DRAFT Stakeholder Engagement Plan (SEP) LIFTING EDUCATION ACCESS AND RESILIENCE IN TIMES OF NEED IN UKRAINE PROJECT (LEARN) (P504171) June 2024 1. Introduction/Project Description The Project comprises the Investment Project Financing (IPF) Component of the Lifting Education Access and Resilience in Times of Need in Ukraine (LEARN) Program for Results Operation. The IPF component aims at supporting the Ministry of Education and Science in the implementation of the New Ukrainian School (NUS) reform in upper grades (8-12) and strengthening the MoES’ capacity to manage critical reforms and allocate resources. Thus, it will finance the development of educational methodologies and teacher’s and managers' professional development for the grades 8 to 12, as well as the procurement of laboratory and IT equipment in pilot schools. Importantly, the IPF will also enhance the management capacity of the MoES related to the NUS, to specifically strengthen (i) data and evidence, (ii) sectoral planning, monitoring, and (iii) the efficiency of domestic financing. Also, complemented by a System Capacity Grant (SCG) financed by the Global Partnership for Education (GPE), the IPF will support capacity building activities within the MoES for the implementation of the Strategic Action Plan across the education system. 1. Sub-component 1. Support the rollout of NUS in grades 8 to 12 (US$16,6M). The NUS reform is rolled out grade by grade with grade 8 being implemented beginning in 2025. This part seeks to prepare educational institutions for the rollout of i) grades 8-9 of basic school, and ii) grades 10-12 of high profile school by updating educational and methodological support in accordance with modern educational standards and ensuring high-quality professional development of teachers, as well as iii) strengthen capacities of the Ukrainian Institute of Education Development (UIRO) as a key implementing educational institution for the NUS reform. The activities will include: a. Activity 1.1. NUS reform in grades 8 and 9 by a) developing and pilot implementation of a new procedure for examination of educational and methodical materials for NUS piloting, b) developing, printing, and testing teaching and methodological materials for the grade 9 pilot, c) developing teacher training programs for grades 8 and 9, and d) equipping schools participating in the piloting of the NUS reform at the basic education level with STEM equipment, furniture, ICT devices, etc. b. Activity 1.2. NUS reform for grades 10 to 12 by a) developing educational and methodological materials for the pilots of grades 10 to 12, b) developing teacher and lyceum leader training programs for grades 10-12, and c) equipping schools participating in the piloting of the NUS reform at the level of high profile school education with STEM equipment, furniture, ICT devices, etc c. Activity 1.3. Strengthening the UIRO capacity through a) an organizational capacity audit, b) the design of a capacity development plan, c) staff training, d) the creation of a digital platform for the storage, distribution, organization, and assessment of digital educational materials, and e) material and technical equipment for educational and methodological 1 labs of UIRO. UIRO capacity would also be further strengthened through technical assistance to design a fit-for-purpose instrument for measuring teacher classroom practices, and to implement this instrument in a sample of classrooms in grades 8-12. 2. Sub-component 2. Strengthen MoES Management Capacity (US$2,7M). This part seeks to strengthen the capacity to successfully manage, monitor, and evaluate the rollout of the NUS reform by investing in i) the development of sustainable institutional and operational capacity of the MoES, ii) the creation of a special online platform (SOP) for conducting State Final Examination (DPA) (conducted for students in grades 4, 9, and 11), iii) modernization of the education management information system (AIKOM), and iv) education infrastructure planning. The activities will include: a. Activity 2.1. Institutional and operational capacity of MoES (for effective support to response and recovery of the school education sector, implementation of subventions, and continuation of the New Ukrainian School reform (including the development and support of the upper secondary school pilot). b. Activity 2.2. Creating SOP for DPA through a) the development and piloting of SOP software, b) modernization of SOP software, its technical support, , and c) expansion of software functionality for the grade 9 DPA. The development of the SOP would complement the NUS reform by increasing efficiency in the measurement and analysis of student performance trends over time and across the country. c. Activity 2.3. Modernization of AIKOM through a) development of new AIKOM functionality and b) support for AIKOM interoperability with the solutions/clients developed as part of the UNESCO/GPE project. d. Activity 2.4. Education infrastructure planning through preparation of infrastructure development plans for educational institutions, as induced by the war-related challenges to their safe operation, and the need to rebuild educational infrastructure on the ‘build- back-better’ approach. These could include, i.e., characterization, development of feasibility studies and detailed designs for at least 5 typical transformations of the pre- schools. 3. Sub-component 3. Project management and monitoring. The objective of this part is to support the effective management and implementation of the proposed program. This part would finance the day-to-day management and monitoring of the proposed project through a Project Implementation Unit (PIU). It would cover salaries for such consultants, including a project manager and fiduciary, environmental and social risk management specialists. It would also finance training activities, targeted technical assistance, data collection and analysis, project monitoring and evaluation, and operating costs. 