UKRAINE PROGRAM-FOR-RESULTS Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program (P504171) Environmental and Social Systems Assessment (ESSA) FINAL World Bank August 2024 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) Acronyms and abbreviations AIE Assessment of the Impact on the Environment AICOM Automated Information Complex of Educational Management BP Bank Procedures CEB Council of Europe Development Bank CMU Cabinet of Ministers of Ukraine CP Core Principles CSO Civil Society Organization COVID19 Global pandemic of coronavirus disease 2019 DBN State Building Norms DLI Disbursement-linked Indicator DLR Disbursement-linked result DBN State Building Regulation DREAM Digital Restoration EcoSystem for Accountable Management DSTU National Standard of Ukraine EBRD European Bank for Reconstruction and Development EDESSB Unified State Electronic System in the Field of Construction EIB European Investment Bank ERW Explosive Remnants of War EU European Union EIA Environmental Impact Assessment E&S Environmental and Social ESS Environmental and Social Standard ESF Environmental and Social Framework ESSA Environmental and Social Systems Assessment ESCP Environmental and Social Commitment Plan ESMP Environmental and Social Management Plan FM Financial Management GBV Gender Based Violence GHG Greenhouse Gas GPE The Global Partnership for Education GRM Grievance Redress Mechanism IDP Internally Displaced Persons IEA Institute of Educational Analytics ILO Intercultural Learning Online IOM International Organization for Migration IPF Investment Project Financing LEARN Lifting Education Access and Resilience in times of Need MoES Ministry of Education and Science of Ukraine MSP Ministry of Social Policy of Ukraine 2 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) MoF Ministry of Finance NUS New Ukrainian School OHS Occupational Health and Safety OM Operational Manual OVD Ukrainian abbreviation of equivalent of EIA OVNS Ukrainian abbreviation of equivalent of AIE OP Operational Policy p. 24 PAP Program Action Plan PforR Program for Results PPE Personal Protective Equipment PIU Project Implementation Unit RA Result Area SEA Sexual Exploitation and Abuse SH Sexual Harassment UNESCO United Nations Educational, Scientific and Cultural Organization UNICEF United Nations International Children's Emergency Fund UNOPS United Nations Office for Project Services UIHERP Ukraine Improving Higher Education for Results Project UCEQA Ukrainian Center for Educational Quality Assessment UXO Unexploded Ordnance WB World Bank 3 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) Contents Executive Summary ....................................................................................................................................... 6 1. Introduction ........................................................................................................................................ 12 1.1. Purpose and Scope of the ESSA .................................................................................................. 12 1.2. Methodology and Consultations ................................................................................................. 12 2. Program Description ........................................................................................................................... 15 2.1. The current situation and development priorities ...................................................................... 15 2.2. State Program scope ................................................................................................................... 15 2.3. PforR Program Boundary and Scope ........................................................................................... 16 3. Description of Expected Program Environmental and Social Effects .................................................. 20 3.1. PforR component ES risks overview ............................................................................................ 20 3.2. Detailed Screening of Environmental and Social Effects ............................................................. 22 3.3. Exclusion Criteria ......................................................................................................................... 26 3.4. IPF component ES risks ............................................................................................................... 26 4. Assessment of Borrower’s Environmental and Social Management Systems .................................... 27 4.1. Assessment of Borrower E&S Systems against Core Principle 1 (General Principle of Environmental and Social Management) ................................................................................................ 28 4.1. (a) Avoid, minimize, or mitigate adverse impacts and (c) Promote informed decision-making relating to the Program’s environmental and social effects ............................................................... 30 4.1. (b) Promote environmental and social sustainability in Program design .................................... 36 4.2. Assessment of Borrower E&S Systems against Core Principle 2 (Natural Habitats and Physical Cultural Resources) ................................................................................................................................. 39 4.3. Assessment of Borrower E&S Systems against Core Principle 3 (Public and Worker Safety) ..... 40 4.4. Assessment of Borrower E&S Systems against Core Principle 4 (Land Acquisition) ................... 42 4.5. Assessment of Borrower E&S Systems against Core Principle 5 (Indigenous Peoples and Vulnerable Groups) ................................................................................................................................. 42 4.5.1 Inclusion in Education ................................................................................................................ 42 4.5.2 Gender ....................................................................................................................................... 43 4.5.3 Gender Based Violence (GBV) .................................................................................................... 44 4.5.4 Children with special needs or disabilities ................................................................................. 46 4.5.5 Ethnic and Linguistic Groups ...................................................................................................... 48 4.5.6 Internally Displaced Persons ...................................................................................................... 48 4 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) 4.6. Assessment of Borrower E&S Systems against Core Principle 6 (Avoid exacerbating social conflict. Distributional Equity)................................................................................................................ 49 4.7. Assessment of institutional systems ........................................................................................... 50 5. Stakeholder Engagement and Information Disclosure........................................................................ 51 5.1. Program Grievance Mechanism .................................................................................................. 52 6. Conclusions and Recommendations ................................................................................................... 56 Annexes ....................................................................................................................................................... 58 Annex 1. Environmental and Social Checklist ......................................................................................... 58 Annex 2: Program Stakeholder Mapping ................................................................................................ 67 Annex 3. Scope of the capacity building and supervision program ........................................................ 71 Annex 4 Consultation Summary Report .................................................................................................. 72 5 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) Executive Summary The Environmental and Social Systems Assessment has been prepared for the PForR Program in accordance with paragraph 9 of Section III of the PforR Policy and the World Bank PforR Directive. The ESSA (a) examines the scope, context, and potential impacts of the Program from an E&S perspective; (b) assesses in detail the different E&S effects under the Program activities, including indirect and cumulative effects, contextual and political risks related to the E&S issues; (c) assesses the capacity of national bodies in addressing related E&S risks and identify any complex risks in implementing E&S measures; (d) compares the borrower’s systems (laws, regulations, standards, procedures, and implementation performance) against the PforR core E&S principles; and (e) formulates recommended measures to address capacity for and performance on policy issues and specific operational aspects relevant to managing program risks. Methodology. To prepare the ESSA of the proposed operation, the World Bank assessed the Ministry of Education and Science (MoES) environmental and social systems by analyzing available documents and working sessions with the main stakeholders, as well as relevant national legislation and practices. The ESSA is completed based on: current knowledge and supplementary research of environmental and social systems that are relevant to the program, including regulatory frameworks governing environmental and social assessment; labor and health and safety; cultural heritage; construction standards; non- discrimination, gender and disability inclusion; information disclosure and grievance redress; as well as environmental and social performance of such regulatory frameworks based on experience from other World Bank operations, reviews of existing analytical and diagnostic products, published information, and reports, and site visits to schools that have constructed protective shelters in previous years. To further inform its development, the ESSA has been consulted with a wider range of relevant stakeholders and interested parties prior to appraisal. Due to the implications of martial law, limited in person consultations are possible; on-line consultations were the consultation modality. Environmental risks are rated Substantial. Environmental risks and impacts are mostly associated with project-related civil works (for rehabilitation/installation of infrastructure/equipment) and issues associated with school