5. Assess the implementation of contractors ESMPs (C-ESMPs), consistent with ESSs. Project implementation. 4. No later than two (02) years after the Effective Date and thereafter implement throughout Project implementation. 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 PIU within 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. 5 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 1.3 TECHNICAL ASSISTANCE Throughout Project PIU within 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 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 PIU within SIRAT 1. Throughout Project 1. Ensure that the Strategic Environmental and Social Assessment (SESA), disclosed on November implementation. 18, 2024, and the standalone draft preliminary ESIA as addendum to the ESMF, agreed with the Association and disclosed on January 14, 2025, are both implemented in accordance with ESSs. 2. Finalize and start implementing the collaboration arrangements 2. Enter into collaboration arrangements with ADELAC to manage E&S risks and impacts of the prior to the start of lake transport activities of the lake transport. activities. 3. Ensure that the dredging of the Lake Nokoue are carried out by ADELAC in accordance with the 3. Throughout Project applicable requirements of this ESCP and the ESSs, including, inter alia, the Lake Transport Safety implementation. Plan including emergency response measures in case of boats capsizing and sinking. ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Implement the LMP throughout PIU within SIRAT and Project implementation. Project contractors and Implement the Labor Management Procedures (LMP) for the Project, which was prepared, adopted subcontractors and disclosed on February 12, 2025, consistent with ESS2. 2.2 OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT PLAN Prepare the OHS Management Plan PIU within SIRAT and prior to the commencement of civil Project 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 PIU within SIRAT and prior to engaging Project workers Project contractors and Establish and operate a grievance mechanism for Project workers, as described in the LMP and and thereafter maintain and subcontractors consistent with ESS2. operate it throughout Project implementation. 6 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Same timeframe as for the PIU within SIRAT and Prepare and implement a Waste Management Plan (WMP), as part of the ESMPs to be prepared preparation and implementation of Project contractors and under action 1.1 above to manage hazardous and non-hazardous wastes, consistent with ESS3. the ESMPs. subcontractors 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Same timeframe as for the PIU within SIRAT and Incorporate resource efficiency and pollution prevention and management measures in the ESMPs preparation and implementation of Project 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 PIU within 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. Finalize, consult, adopt and disclose the Road Safety Plan (RSP) of the ATC 1 under Part 3.2 of the b. Finalize and disclose the RSP Project for which a draft was disclosed on March 20, 2024. prior to the start of the civil works, and thereafter implement the RSP throughout Project implementation.. 4.2 COMMUNITY HEALTH AND SAFETY Same timeframe as for the PIU within 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 any requisite SEA/SH measures and include mitigation measures in the ESMPs to be prepared in accordance with the ESMF. 4.4 SECURITY MANAGEMENT Prior to engaging security PIU within 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. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 7 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 5.1 RESETTLEMENT FRAMEWORK and PLANS 1. Implement the RPF throughout PIU within SIRAT Project implementation. 1. Implement the Resettlement Policy Framework (RPF) for the Project, which was prepared, adopted and disclosed on January 24, 2025, consistent with ESS5. 2. Prepare, disclose, consult, adopt and implement the respective RP 2. Prepare, disclose, consult, adopt and implement a Resettlement Plan (RP) for each activity as set prior to carrying out the relevant out in the RPF and consistent with ESS5. works, including ensuring that before taking possession of the 3. Implement the RAP of ATC 1 under Part 3.2 of the Project, which was prepared, adopted, and land and related assets, full disclosed on March 21, 2025. 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 under Part_3.2__ of the Project. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS 1. Same timeframe as for the PIU within 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 2. Enter into collaboration arrangements with Agence Beninoise de l’Environnement (ABE) to the collaboration arrangements no support the management E&S risks and impacts of the Project on the Ramsar site 1018, consistent later than three (03) months after with ESS6. the Effective Date, 3. To address biodiversity risks and impacts associated with activities under Component 3, 3. Throughout Project implement the biodiversity measures incorporated in the ESAs to be prepared under action 1.1 implementation above in accordance with ESS6. 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 Throughout Project PIU within SIRAT implementation Screen Project sites in accordance with ESS8 to avoid impacts on cultural heritage sites where possible. 8 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Prepare and implement a Cultural Heritage Management Plan (CHMP) as part of the ESMP, in Prepare the CHMP as part of the accordance with the guidelines of the ESMF prepared for the Project, and consistent with ESS8. ESMP prior to commencement of any activities that would have significant impact on cultural heritage, and thereafter implement the CHMP throughout Project implementation. 8.2 CHANCE FINDS Implement the procedures PIU within SIRAT Apply the chance finds procedures described in the ESMF in the case of any encounter with cultural throughout Project implementation heritage during the works. ESS 9: FINANCIAL INTERMEDIARIES Not applicable ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN Update the SEP prior to the start of PIU within SIRAT the civil works or the lake Update, disclose, adopt and implement the Stakeholder Engagement Plan (SEP) for the Project, transport, and thereafter consistent with ESS10, that has been disclosed on January 30, 2025 and which include measures to, implement the SEP throughout inter alia, provide stakeholders with timely, relevant, understandable and accessible information, Project implementation. 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 PIU within 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. a manner consistent with ESS10. The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. While the operationalization of the Project GM is pending, register any Project-related complaints through the GRM of the Benin Building Resilient and Inclusive Cities Program (P176653) and of the Cotonou Rainwater Sanitation Program - PAPC (P167359) under SIRAT coordination. 9 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY INDICATORS FOR IMPLEMENTATION READINESS The following actions are indicators for implementation readiness: i) Establishment of PIU 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. 10