4. Sub-component 4. Contingent Emergency Response Component: Following an eligible crisis or emergency, the Borrower may request the World Bank to re-allocate project funds to support emergency response and reconstruction. This component would draw from the uncommitted loan/credit/grant resources under the project from other the IPF component to cover emergency response. As part of project preparation, the Borrower prepares, with the World Bank’s support, a CERC Annex to the Project Operations Manual (POM). The LEARN (IPF Component) is being prepared under the World Bank’s Environment and Social Framework (ESF). Per Environmental and Social Standard ESS10 on Stakeholder Engagement and Information Disclosure, the implementing agencies should provide stakeholders with timely, relevant, 2 understandable, and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination, or intimidation. 2. Objective/Description of SEP The overall objective of this SEP is to define a program for stakeholder engagement, including public information disclosure and consultation throughout the entire project cycle. The SEP outlines the ways in which the project team will communicate with stakeholders and includes a mechanism by which people can raise concerns, provide feedback, or make complaints about project activities or any activities related to the project. The SEP covers the activities of the IPF Component. Other related environmental and social documentation for the project includes the Environmental and Social Systems Assessment (ESSA) for the broader PforR program, prepared and disclosed by the World Bank during project preparation. The ESSA identifies the stakeholders for the broader program and describes the manner in which stakeholder engagement is mainstreamed into all interventions. A Stakeholder Engagement and Communications Plan will be prepared for the PforR under the Program Action Plan. An Environmental and Social Commitment Plan (ESCP) is also prepared for the IPF Project. 3. Stakeholder identification and analysis 3.1 Methodology In order to meet best practice approaches, the project will apply the following principles for stakeholder engagement: • Openness and life-cycle approach: Public consultations for the project(s) will be arranged during the whole life cycle, carried out in an open manner, free of external manipulation, interference, coercion, or intimidation. • Informed participation and feedback: Information will be provided to and widely distributed among all stakeholders in an appropriate format; opportunities are provided for communicating stakeholder feedback, and for analyzing and addressing comments and concerns. • Inclusiveness and sensitivity: Stakeholder identification is undertaken to support better communications and build effective relationships. The participation process for the projects is inclusive. All stakeholders at all times are encouraged to be involved in the consultation process. Equal access to information is provided to all stakeholders. Sensitivity to stakeholders’ needs is the key principle underlying the selection of engagement methods. Special attention is given to vulnerable groups that may be at risk of being left out of project benefits, particularly women, the elderly, persons with disabilities, displaced persons, and migrant workers and communities, and the cultural sensitivities of diverse ethnic groups. • Flexibility: If social distancing, cultural context (for example, particular gender dynamics), or governance factors (for example, high risk of retaliation) inhibits traditional forms of face-to-face engagement, the methodology should adapt to other forms of engagement, including various forms of internet- or phone-based communication. Within the current context of the war in Ukraine, stakeholder engagement is constrained by martial law. 3.2. Affected parties and other interested parties 1 Affected parties include local communities, community members, and other parties that may be subject to direct impacts from the Project. The projects’ stakeholders also include parties other than the directly affected communities. include NGOs or civil society groups at the local and national levels, business owners and providers of services within the project area, other government officials]. 3 Specifically, the following individuals and groups fall within these two categories: Stakeholder group Interests Influence Interest Impact Project-affected parties IPF Component: Supporting the implementation of the NUS reform in upper grades (8-12) and strengthening the MoES’ capacity for education system’s management School teachers and school • Professional development, career advancement, H H teachers unions (if available) Improving the effectiveness of the learning process • Boosting professional motivation • Enhancing education management system Ð? Ð? effectiveness through technology implementation School managers • Ensuring adequate and transparent funding for educational institutions • Improving managerial skills and professional growth • Equal access to quality educational services Ð? L • Safe, comfortable, and inclusive learning Pupils and their families environment • Availability of highly qualified teaching staff in educational institutions • Improving the efficiency of funds allocated to H M Founders (local self- educational institutions government bodies) • State assistance in developing and restoration of educational infrastructure at the community level Relevant Directorates in the • Enhancing