buses. Rehabilitation and construction-related risks include potential increased pollution due to improper care, handling and storage of construction material and waste; temporary impact on cross drainage; water/soil quality impacts in case of construction pollution as well as pressures on the environment caused by the material sourcing; generation of excessive noise and dust levels from trucks and other construction machinery; soil disturbance during earthworks; tree-cutting and loss of vegetation; negative impact on ecosystems (through disturbance); traffic safety issues; community and workers’ health and safety incidents. School buses operations-related risks include design and functional layout for new facilities (shelters) and equipment to ensure proper OHS conditions and community health and safety; and practices to manage household and organic waste. These risks are site-specific and temporary and can be mitigated by existing construction and healthcare management best practices. However, these risks may be exacerbated by potential aerial strikes and other military actions which add an element of extreme uncertainty and risk of fatality or serious injury that cannot be entirely mitigated by environmental and social management measures. Also, there is a risk that project sites may become a target for aerial strikes which will endanger nearby communities and site workers. Other related risks include possible site contaminations with hazardous compounds and ERWs. 6 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) The social risks are rated Substantial. The proposed operation will have positive social effects by increasing access to in-person learning and improving teaching and learning conditions in Ukraine. However, the operation takes place within a highly volatile context, and the community and worker health and safety and security risks in the education sector are high. These risks are highly contextual, beyond the immediate control of the borrower, and the operation is designed to help mitigate these impacts on the education system in Ukraine and build resilience against future shocks. The key potential adverse social effects are associated with the construction and rehabilitation of approximately 286 protective structures within existing schools that are supported under PforR Results Area 1; for example, if the structures are not constructed properly leading to collapse or injury during operation, or if health and safety of workers and community (including children at school sites) are affected by the works. Land acquisition will be excluded from the program. Other social risks of the program are related to ensuring that the benefits (e.g., school shelters, buses, textbooks, teacher training) are designed to be inclusive, and accessible to vulnerable individuals and groups, for example by reaching the poorest children, and children with disabilities. Environmental and social systems for shelters. Robust environmental and social systems are in place for constructing shelters with gaps related to contractor management and monitoring at subnational and local levels. Ukraine has a well-set system for managing environmental and social impacts for civil works embedded in the primary legislation (on impact assessment, on labor conditions etc.), as well as construction, labor and sanitary norms and regulations. Some features such as disability access, material sourcing, climate adaptation and so on are not mandated by ES legislation but by the design regulations adding another separate layer of oversight/supervision. For construction/retrofitting of shelters, the EIA (Ukrainian abbreviation ‘OVD’) is not required by law, hence, all the requirements will be outlined in the general design documentation (with sections on the environmental protection measures (Ukrainian abbreviation ‘OVNS’) and OHS), with supervision role assigned to the authorized party. The MoES mandate is to disburse funds to local authorities. They receive financial reports on implementation but do not currently have a mandate to monitor construction and system gaps exist owing to capacity constraints at local level for contractor management and regulatory enforcement by the Ministry of Infrastructure and Ministry of Environmental Protection and Natural Resources. Also, very little monitoring role is given to the beneficiaries of the subvention (schools, local administrations) due to lack of technical knowledge, among other things. This results in sometimes subpar performance on account of community and occupational health and safety (absent site fencing, lack of PPE usage, incompliant working schedule, lack of adherence to safety protocols etc.), waste management (inappropriate storage of construction and hazardous waste), incident reporting etc. To address system gaps, MoES is planning to incorporate an Environmental and Social Management Plan Checklist (developed in compliance with World Bank Core Principles and Environmental Health and Safety Guidelines) into the resolution for school shelters subvention. The objectives of the ESMP Checklist are to inform a wider audience (contractors, workers, local administration representatives, school staff, parents) about applicable regulations and required ES mitigation measures. The ESMP Checklist provides guidance to the project administrator on how to use it, and outlines measures to avoid and minimize the potential risks and negative impacts on the environment, as well as health and safety of the community and workers, including children at school sites, during construction works. Further dissemination and training of contractors and local authorities to employ the ESMP Checklist is necessary. 7 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) The program will support budget funds for shelter construction that will be accessed by application submitted by local authorities to the MoES. The application process and approval of budget subventions is governed by the Resolution of the Cabinet of Ministers of Ukraine on “Issues regarding the establishment of safe conditions in general secondary education institutionsâ€?. The Resolution sets out geographic areas where shelters can be constructed based on approved security and safety zones (i.e. proximity to areas with security concerns). The 2024 resolution introduces new sets out criteria for scoring and decision- making regarding applications based on financial sustainability, project readiness and where the funds are needed the most to restore or continue with in-person learning in areas close to the front lines or areas that are once again under the government’s control, and other factors. Communities with lower tax capacity will be given additional scoring points to help ensure distributional equity. The MoES will use the unified national Digital Integrated Information and Analytical System (DREAM) to rank applications and promote transparent decision making. The ESSA recommends that selection criteria for future shelter subventions be developed to consider socioeconomic factors. Environmental and Social Systems Assessment for school buses. The program will also support budget subventions for general secondary schools to purchase school buses to support in-person learning by addressing transportation constraints. The Resolution of the Cabinet of Ministers of Ukraine on “Issues of providing subvention from the state budget to local budgets for the purchase of school busesâ€? has been passed by the government and will be put into effect. The resolution on school buses references the requirements for such buses, and if the school has students with limited mobility and wishes to purchase a bus for transporting wheelchairs, it specifies the applicable Ukrainian standards. The ESSA recommends that the MoES conduct additional needs assessment for transportation for children with disabilities with relevant stakeholders, and issue additional instructions to oblast/district in this regard. The ESSA also recommends that all schools should develop safety protocols (Emergency Preparedness and Response Plans) for instances of war-related hazards (for example, aerial strikes) that occur during transportation. Protocols for technical maintenance and driver’s qualification requirements are covered by existing national legislation for traffic safety and others. Environmental and Social Systems Assessment Teacher Training and Textbooks. Teacher training and textbooks activities supported under the Program are being rolled out under a broader rollout of the New Ukrainian School (NUS) curriculum. As described in the technical assessment, NUS was designed and initiated in 2018 and is aligned with EU norms and underwent extensive public consultation. No environmental and social risks of serious concern have been noted. Regarding the program activities for teacher training and textbooks; Ukrainian regulatory framework contains a wide range of policies and legislation at various administrative levels, pertaining to gender and social inclusion within the education system and applicable to development of educational materials and inclusive access of program benefits for vulnerable groups. The MoES has developed a comprehensive operational plan of measures for 2022- 2024 detailing a wide range of activities to increase staff qualifications and awareness in areas such as eliminating gender stereotypes, awareness about gender equality, and gender-based violence. The ESSA recommends that MoES establish a gender function or unit with adequate staffing to support the implementation of its operational plan. The ESSA also recommends that knowledge requirements (curriculum for teacher training, textbooks, etc.) are issued by the MoES to promote and implement feasible climate change adaptation/mitigation measures, sustainable development practices, etc. Stakeholder engagement and grievance mechanism. There are several national policies and regulations that comprise cross-cutting systems for stakeholder engagement and information disclosure across all the 8 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) program activities. In addition to obligations imposed to the MoES by the Laws of Ukraine which regulates citizen appeals, the Ministry has its own communication mechanisms. To meet the informational needs of citizens, the MoES actively utilizes social media platforms. The Ministry also operates a Hotline regarding educational issues for citizens from territories temporarily not under the government’s control. The Ministry actively conducts online consultations and has a dedicated webpage on the Ministry's website providing summaries of active and archived consultations. The Ministry also