opportunities for shaping state H H MOES policy in the education sector • Enhancing opportunities for disadvantaged children H M Ministry of Social Policy including poor and those with disabilities • Dissemination of information 4 Stakeholder group Interests Influence Interest Impact • development of educational standards, curricula, H H their implementation, and providing methodological support to teachers and schools • development of professional standards and training Ukrainian Institute of programs for pedagogical staff, teaching materials, Education Development and methodological recommendation (UIRO) • providing educational and methodological support for teachers working in inclusive educational environment, preparing proposals for improving the content, forms and methods of education of children with special educational needs Other interested parties Cabinet of Ministers of â–ª Speed of delivery – demand for results quickly H H Ukraine, Ministry of finance of â–ª Providing meaningful support for relief & recovery in Ukraine war affected communities National and local media and â–ª Minimizing risk of Project benefits lost to corruption M H NGOs â–ª Transparency, accountability, and robust public information flow about Project activities â–ª Representing the interests of vulnerable groups such as children with disabilities. Donors â–ª Providing financing, supervision and monitoring of H H implementation 3.3. Disadvantaged/vulnerable individuals or groups2 Within the Project, vulnerable or disadvantaged groups may include but are not limited to the following: Disadvantaged/vulnerable individuals and groups are those who may do not have a voice to express their concerns or understand the impacts of a project, are sometimes excluded from stakeholder engagement. Within the context of Ukraine education sector, the following vulnerable groups can be identified: a) internally displaced children and their families as a result of the war; b) children with special learning needs or children with disabilities, and their families; c) poor children living in households with more than two children; d) marginalized ethnic communities, such as Roma; d) orphans and social orphans that live in an institutionalized environment and who may miss on the benefits and services provided by the project e) rural populations including teachers and children that are disadvantaged in terms of physical and digital connectivity and access to education. Although the project is not targeting these groups directly, their needs should be considered as a focus of the capacity building activities and systems supported under the project. 5 Vulnerable groups within the communities affected by the Project may be added, further confirmed, and consulted through dedicated means, as appropriate. Description of the methods of engagement that will be undertaken by the project is provided in the following sections. 4. Stakeholder Engagement Program 4.1. Summary of stakeholder engagement done during project preparation A summary of the public consultation meetings conducted during project preparation will be provided. The environmental and social reports and plans will be disclosed through MoES website . Feedback received during consultations will be summarized and information about how comments were taken into account will be incorporated into the SEP. A summary of the main recommendations received and integrated into the Stakeholder Engagement Plan will be provided 4.2. Summary of project stakeholder needs and methods, tools, and techniques for stakeholder engagement Different engagement methods are proposed and cover different stakeholder needs for the different activities, as stated described in the table below. 4.3. Stakeholder engagement plan Project Stage/ Estimated Topic of Method Used Target Stakeholders Responsibilities Component Date/Time Consultation/ Period Message Implement sub- Connectivity, Consultations (mainly All stakeholders, MoES , UIRO (for Component 1: accessibility and on-line); surveys (e.g. including representative Activity 1.3) Support the rollout capacity to roll with cell phones) teachers, and NGOs of NUS out NUS representing including STEM Disclosure of draft marginalized/vulnerable • NUS Pilots and ICT materials and terms groups /materials for equipment of reference grades 8-12 • Equipping Universal design Consultations and Teachers, school staff Local schools with for learning Focus Group and parents, in governments STEM and ICT meetings/discussions representative and school staff equipment geographic regions, on behalf of • Strengthening gender etc. MoES and/or capacity for UIRO UIRO, digital Correspondence by platforms for phone/email and one Government entities MoES , UIRO (for educational on one meetings Activity 1.3) materials Implement Sub- Connectivity, Consultations All stakeholders MoES component 2: accessibility, Focus Group including teachers, and foreseeing meetings/discussion school staff and parents, 6 • MOES implementation and purposeful in representative institutional challenges sampling. geographic regions, strengthening gender, age, etc • SOP Universal design Correspondence by development for learning phone/email and one • Modernize on one meetings AIKOM Addressing Government entities needs of internally displaced children Implement Sub- E&S impacts One on one meetings NGOs representing MoES component 2 associated with vulnerable groups Education design of Community and infrastructure typical/ model group consultations Directorates within planning pre- schools MOES (e.g. energy Correspondence by efficiency, email/phone universal access) Implement Sub- Accessibility, Correspondence by Teachers and school MoES component 3 and connectivity phone/email and one staff benefitting from training activities of training on one meetings training events Safety protocols Outreach activities for any in person training Feedback and surveys as per from training events Emergency Preparedness Plan Proposed Strategy for Information Disclosure Stakeholder group Project information shared ` Means of communication disclosure Ministry of Education and Science of â–ª Summary project objectives and Ukraine ; general information. Regular updates on project implementation â–ª Environmental and social PIU commitment plan 7 Cabinet of Ministers of Ukraine, Ministry â–ª Stakeholder engagement plan and of finance of Ukraine other ESF related documents Ministry of Social Policy â–ª Grievance mechanism Non-Governmental and community Information about results of â–ª Public notices, publications and based organizations consultations with the MoES press releases on the official websites. Public information requesting according to the Law of Ukraine “On access to public National and local media informationâ€? Local authorities â–ª Information about improvement of â–ª Public notices in local media and equipment and enhancement of offices, communication with local educational system population and other local stakeholders Teachers and school managers Information about trainings and â–ª Official communication channels, capacity building program information from local education authorities Pupils and their families Information about the NUS and Project â–ª Public notices in local media and activities offices, communication with local population and other local stakeholders 4.4. Reporting back to stakeholders Stakeholders will be kept informed as the project develops, including reporting on project environmental and social performance and implementation of the stakeholder engagement plan and Grievance Mechanism, and on the project’s overall implementation progress. 5. Resources and Responsibilities for implementing stakeholder engagement activities 5.1. Resources Using existing agencies and mechanisms with a proven track record is an effective approach for implementing relief and recovery operations. Given the urgency for expedient and effective implementation, to the extent possible, LEARN will capitalize on existing institutions, platforms, and mechanisms (such as GRM, stakeholder engagement channels, etc.) that are trusted, acceptable to the Bank and have the capacity to facilitate the implementation of project-finance activities. The MOES, as the implementing agency for LEARN, is highly experienced with solid institutional capacity in place, developed during the preparation and implementation of Ukraine Improving Higher Education for Results Project (UIHERP) Project financed by WB. The overall responsibility for the project implementation, including the E&S-related aspects, lies with the Project Implementing Unit (PIU) within MOES. The Project will maintain a dedicated, itemized budget for implementing the SEP including staffing; communications and outreach activities; consultation events; and training. It should be noted that technical assistance activities procured under the project should include the costs of stakeholder engagement and information disclosure activities consistent with the SEP, in view of activity specific stakeholder consultations and information dissemination. The source of funding is the Project budget. 8 5.2. Management functions and responsibilities The main entity responsible for carrying out stakeholder engagement activities are the members of the Project Implementing Unit (PIU) within MoES. The PIU will work with the Department of Document Management, Control and Information Technologies of MoES - the Department of Citizen’s Appeals to resolve any grievances related to project activities that come in through MoES channels. The stakeholder engagement activities under the project will be documented through semi-annual reporting on project implementation. 6. Grievance Mechanism The main objective of a GM is to assist to resolve complaints and grievances in a timely, effective, and efficient manner that satisfies all parties involved. 6.1. Description of GM Objective: To strengthen transparency and accountability to beneficiaries and provide channels for project stakeholders to provide feedback and/or express grievances related to project supported activities. Aims: Identification and resolving of issues affecting the project; mitigate the risk of the project inadvertently affecting citizens/beneficiaries; obtain feedback and learning to help improve project impact. Activities: Receive, record, evaluate and address complaints and concerns from project affected parties and citizens at project level and escalate for further response as needed. Scope: GM will be available for project stakeholders (especially project beneficiaries and those directly or indirectly affected, positively or negatively, by the project) and other interested parties to submit questions, comments, suggestions and/or complaints, or provide any form of feedback on all project-funded activities. Implementation The GM for the project is managed by the MOES/PIU. Structure: The PIU will work with the Department of Document Management, Control and Information Technologies of MoES - the Department of Citizen’s Appeals to resolve any grievances related to project activities that come in through MoES channels. Legal basis: Citizens’ appeals, complaints and recommendations procedure is specified in the Law On Citizens’ Appeals and amendments to the latter through the 2015 amendment on Electronic Petitions. According to the mentioned law and Constitutional Article 40, the Project proposes the following channels through which ball interested parties can make complaints regarding project-funded activities. Grievance procedure Dissemination of Information included in SEP and available at the MOES website, disseminated in GM communications with stakeholders. 