has several grievance channels consistent with Ukrainian Law, and an Ombudsman dedicated to MoES responsible for mediating and addressing complaints. Ukrainian Law does not allow for anonymous complaints. Further recommendations for ensuring the program have an accessible, effective and confidential grievance mechanism, are provided. To this end, the ESSA recommends that the MoES establishes a grievance mechanism for the program including a channel for anonymous complaints; prepares procedures for handling of GBV complaints in a confidential, survivor, and safety-centered manner consistent with good international practice, including referral protocols to qualified providers, and including guidance to schools. Conclusions and Recommendations The ESSA concludes that the environmental and social risks of the program are considered to be adequately mitigated, through committed actions in the Program Action Plan and Program Design. All recommendations will be supervised throughout bank implementation: The list below represents a summary of the actions and measures related to the ESSA that MoES is required to take during implementation of LEARN Program to improve system performance. Incorporation into project design Action and pre-effectiveness delivery Develop knowledge requirements (curriculum for teacher To be incorporated into project training, textbooks etc.) to promote and implement feasible verification protocols and Operational climate change adaptation/mitigation measures, sustainable Manual (OM) development practices etc. Develop guidance for technical requirements (for shelters, To be incorporated into project school busses and IT infrastructure) to promote and verification protocols and OM implement feasible climate change adaptation/mitigation measures, sustainable development practices etc. The following actions that will be incorporated into the Program Action Plan (PAP): 9 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) Indicators for Action Responsibility Timeline completion of actions Project management unit should The MoES ES staff should be Regular ES maintain requisite environmental hired 1 month after reporting and social staffing (1 the Program (quarterly) social/stakeholder engagement effectiveness date specialist and 1 environmental/OHS and maintained specialist) throughout Program implementation Issue a ministerial recommendation The MoES 3 months after the ES Checklist in connection to subvention for Program dissemination shelters, annually, to adopt the effectiveness date evidence Environmental and Social Checklist (Annex 1) for all shelter subvention beneficiaries, and ensure it is included in the civil works contracts. Create a comprehensive capacity The MoES 6 months from the Supervision Plan building and supervision program Program Capacity building in line with scope outlined in effectiveness and supervision Annex 3 of the ESSA. program and regular reporting on its implementation Develop safety protocols The MoES 3 months from the Report on safety (Emergency Preparedness and Program protocols Response Plans) for instances of effectiveness preparation and war hazards implementation Prepare guidance checklist for The MoES 3 months from Completion of handling of GBV complaints in a Program checklist and confidential, sensitive and survivor Effectiveness dissemination of and safety centered manner guidance consistent with good international practice, including referral protocols to qualified providers, as well as including guidance to schools. Prepare a stakeholder engagement The MoES October 2024 Plan delivered and and communication planning report document for the program implementation including the grievance mechanism thereafter. equipped to handle anonymous complaints and SEA/SH complaints 10 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) Indicators for Action Responsibility Timeline completion of actions Further to the resolution on buses, The MoES 1 month from Instructions issued conduct needs assessment on program transporting children with effectiveness date disabilities and issue instructions accordingly on purchasing buses with accessibility for children with limited mobility Confirm targeting criteria for The MoES Prior to issuance of To be integrated shelter subventions includes 2025 and 2026 into 2025 and socioeconomic factors (e.g. subventions 2026 subvention municipal tax capacity) respectively Establish a gender function /unit The MoES 6 months from Unit with staffing to support program established/staff implementation of the Operational effectiveness recruited Plan. (supported under the IPF) 11 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) 1. Introduction 1.1. Purpose and Scope of the ESSA This ESSA has been prepared by the World Bank according to the requirements of the Bank’s Policy for PforR financing for adequately managing the environmental and social effects of the Program. The ESSA aims to assess at the Program level, the potential E&S effects of the PforR (including direct, indirect, induced, and cumulative effects as relevant); the Borrower’s capacity (legal framework, regulatory authority, organizational capacity, and performance) to manage those effects; and the determination if any measures would be required to strengthen them. The specific objectives are as follows: • Identify potential environmental and social benefits, risks, and impacts applicable to the Program activities. • Assess the borrower’s environmental and social management systems for managing the identified E&S effects relevant to these activities, including reviewing the policy and legal framework and the performance track record. • Assess the extent to which the Borrower’s environmental and social management systems are consistent with the Bank’s core environmental and social principles spelled out in Bank policy and associated guidance materials (refer to Section 1.2 for further elaboration). • Based on the identified gaps, recommend, and formulate measures for inclusion in the DLIs, if any, and the PAP to enhance both the E&S management systems and the E&S outcomes during implementation. • Describe the consultation process for the ESSA, and for the preparation and implementation of the Program. The findings and recommendations of the ESSA are subsequently factored into the operation’s overall Integrated Risk Assessment, Program Appraisal Document (PAD), and the Program Action Plan, which is used as an input for the decision-making by the World Bank regarding the Program activities that may be supported under the proposed PforR. 1.2. Methodology and Consultations To prepare the ESSA of the proposed operation, the World Bank assessed the Ministry of Education and Science (MoES) environmental and social systems by analyzing available documents and working sessions with the main stakeholders, as well as relevant national legislation and practices. The ESSA is completed based on: current knowledge and supplementary research of environmental and social systems that are relevant to the program, including regulatory frameworks governing environmental and social assessment; labor and health and safety; cultural heritage; construction standards; non-discrimination, gender and disability inclusion; information disclosure and grievance redress; as well as environmental and social performance of such regulatory frameworks based on experience from other World Bank operations in Ukraine including in the education sector; reviews of existing analytical and diagnostic products, published information, and reports; and site visits to schools that have constructed protective shelters in previous years. The ESSA preparation also benefitted from broader consultations on the PforR Operation, its objectives and design, as well as its coordination with other donors and capacity building initiatives. The Program was consulted with key donors including UN agencies and key civil society organizations (CSO) and 12 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) international non-governmental organizations (INGO) and the Education Sector Working Group organized by MoES, through a series of meetings in February and March 2024. In March 2024 World Bank attended presentations of the Ukraine Education Cluster (facilitated by MoES) and the Charitable Foundation "Rokada" about “the state of bomb shelters in education institutions in Ukraineâ€? The research covered 24 regions and 101 school principals took part in it. The issues and research findings indicate the significant on-going need for school subsidies to build and repair shelters to restore in-person learning. The research also highlighted the need to have shelters with sanitation facilities, ventilation, room zoning, additional exits, provision of seats and desks for studying, and internet connection. Recommendations of the findings include launching an information campaign preceding the announcement of Subvention applications, increasing the duration of Subvention applications, allowing, the transitional nature of the Subvention for shelters in the final construction stage, prioritization based on proximity to conflict as well as budgetary features of communities. The draft ESSA was consulted at appraisal stage on July 3rd ,2024. The consultations were hosted jointly by the World Bank and the Ministry of Education and Science. Based on security considerations and recommendations for holding public meetings under martial law, as well as taking into account that virtual events are common and accessible in Ukraine ),1 consultations were conducted using an online format. Two events were organized, one that was tailored for national stakeholders, and a second session tailored for sub-national governments and local entities. The ESSA was disclosed on World Bank website, as well as MoES website (over a 3-week period) and written comments were accepted at the email address listed. The consultations were attended by 126 participants representing the following groups: management of regional departments of education, representatives of school education institutions including teachers and principals, parents of those getting school education, representatives of professional educational institutions for teachers, non-governmental organizations. The table below summarizes the main issues raised during the consultations, as well as the responses about how the issues have been taken into account. A more detailed summary of the consultations is provided in Annex. Issue Response/How considered How will the program address The program supports the implementation of NUS. Inclusion is one educational needs and of the foundational principles of the NUS reform; inclusiveness will equipment for individuals with be considered a central approach and priority in the content and special needs, consistent with subventions. MoES continues to ensure prioritization of inclusivity international norms. and schooling of students with special learning needs, as relevant and central to the NUS reform concept The issue of inclusion will be considered broadly and not limited to those with physical disabilities. 1 Analytical Report “Opinions and Views of the Population of Ukraine on State Electronic Servicesâ€? https://www.undp.org/uk/ukraine/publications/analitychnyy-zvit-dumky-i-pohlyady-naselennya-ukrayiny-shchodo- derzhavnykh-elektronnykh-posluh-u-2023-rotsi 13 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) Implementation arrangements MoES, local communities and Ministry of Finance will implement the for the Program and system component of the program, PforR. For the investment involvement of public project, project implementation unit at the MoES will be working organizations/consultants/NGOs with corresponding directorates. Additional expertise would be regarding special equipment for hired as needed, including both international and local companies children with special educational and individual technical experts. needs. Program activities including where there are considerations for students with special needs, will be consulted by MoES on an ongoing basis, including with NGOs and other stakeholders. The Stakeholder Engagement Planning Document is required to be prepared under the Program Action Plan and will set out the consultation program in more detail. In accordance with World Bank requirements, special attention is paid to needs of disadvantaged groups. How will the E&S The recommendations in the ESSA are already consistent with, and recommendations for are provided by, Ukrainian legislation. The recommendations are contractors [constructing bomb therefore mandatory regulatory requirements that are enforceable shelters] be enforced? by law. The recommendations will be part of the bidding document and the contractor must fulfill their contractual obligations. The contract can be suspended until the contractor starts working properly. MoES to focus on the quality, Both parts of the LEARN project (PforR and IPF) will support consistency and sustainability of teacher training. Under the PforR there is a focus on grades 7 and in-service teacher training, as 8 and under the IPF there will also be support for teacher training aligned with NUS. for the NUS pilot grades. During the project implementation, MoES will also liaise with pre-service teacher training institutions (e.g., pedagogical universities) as part of the project effort to improve quality of teacher training. . . 14 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) 2. Program Description 2.1. The current situation and development priorities Impact on students and teachers Since 2022, Russia’s invasion of Ukraine has critically disrupted education due to damage to educational institutions, population displacement, and trauma. As of December 2023, nearly 4,000 educational and research institutions (12 percent of the total) have been damaged or destroyed, totaling more than US$10 billion in reconstruction costs. Access to in-person schooling has been critically affected by insufficient safety infrastructure in schools and a lack of student transportation; at the same time, teaching and learning conditions in schools have deteriorated since February 2022, contributing to the accumulation of learning losses. The conditions of the teaching profession have also significantly deteriorated, prompting the government and the Bank to protect teachers’ salaries. The invasion has unequal geographical impacts and further exacerbates inequalities among children and the reliance on online learning does not ensure full access to quality education and limits caregivers’ labor market participation. Impact on educational reform The most relevant reform is the New Ukrainian School (NUS), introduced by the Framework Law on Education of 2017, which aims to modernize and radically enhance the quality of school education in Ukraine. However, the Ministry of Education and Science (MoES)’s reform plans, especially the NUS, have been severely impacted, putting in jeopardy the overall reform agenda in the education sector. The resumption of the educational reforms is essential not only to address immediate needs but also to effectively reverse the long-term impact of the current situation. Key priorities in short- and medium-term Infrastructure and NUS: the green transition is expected to shape Ukraine’s reconstruction and recovery, and the implementation of the NUS can help the country achieve these ambitious goals. The resumption of high-quality in-person education and the continued roll-out of the NUS reforms is the key priority of Ukrainian authorities in the short term. Capacity building: since the February 2022, the MoES has had limited capacity and resources to effectively provide emergency responses and implement reforms. Ultimately, the lack of resources limits the effectiveness of the MoES response and prevents education authorities from providing the necessary guidance, oversight, and expertise required to effectively implement and pilot reforms that are key to the country's long-term development. Meanwhile, it is important to note the key role played by municipalities to ensure the continuity of education services. Yet, given the current challenges and relatively recent introduction of the decentralization process, municipalities have important capacity capacity-building needs as well. 2.2. State Program Scope The MoES presented in March 2024 its Strategic Action Plan for 2024-2027, which provides the policy framework for investments and reforms in the education sector to transform the education system. The Strategic Action Plan is organized into nine priorities, covering all sub-sectors of the education system. The Strategic Action Plan aims to comprehensively transform the education system, with investments and reforms planned at each level of education, each with 3-5 strategic goals and targets. 15 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) The Strategic Action Plan aims to build on the previous reform agenda across sub-sectors and further deepen it to transform the education system and address the impact of the invasion. Critically, this plan aims to take stock of previous reform implementation and address bottlenecks where required. 2.3. PforR Program Boundary and Scope The Program will focus on Strategic Action Plan Priority 2: School education and the NUS through a combination of emergency actions to restore in-person education with initiatives to promote the quality of education. The continuation of the NUS reform is a key priority of the MoES. By focusing on school education from grade 1 to 12, the Program supports the largest education subsector, currently serving 3.8 million students and close to 400,000 teachers, and pursues a strategic impact on students’ foundational skills, while also serving as a model for broader educational reforms. Priority 2 also represents 55 percent of the total financing of the Strategic Action Plan. The Program will have a nationwide scope (excluding territories temporarily no longer under the government’s control and territories close to the frontline2) and will align with the implementation period of the Strategic Action Plan. To contribute to restoring access to in-person education, the Program will support students' access to safety protective structures in their schools (decree #419-2023) and free school transportation (decree #100-2020). To improve teaching and learning conditions in basic education, the Program will support the development of teacher capacities and the equipment of basic education schools with textbooks and materials according to the NUS standards. The World Bank PforR will provide US$385 million of financing, supporting a broader counterpart financing of US$11.8 billion. The program scope also includes salaries of teachers and pedagogical staff who are part-time or full time under public service employment contracts. Table 1: Program boundary and projected costs Projected Projected costs PforR Program Reasons for non- Priority 2024 – 20273 2024 – 20274 alignment (US$ million) (US$ million) 2. NUS Reform 11,828 1,0565 Includes only 8.3% of teacher salaries budget lines and excludes unconfirmed capital expenditures Total 2024 – 2027 11,828 1,056 In alignment with the Strategic Action Plan goals, the Program will focus on: 2 Zone is determined by Order of the MoES (Decree of the Cabinet of Ministers of Ukraine) based on security and risk across territories. 3 These investments represent the amount of central budget projected to be dedicated to education within the next years. A large share is dedicated to the payment of salaries, especially of school teachers, but it also includes key investments for the provision of in-person learning and high-quality education. 4 Corresponding to the World Bank’s FY25-27 5 The counterpart financing estimated at US$572 million and World Bank financing of US$385 million 16 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) • Strategic Goal 2.1: School students learn in a safe, modern, and inclusive educational environment. • Strategic Goal 2.2: School students receive quality education following the NUS principles. • Strategic Goal 2.4: Pedagogical teams of education institutions work based on partnership principles and implement the NUS principles. PforR Results Areas: Results Area 1: Improving teaching and learning conditions according to NUS principles focuses on ensuring the provision of safe, high-quality in-person education, through the implementation of a competency-based and student-centered curriculum. As a contribution to the quality of teaching and learning, this Results Area will focus on improving students’ safety and teaching practices and materials aligned to the NUS reform. The Results Area will support critical government subprograms aimed at improving teaching and learning conditions implemented through subventions from the state budget to local budgets, including (a) Students’ and teachers’ access to safe conditions for in-person teaching and learning through climate-resilient and energy efficient shelters in selected schools and free, inclusive, and low-emissions bus transportation to schools (in line with the latest fuel efficiency standards in Ukraine, EURO5 or EURO6); and (b) Teachers’ and managers’ professional development to implement the NUS reform through high quality training on NUS curriculum and