9 MoES will disseminate information about GM for such category of stakeholders as teachers and parents and report on such measures . Channels for MoES: submitting • By the phone number: (044) 481-47-57, (044) 481-47-65, (044) 481-47- complaints 95 • By E-mail: ez@mon.gov.ua • Through the following web page: mon.gov.ua • In writing: 01135, Kyiv, 10, Beresteyskiy ave. • In person: at the above addresses or at the addresses of delegated authority by the latter • Other: Written complaints to project staff (through project meetings) Education Ombudsman Service: • By Email: ez@eo.gov.ua • Through the following web page: http://zvernennya.eo.gov.ua • In writing: 04053, Kyiv, Lvivska Sq., 14Ð? (https://eo.gov.ua/podaty-zvernennia/2020/06/21/) • Phone: +380 951438726 Government contact center • Phone: 1545 For corruption issues • Whistleblower Reporting Portal whistleblowers.nazk.gov.uat • Phone +38 (044) 481 32 06 Anonymous complaints: may be submitted without personal details. Anonymous Confidentiality will be ensured in all instances, including when the person making the complaint is known. Sorting, A focal point at the MOES (Department of Document Management, Control and Processing Information Technologies of MoES), who receives a complaint, registers it according to the internal rules of the MOES. Upon receipt of the complaint within the Project, the Head of PIU is promptly notified about grievance received and forwards the complaint to the responsible person for addressing in PIU. The specialist social issues will register the complaint in the Grievance log. Acknowledgement The person/department responsible for reviewing the complaint will gather and and follow-up examine all facts related to the submission of the Grievance. The process may include meetings/virtual consultations with the complainant (if needed) and others who can contribute to the resolution. The review period may be extended up to 30 working days, and the complainant must be informed of this within 15 10 working days, regardless of whether: additional consultations are needed to respond to the complaint; the complaint involves a complex volume of information, and additional materials need to be studied to respond. After the investigation is completed, the response will be provided to Complainant. The social issues specialist will record actions taken in the Grievance log. Verification, Investigation of the complaint is lead by the Project Coordinator who assign Investigation resources and responsibilities for investigating the complaint including gathering facts in order to generate a clear understanding of the circumstances surrounding the grievance. The investigation/follow-up can include site visits, review of documents and a meeting with those who could resolve the issue. A proposed resolution is formulated by the Project Coordinator and communicated to the complainant no later than 15 days after receipt. Complaints requiring additional evaluation are considered and resolved no later than one month after receipt (Article 20 of the Law of Ukraine on Citizens’ Appeals) Handling of The project will develop procedures to handle sensitive and confidential SEA/SH complaints, including those related to Sexual Exploitation and Abuse/Harassment complaints (SEA/SH) in line with the World Bank ESF Good Practice Note on SEA/SH. The procedure will ensure (i) confidential referral of survivors to support services (health, legal, psychosocial, security and other assistance), based on the consent, needs and wishes of survivors; (ii) linkage to the domestic legal system (based on the consent of survivors unless the reporting to the law enforcement agencies is mandatory in Ukraine). Unlike other types of issues, SEA/SH Grievance Mechanisms do not conduct investigation, make any announcements, or judge the veracity of allegations; and (iii) determination of the likelihood that SEA/SH allegations relate to the Project. If a SEA/SH incident is confirmed, an employer is expected to take a corrective action against the perpetrator. Escalation and Complaints that cannot be resolved within one month referred to the head or Appeal deputy of the organization to define necessary time for its consideration, and report about it to the person who filed the appeal (entire term for resolving issues raised in the complaint may not exceed forty-five days). If the complainant is not satisfied with the proposed resolution of the complaint. Once all possible means to resolve the complaint have been proposed and if the complainant is still not satisfied, then they should be advised of their right to legal recourse. Response to The complainant will be informed about the results of verification via letter or complainant email, as received. The response shall be based on the materials of the investigation and, if appropriate, shall contain references to the national legislation. Monitoring and The project will prepare a a semi-annual report of GM results, including any reporting suggestions and questions, to the project team and the management, and review the status of complaints to track which are not yet resolved and suggest any needed remedial action. 11 Training MoES will conduct training for the staff of the Office of Information Policy and Communications and Department of Records Management, Control and Information Technologies - on the project GM, including anonymous grievances and WB ESS10 requirements related to GM. Progress reports In the semi-annual project implementation reports submitted to the Bank, MOES submitted to the will provide information on the following: World Bank • Status of establishment of the GM (procedures, staffing, awareness building, etc.); • Quantitative data on the number of complaints received, the number that were relevant, and the number resolved; • Qualitative data on the type of complaints and answers provided, issues that are unresolved; • Quantitative data on the number of SA/SH complains; • Time taken to resolve complaints; • Number of grievances resolved at the lowest level, raised to higher levels; • Any particular issues faced with the procedures/staffing or use; • Factors that may be affecting the use of the GRM/beneficiary feedback system; • Any corrective measures adopted. Referral to World Communities and individuals who believe that they are adversely affected by a Bank GRS WB supported project may submit complaints to the above project-level GM or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns. Project affected communities and individuals may also submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank’s attention, and Bank Management has been given an opportunity to respond. For information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS), please visit: http://www.worldbank.org/en/projects-operations/products-and- services/grievance-redress-service. The project will establish and operate a responsive Grievance Mechanism to allow Project Workers under ESS2 to inform management of labor issues and raise workplace concerns and labor-related matters without retaliation. This mechanism will use the same uptake channels of the project's overall GM but follow separate avenues for the resolution of labor-related complaints and shall be further detailed in the Project Operations Manual. The World Bank and the Borrower do not tolerate reprisals and retaliation against project stakeholders who share their views about Bank-financed projects. 12 7. Monitoring and Reporting 7.1. Summary of how SEP implementation will be monitored and reported MOES will maintain a database and activity file detailing all public consultation, disclosure information and grievances collected throughout the Project, which will be available for public review on request. MOES will also closely monitor the effective implementation of all safeguards’ instruments (SEP, ESMPs and the GRM designed under the Project). MOES will prepare and will submit to WB and other interested parties the semiannually Project’s progress reports that will include the information on stakeholder engagement activities, which will include: • Activities conducted; • Public outreach activities (meetings with stakeholders and newsletters); • Entries to the grievance register; • New stakeholder groups (where relevant). 7.2. Reporting back to stakeholder groups The SEP will be periodically revised and updated as necessary in the course of project implementation. semiannually summaries and internal reports on public grievances, enquiries, and related incidents, together with the status of implementation of associated corrective/preventive actions, will be collated by responsible staff and referred to the senior management of the project. The semiannual summaries will provide a mechanism for assessing both the number and nature of complaints and requests for information, along with the Project’s ability to address those in a timely and effective manner. Information on public engagement activities undertaken by the MOES during the year may be conveyed to the stakeholders through the publication of Reports and publications on the MOES official website. 13 Endnotes 1 For the purposes of effective and tailored engagement, stakeholders of the proposed project(s) can be divided into the following core categories: • Affected Parties: Persons, groups, and other entities within the Project Area of Influence (PAI) that are directly influenced (actually or potentially) by the project and/or have been identified as most susceptible to change associated with the project, and who need to be closely engaged in identifying impacts and their significance, as well as in decision-making on mitigation and management measures. • Other Interested Parties: Individuals/groups/entities that may not experience direct impacts from the Project but who consider or perceive their interests as being affected by the project and/or who could affect the project and the process of its implementation in some way. • Vulnerable Groups: Persons who may be disproportionately impacted or further disadvantaged by the project(s) compared with any other groups due to their vulnerable status, and that may require special engagement efforts to ensure their equal representation in the consultation and decision-making process associated with the project. • It is important to note that sometimes projects have different components with very different sets of stakeholders for each component. Those different stakeholders should be considered in preparing the SEP. 2 It is particularly important to understand whether project impacts may disproportionately fall on disadvantaged or vulnerable individuals or groups, who often do not have a voice to express their concerns or understand the impacts of a project, and to ensure that awareness raising and stakeholder engagement be adapted to take into account such groups’ or individuals’ particular sensitivities, concerns, and cultural sensitivities and to ensure a full understanding of project activities and benefits. Engagement with vulnerable groups and individuals often requires the application of specific measures and assistance aimed at the facilitation of their participation in the project-related decision making so that their awareness of and input into the overall process are commensurate with those of other stakeholders. 14