standards, including training on climate and environmental awareness, green skills for the green transition, and responding to climate-related disasters. The Program will also support (c) the provision of updated textbooks and teaching materials aligned with NUS principles of competency-based and student-centered education, including climate and environmental awareness and green skills for the green transition, provided nationwide by the central state budget. The combination of these interventions will enhance students’ academic and socio- emotional learning and psychosocial wellbeing because of social interactions and a more pleasant environment, while promoting a positive and safe learning environment that is resilient to the impacts of current challenges and local climate-related risks, such as floods, mudslides, extreme heat, and droughts. DLI 2 focuses on ensuring the basic safety and security of students and teachers attending selected schools that will benefit from climate-resilient and inclusive access to shelters, enabling the schools to open and operate and DLI 4 will support the procurement of buses providing free transportation under the state subvention. DLI 5 and DLI 6 also supports instructional aspects of the implementation of the NUS reform for grades 7, 8, and 9 through the training of teachers according to an updated teacher development plan aligned with the NUS reform (DLR 5.1); and ensuring that all (DLR 6.1) students, including those with disabilities, will receive updated textbooks aligned with the NUS, including content related to climate and environmental awareness and green skills for the green transition, supported by the state budget. Results Area 2: Improving management capacity is focused on promoting a more efficient, transparent, and equitable management of sector funding programs. It will focus on results that demonstrate a progressive improvement in the management of state subvention programs to the regions. To this end, the Results Area will focus on improving the government’s capacity to distribute resources efficiently, through changes in the regulations, budget allocations, and management procedures applied in the subventions to the regions. First, these changes will aim at updating the allocation criteria of the shelter and bus subventions through: i) data-based methods of selection of schools and municipalities to be supported by the state budget, including climate risk considerations; ii) the prioritization of vulnerable groups and/or high-need areas, for example students lacking transportation to school, schools exposed to climate hazards (floods, mudslides, extreme heat and droughts), and students with disabilities and iii) enhanced use of systems for the planning, targeting, and monitoring of the subventions. Second, Results Area 2 will support the school network optimization efforts in the context of the declining demographic 17 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) trends. The operation will contribute to the adjustments to the education subvention (teacher salaries), gradually increasing the minimum number of students per school required to receive the subvention, as a way to incentivize the municipalities to reorganize the school network according to the actual demand. However, there are exceptions to mitigate risks; for example, primary schools serving grades 1-4 would be excluded. Also, as a mitigation measure to support students participating in small schools that can eventually be closed, the program is contributing to increase the buses for the free and safe transportation of students to other schools. Result Area 2 also focuses on increasing the efficiency, equity, and transparency of subvention management by (i) strengthening the shelter subvention (DLI 1) with improved management due to, inter alia, the use of the government's Digital Restoration Ecosystem for Accountable Management (DREAM) system to allocate resources, a prioritization of schools closed for in-person education located in municipalities with higher risks, and direct disbursement mechanisms from the State to municipalities and schools; (ii) strengthening the bus subvention (DLI 3), whose allocation will be improved through, inter alia, the use of data to identify existing gaps in access to school transportation, prioritizing students with disabilities, and using an improved disbursement mechanism directly to the municipalities; and (iii) strengthening the education subvention (teachers' salaries, DLI 7), which, as a measure to optimize the education network, will change the formula for allocating resources through a gradual increase in the minimum number of students required to receive the state subsidy. The two results areas would specifically rely on subventions from the state budget to local budgets, ensuring the targeted allocation of funds. Subventions for the establishment of bomb shelters, for the provision of school buses, and for the roll out of the NUS (learning materials and teacher training) are allocated based on a competitive selection, prioritizing the needs at the local level and capacity of implementation. As a result, these resources can be targeted to ensure impact and maximum benefit. IPF Component The IPF component will complement the PforR by supporting the implementation of the NUS reform in upper grades (8-12) and strengthening the MoES’ capacity for education system’s management. Given the current capacity challenges to ensure the rollout of the NUS in upper grades, the IPF will support MoES in the preparation and implementation of the pilots in grades 8 to 12 that will be implemented in the upcoming years, priori to be scaled up nationwide. The support will include the development of educational content and teacher’s and managers’ professional development, as well as the procurement of laboratory and IT equipment aligned with the NUS in pilot schools. Importantly, the IPF will also enhance the management capacity of the MoES related to the NUS, to specifically strengthen the relevant Directorates in planning and monitoring, data and evidence generation and financial planning. Thus, the IPF will cover technical assistance through consulting services (individual and firms) and goods (equipment and supplies) to ensure successful implementation of the NUS. The support would also include an impact evaluation of teachers’ practices. Also, the IPF will also support other MoES areas to ensure the delivery of key reforms planned in the Strategic Action Plan, such as preschool education, technical and vocational training, among others. Finally, the IPF will support Program management through a dedicated Project Implementation Unit (PIU) in the MoES. The implementation arrangements and organizational capacity The LEARN PforR would be implemented using a two-tier structure led by the Ministry of Finance (MoF) and the MoES. In line with National Legislation, MoF will manage overall Program coordination as the coordinating agency, collaborating closely with the MoES, which will act as the executing agency for policy implementation in the education sector. In parallel, the MoES’s existing PIU would continue to be 18 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) strengthened, including through the hiring of consultants, to support both the PforR and IPF components. Emphasis would be placed on ensuring the capacity to successfully implement and monitor the subventions. Both Ministry of Finance and Ministry of Education have on-going IBRD projects with adequately staffed PIUs with experience implementing projects under ESF, though both projects have limited application of ESF (rated Moderate). Under the PforR component, the MoES will have the ultimate responsibility for managing the financial management and procurement aspects of the government expenditure program, even when subvention funds are implemented by local (municipal) governments, in line with existing government arrangements and implementation systems. Inter alia, the local (municipal) governments will be responsible for the process of preparing technical design, obtaining necessary permits, and ensuring compliance with national legislation and building codes (including environmental legislation, Labor Code etc.). The MoES has an on-going World Bank supported IPF project, with established PIU and experience implementing projects under ESF (Ukraine Improving Higher Education for Results Project). This Project is in the process of recruiting one Social/Stakeholder Engagement Specialist and one Environmental/OHS Specialist. The MoES PIU will also be responsible for implementation of the PforR Operation including the IPF component (including procurement, financial management, environmental and social aspects and monitoring and evaluation). The MoES PIU ES staff will be responsible for implementation of the ESF instruments (IPF) and environmental and social aspects of the PForR including the related activities under the Program Action Plan. For example, they will be tasked with capacity building measures (development of relevant guidance, templates etc.), as well as regular supervision and monitoring activities to support local governments and beneficiaries. The MoES PIU will be funded through the IPF component of the PforR. There are no consistent reports on the implementation results of shelters/busses subsidies for the previous years, however, based on anecdotal evidence provided by the MoES on the ongoing shelter constructions in 2023, there are number of non-compliance issues in construction practices in waste management, OHS and community health and safety aspects. 19 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) 3. Description of Expected Program Environmental and Social Effects 3.1. PforR component ES risks overview Environmental risks are rated Substantial. The proposed Program will lead to some long-term environmental benefits: improving safety conditions; positive effect on air pollution from switching to low- emission public transportation; creating more sustainable approach to planning and executing transportation services; integrating sustainability education into the revised curriculum; fostering environmental literacy; reducing the environmental impact associated with paper usage. At the same time, the program will result in number of environmental risks and impacts mostly associated with project-related civil works (for rehabilitation/installation of infrastructure/equipment) and operation of new/refurbished facilities and equipment. Rehabilitation and construction-related risks include potential increased pollution due to improper care, handling and storage of construction material and waste; temporary impact on cross drainage; water/soil quality impacts in case of construction pollution as well as pressures on the environment caused by the material sourcing; generation of excessive noise and dust levels from trucks and other construction machinery; soil disturbance during earthworks; tree-cutting and loss of vegetation; negative impact on ecosystems (through disturbance); management of household and construction waste; traffic safety issues; community and workers’ health and safety incidents. Potential operational risks for shelters include health and safety risk from shelter damage due to design or execution flaws due to the urgency associated with ongoing conflicts (structural collapse, malfunction of ventilation or sewage systems, fire safety etc.), as well as other operational risks (lack of adequate water supply and sanitary conditions; increase in energy consumption etc.). School buses operations-related risks include potential negative effect if busses are not operated and maintained properly due to lack of funds and/or qualified staff/equipment; potential negative effect on the health and safety of the beneficiaries due to lack of emergency protocols (actions in case of traffic accident, aerial missile alarm etc.). These risks are site-specific and temporary and can be mitigated by existing construction and healthcare management best practices. However, these risks may be exacerbated by potential aerial strikes and other military actions which add an element of extreme uncertainty and risk of fatality or serious injury that cannot be entirely mitigated by environmental and social management measures (these risks also apply to in person trainings if not considered in the training standard). Also, there is a risk that project sites may become a target for aerial strikes which will endanger nearby communities and site workers. Other related risks include possible site contaminations with hazardous compounds and explosive remnants of war (ERW). The social risks are rated Substantial. The proposed operation will have positive social effects by increasing access to in-person learning and improving teaching and learning conditions in Ukraine. The Program activities are nationwide in scope but excluding territories temporarily no longer under the government’s control and territories close to the frontline. However, the overall community and worker health and safety and security risks in the education sector remain volatile and are also highly contextual, beyond the immediate control of the borrower. Further the operation is designed to help mitigate these impacts on the education system in Ukraine and build resilience against future shocks. The key potential direct adverse social effects are associated with the construction and rehabilitation of approximately 286 protective structures within existing schools that are supported under PforR Results Area 1; for example, if the structures are not constructed properly leading to collapse or injury during operation, or if health and safety of workers and community (including children at school sites) are affected by the works. The 20 P504171 - Ukraine Lifting Education Access and Resilience in times of Need (LEARN) Program Environmental and Social Systems Assessment (ESSA) works are small to moderate in scale and the can be mitigated with good practices in contractor management and health and safety including considerations for child safety near construction sites and war-related emergencies and hazards for workers. Land acquisition will be excluded from the program. Other social risks of the program are related to ensuring that the benefits (e.g., school shelters, buses, textbooks, teacher training) are designed to be inclusive, and accessible to vulnerable individuals and groups, for example by reaching the poorest children, and children with disabilities. 21 3.2. Detailed Screening of Environmental and Social Effects Relevance to ESSA Relevant DLIs Activities Environmental Effect Social Effect Core Principles (CPs) Results Area 1: Improve teaching and learning conditions according to NUS principles DLI 2: • Ensure funding and • Benefit of improved safety conditions in • Benefit of increased access to in-person CP1 Additional construction (or refurbished or newly built shelters by education, continuity of education CP2 students and renovation/rehabilita providing a secure environment for during conflicts, minimizing disruption teachers with tion) of safe, inclusive students and staff during aerial missile to student’s learning and improvement CP3 and climate-resilient access to alarms of teaching and learning conditions. CP5 shelters at schools. constructed or • Potential short-term negative effects • Potential negative effect if shelters are rehabilitated related to construction: noise, dust, not accessible for people with CP6 shelters vegetation clearance, storage and handling disabilities. of construction and hazardous materials • Potential negative effects to historical and waste, workers health and safety, heritage during construction of shelters community health and safety issues in school basements (including traffic safety) etc. • Potential negative effects from not being • Potential long-term health and safety risk able to use the shelter over the long from shelter damage due to design or term, or from injuries to shelter users in execution flaws due to the urgency the case of shelter collapse as a result of associated with ongoing conflicts low-quality construction. (structural collapse, malfunction of • Potential negative effects from risks of ventilation or sewage systems, fire safety, gender-based violence in the shelters. etc.) • Potential risks of social • Potential health risks from improper tensions/distributional inequity if operation of shelters (lack of adequate shelters are not awarded to schools in a drinking water supply, lack of proper transparent and equitable manner. sanitary conditions, etc.) • Potential increase of energy consumption for heating/air conditioning of shelters • Coordination complexities between ministries, local governments, school authorities, construction communities could impact implementation efficiency and effectiveness. • Capacity and resource constraints within the responsible institutions to operate and maintain shelters effectively over a long time. DLI 4: Additional • Procurement • Minor positive effect on air pollution from • Students, particularly in remote and CP1 students with of school buses switching to low-emission public rural communities, will benefit from safe CP2 access to free transportation (as opposed to old school transportation during extreme weather bus busses or using personal vehicles for events and permanent access to in- CP3 transportation transportation) person education. CP5 • Potential long-term effect from creating • Potential negative effects if children with sustainable approach to planning and limited mobility or special needs do not CP6 executing transportation services (i.e., have access to buses. change of mindset) • Potential negative effects from risk of • Potential negative effect if busses are not road accidents in areas where children operated and maintained properly due to are likely to be walking on or playing in lack of funds and/or qualified the road, instead of off the road. staff/equipment. • Potential negative effects if buses can’t • Potential negative effect on the health and be used over the long term because safety of the beneficiaries due to lack of there is insufficient budget for emergency protocols (actions in case of maintenance of buses. traffic accident, aerial missile alarm etc.) • Potential risks of social tensions/distributional inequity if buses are not awarded to schools in a transparent and equitable manner DLI 5. Teachers • Teacher training plan • Long-term down-the-line benefits from • Expected benefits from improved CP1 trained to for nationwide rollout integrating sustainability education into learning outcomes and professional CP5 implement the of NUS reform for the revised curriculum; fostering development for teachers who NUS reform grades 7, 8, and 9 environmental literacy. implement the New Ukrainian School CP6 adopted. • Potential safety risks and emergencies in (NUS). • Train teachers for the event of air strikes for in person • Potential exclusion risks for children grades 7 to 9 on NUS curriculum trainings (if not considered in the training with special educational needs if teacher standard) training in this area is inadequate. and education • Potential negative effects if gender is not standards adequately considered and addressed in teacher training. • Potential risks of unequal access to training opportunities for teachers. DLI 6. Students • 2024 textbooks • Long-term down-the-line benefits from • Benefits from new textbooks and CP1 with access to decree establishes integrating sustainability education into educational process according to the CP5 NUS Teaching & that 100% of grade 7 the revised curriculum; fostering principles and approaches of the “New Learning students, including environmental literacy. Ukrainian School.â€? CP6 those with Materials • Gender and social inclusion risks disabilities, will receive NUS-aligned associated with textbook content or textbooks. formats. • Development and procurement of books Results Area 2. Improving management capacity DLI 1. • Update allocation • Paperless administrative processes • Socioeconomic benefits from more CP1 criteria for shelters (digitizing forms, reports, and efficient use of financial resources to Updated CP5 subventions to the communication channels) reduce the target hub schools. allocation criteria for the regions prioritizing environmental impact associated with • More equitable distribution of funds to CP6 hub schools paper usage the regions with greatest challenges for shelter’s working in distance continuity of education, as they border subvention to or hybrid mode, the frontline and/or have had some the regions located in high- territories which came back under the need regions, and government’s control, which require utilizing the DREAM rehabilitation of learning spaces. system for project • Positive benefits of increased processing. transparency by using the DREAM system. DLI 3. • Update allocation • Paperless administrative processes • Positive socioeconomic benefits from CP1 criteria of the bus (digitizing forms, reports, and increased efficiency and equity in the Updated CP5 subvention to the communication channels) reduce the allocation criteria of 2024 school bus allocation regions based on environmental impact associated with subvention to the regions that need it CP6 criteria for the data driven needs paper usage most depending on proximity to front school bus assessment line. subvention to prioritizing high- the regions need regions and streamlined redistribution mechanism. DLI 7. Support • update 2025 and • Paperless administrative processes • Overall positive socioeconomic benefits CP1 for school 2026 education (digitizing forms, reports, and from optimizing use of resources CP5 network subvention formula communication channels) reduce the (including towards teacher salaries) at optimization (including towards environmental impact associated with consolidated schools. CP6 teacher salaries) to paper usage • Potential social tensions if school increase minimum consolidations are not sufficiently student consulted or communicated. requirement per school 3.3. Exclusion Criteria Consistent with World Bank PforR Policy requirements, the Program will exclude any activities or expenditures that are likely to have significant, sensitive, diverse or unprecedented impacts to the environment and/or affected people. Such activities include significant land acquisition, economic or physical displacement or changes in land use, and significant impacts to critical cultural heritage sites or natural habitats. Screening against the exclusion criteria have has been completed of program activities and expenditures required to meet the PDO and results areas, at time of ESSA preparation. The following exclusion criteria apply to the PforR: (i) Significant conversion or degradation of critical natural habitats or critical cultural heritage sites (ii) Air, water, or soil contamination leading to significant adverse impacts on the health or safety of individuals, communities, or ecosystems. (iii) Workplace conditions that expose workers to significant risks to health and personal safety, such as in areas under conflict (the program excludes activities in territories temporarily no longer under the government’s control and territories close to the frontline6) (iv) Land acquisition and/or resettlement of a scale or nature that will have significant adverse impacts on affected people or the use of forced evictions. (v) Large-scale changes in land use or access to land and/or natural resources (vi) Adverse E&S impacts covering large geographical areas, including trans-boundary impacts, or global impacts such as greenhouse gas (GHG) emissions. (vii) Significant cumulative, induced, or indirect impacts (viii) Activities that involve the use of forced or child labor. (ix) Marginalization of, or conflict within or among, social groups; or Activities that would have adverse impacts on land and natural resources subject to traditional ownership or under customary use or occupation. 3.4. IPF component ES risks The IPF component of the operation is comprised of capacity building activities, development of educational methodologies to support the piloting and rollout of the NUS curriculum in higher grades; procurement of laboratory and IT equipment; as well as sectoral and infrastructure planning and monitoring. These technical assistance activities have minimal environmental and social impacts in themselves; however, they introduce worker and community health and safety risks during in-person capacity building and other development activities taking place during an active conflict in Ukraine. The project will prepare Emergency Preparedness and Response Plan (as a standalone document accessible to the wide audience) applicable to all such activities. The ESCP has been disclosed before Appraisal specifying that the ToRs for the contractual services for various TA activities will be designed to promote sustainable approach to 'build back better', principles of circular economy and climate-informed designs, carried out in accordance with terms of reference acceptable to the World Bank that are consistent with the ESSs and EHS Guidelines. An E-Waste Management Plan will be prepared and disclosed prior to the start of relevant activities. The ESCP describes the Labor Management Procedures. The Project has prepared and disclosed a draft Stakeholder Engagement Plan that will be further consulted, finalized and adopted, before the project effective date. A central focus of the SEP is to ensure that technical assistance activities supporting the rollout of the New Ukrainian School (NUS) curriculum in higher grades, consider 6Zone is determined by Order of the MoES (Decree of the Cabinet of Ministers of Ukraine) based on security and risk across territories. 26 accessibility and connectivity for STEM and IT equipment, and principles of universal design for learning, for vulnerable groups. 4. Assessment of Borrower’s Environmental and Social Management Systems This section provides an assessment of the extent to which the applicable systems are consistent with the core principles and key planning elements expressed in the Bank’s policy on PforR. It also provides a review of the implementing agencies capacity and aspects where gaps exist between Bank policy requirements and the country systems. The six core principles that guide the ESSA analysis are presented in the Bank Policy and Bank Directive Program-for-Results Financing and include: • Core Principle 1: General Principle of Environmental and Social Management. This core principle aims to: (a) avoid, minimize, or mitigate adverse impacts; (b) promote environmental and social sustainability in Program design; and (c) promote informed decision-making relating to the Program’s environmental and social effects. • Core Principle 2: Natural Habitats and Physical Cultural Resources. This core principle aims to avoid, minimize, or mitigate adverse impacts on natural habitats and physical cultural resources resulting from the Program. • Core Principle 3: Public and Worker Safety. This core principles aims to protect public and worker safety against the potential risks associated with: (a) construction and/or operation of facilities or other operational practices developed or promoted 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. • Core Principle 4: Land Acquisition. This core principle aims to manage land acquisition and loss of access to natural resources in a way that avoids or minimizes displacement, and assist affected people in improving, or at a minimum restoring, their livelihoods and living standards. • Core Principle 5: Indigenous Peoples and Vulnerable Groups. This core principle aims to give due consideration to the cultural appropriateness of, and equitable access to, Program benefits, giving special attention to the rights and interests of the Indigenous Peoples and to the needs or concerns of vulnerable groups. The core principle also emphasizes the need of giving 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. • Core Principle 6: Social Conflict. This core principle aims to avoid exacerbating social conflict, especially in fragile states, post-conflict areas, or areas subject to territorial disputes. In analyzing a program for consistency with the sustainability principles of OP/BP 9.00, the ESSA is intended to ensure that programs supported by PforR financing are implemented in a manner that maximizes potential environmental and social benefits and avoids, minimizes or mitigates any and all adverse environmental and social impacts and risks. Essentially, the ESSA process seeks to improve institutional performance related to the program’s development objectives. 27 For this PforR operation, the ESSA examines Ukraine’s existing environmental and social management systems as applicable to the program’s activities in the education sector, and their ability to manage all adverse impacts and risks identified in the previous chapter. The ESSA describes the potential environmental and social effects associated with the PforR supported activities. The ESSA also assesses institutional roles and responsibilities related to implementing the DLIs and describes current capacity and performance to carry out those roles and responsibilities in line with each of the six Core Principles outlined above. The ESSA also considers public participation, social inclusion, and grievance redress mechanisms in place and as applied to the PforR. It is important to note that the ESSA will be updated based on the feedback received from stakeholders and implementation experiences of the PforR implementation. 4.1. Assessment of Borrower E&S Systems against Core Principle 1 (General Principle of Environmental and Social Management) Ukraine has formally aligned its legislation with the EU’s Environmental Impact Assessment (EIA) Directive and the Directive on Strategic Environmental Assessment. Also, after signing the Association Agreement with the EU, Ukraine became a signatory to environmental and sustainable development international conventions and adopted a wide range of legal acts and programs. The scope of Ukrainian environmental legislation is comprehensive (more than 300 legal acts) and covers most areas of environmental protection and natural resources management. However, the country’s environmental legislation faces several weaknesses: • The legislation is largely declarative in nature and does not have all the essential enforcement mechanisms for implementing legal acts and international agreements, especially due to limited capacity of responsible authorities due to ongoing situation in Ukraine; and • Many of the acts are not coherent with each other. The remarks from the European Commission (Commission Opinion on Ukraine’s application for membership of the European Union) state that there’s still a significant level of non-compliance of national legislation pertaining more to cross-sectoral issues such as environmental impact assessment and environmental liability: “…legislation on environmental impact assessments and on strategic environmental assessment… needs addressing… procedural irregularities and uneven enforcement.â€? Environmental matters that should be considered during the construction and operation of civil infrastructure are generally governed by the Law of Ukraine on Environmental Protection, On the Protection of Atmospheric Air, On the Protection of Land, and On the Environmental Impact Assessment. State Construction Norms and State Sanitary Norms set specific standards for the construction of buildings and, depending on the construction class and its complexity, the construction may require a notification on commencement of the construction work or a building permit. Environmental Impact Assessment Per Law of Ukraine ‘On Environmental Impact Assessment’ (adopted on 18.12.2017), Environmental Impact Assessment (EIA, Ukrainian abbreviation is ‘OVD’) is a procedure that implies: 1) the preparation of an EIA report by the business entity. 28 2) public consultations. 3) the examination by the competent authority of the information presented in the EIA report and any supplementary information, as well as the information received from the public through the public consultations. 4) the reasoned EIA conclusion by the competent authority, which takes into account the results of the examination referred to in subparagraph 3; and 5) consideration of the EIA conclusion in the decision to conduct the planned activities. EIA Law provides lists of activities that require EIA (falling into first and second category, based on technology and scale of impact) depending on the screening results. Full-scale EIA is the only instrument applied to the planned investment projects. Article 6 of the Law provides for the draft scope and scale of EIA: • factors: human health, state of fauna, flora, biodiversity, land (including land take), soil, water, air, climate factors (including climate change and greenhouse gas emissions), material assets, including architectural, archaeological and cultural heritage, landscape, socio-economic conditions and the interaction among these factors. • impacts: size and scale, type (where present – transboundary), intensity and complexity, probability, expected start, duration, frequency and irreversibility of effects (including the direct impacts and any indirect, secondary, cumulative, transboundary, short-term, medium-term and long-term, permanent and temporary, positive and negative impacts). When preparing the EIA report, the commercial entity takes into account the comments and proposals made by the public and authorized territorial authority, and a level of detail of information to be included in the EIA report, in their entirety, partially, or declines such comments and proposals stating a reason for its decision. Resolution No.1010 of the Cabinet of Ministers of Ukraine dated December 13, 2017, provides Criteria for determining planned activities that are not subject to EIA. This resolution has been updated in October 2022 to include rehabilitation activities for assets damaged by war or other emergencies and necessary for livelihood and daily necessities of population (road, rail, district heating, water supply etc.), as well as construction of military and defense facilities, which are used exclusively to ensure the defense of the state. Assessment of Impacts on Environment As per State Building Norms DBN A.2.2.-1-2003, Assessment of the Impact on the Environment (AIE, Ukrainian abbreviation is ‘OVNS’) is a process of the determination of the scales and levels of environmental impacts of designed activity, development of anticipatory or mitigation measures for reducing of these impacts – an assessment of eligibility of projects’ decisions from the environmental point of view. AIE plays the role of pollution control procedure and, in the first place, has to examine and provide for compliance and enforcement of ecological and environmental standards, norms and regulations as the 29 consequence of planned activity. AIE is conducted according to strict regulations and is usually done by the environmental expert in the overall design team. AIE is a part of the project design rather than planning process. Design process starts when a decision on implementation of economic activity has been already approved. In that way, AIE loses its decision-making relevance, since it is being carried out as a part of justification of already taken decision. Any project requiring design documentation will develop AIE as a part of their design except for those that require EIA: projects requiring EIA do not develop AIE as part of their design and only submit EIA conclusion in its stead. 4.1. (a) Avoid, minimize, or mitigate adverse impacts and (c) Promote informed decision-making relating to the Program’s environmental and social effects DLI 2 foresees construction of new bomb shelters in schools or reconstruction/refurbishment of existing basements/underground facilities into bomb shelters in schools. The founder of an educational institution7 is obliged to ensure the maintenance and development of the material and technical base of the educational institution founded by him at a level sufficient to meet the requirements of educational standards and licensing conditions. If the founder of the educational institution is the local government, it is responsible for arranging a shelter (this applies to most educational institutions). According to the Procedure for the creation, maintenance of the fund of protective structures of civil protection and its accounting, the balance keeper of the protective structure — the owner of the protective structure — must take care of the protective structures buildings or a legal entity that maintains it on the balance sheet, and these are the founders of educational institutions. Requirements for the maintenance and operation of civil protection structures protection, criteria for the impossibility of further maintenance and operation protective structures of civil defense, drawing up documents confirming such impossibility, as well as defining sample documents paper accounting of the fund of protective structures, introduction of their system numbering was approved by the Ministry of Internal Affairs by order "On approval of requirements on issues use and accounting of the fund of protective structures of civil protection". Construction of school shelters The Law of Ukraine ‘On EIA’ does not list construction/reconstruction of bomb shelters as substantial or high-risk activity, hence no separate environmental and social risk assessments need to be prepared for such projects and basic information relevant for environmental impacts would be covered under the AIE section of design document. Also, State Construction Norm DBN V.2.2-5:2023 ‘Protective buildings of civil defense’ (the main document outlining the design requirements for school shelters), CMU Resolutions of 7 The founder of an educational institution can be: a state authority on behalf of the state; the relevant council on behalf of the territorial community (communities); natural and/or legal entity, by whose decision and at the expense of whose property the educational institution was founded. The founders of the prevailing number of communal educational institutions: preschool, after-school and general secondary education - are village, settlement or city councils of the respective territorial community. Usually, the founder creates an authorized body (the education management body of a separate community - department, administration or department of education) and delegates to it part of the powers granted to them by law. (source: ) 30 subventions for shelters constructions, other technical guides and requirements relevant to such projects do not specifically outline potential ES risks and impacts and applicable ES mitigation measures. All the potential risks of such activity (including OHS, community health and safety, biodiversity impacts, waste management, etc.) should be mitigated by the existing construction practices mandated by the vast collection of construction standards and norms, sanitary norms and rules, labor Code of Ukraine, legislative and normative base of protection of natural resources etc. However, past experience and practical information from similar construction sites show that some of the national legislation on OHS, community health and safety, waste management and resource efficiency are sometimes overlooked and/or neglected – partially, due to the lack of knowledge of the workforce, due to the lack of supervision and guidance, but also to speed up the process and save the budget (for mitigation measures). These photos were taken from different sites across the country where construction of bomb shelters is ongoing and show different incompliences with ES/OHS requirement of ukrainian legislation: lack of fencing of deep trenches/holes, lack of retaining walls, lack of PPE, improper storage of soils and construction waste, lack of dust prevention measures etc. To provide the needed guidance to workforce and project beneficiaries of the applicable ES requirements and standards for work execution, the Ministry of Education and Science has prepared ‘The ES 31 requirements for construction, reconstruction, restoration, major repair projects of the civil defense shelter objects within school’ in the form of a checklist (see Annex 1). These general Environmental & Social guidelines are presented in abbreviated form with the main objective to avoid and minimize the potential risks and negative impacts on health and safety of the community and workers, as well as the natural environment, during construction works. The checklist also considers that works will take place on school premises, and extra precautions are needed to protect children. The ES Checklist was developed to ensure that good practice mitigation measures are recognized and considered during the project’s activities implementation. The ES Checklist was developed to provide “best practice examplesâ€? and is intended for the convenience of users and is compatible with the requirements of national law. The ES Checklist comprehensively addresses all potential impacts identified in the ESSA, along with appropriate mitigation measures. This ES Checklist is intended to support the project administrator with the following tasks throughout project implementation: 1) Procuring Works: The E&S Checklist will be included in the works contract, as well as in the services contract with supervising entity for the execution of construction works under the project. If the project site has specific conditions or project activities envision risks not covered by this E&S Checklist, the project’s administrator will take an effort to expand and update this Checklist to cover all additional E&S risks and impacts and should incorporate these requirements into construction contracts. 2) Before Works begin: Project Administrator (as advised by the Supervising Entity if applicable) ensures the contractor has the requisite environmental and social risk management measures and/or plans, before start of works. No project’s implementation activities (no physical works including site preparation, offloading equipment and materials, civil works etc.) are allowed to start before the required environmental and social risk management measures are in place. 3) Monitoring Works: The project’s administrator directly or through a contracted supervising entity should receive regular reports on implementing the environmental and social mitigation measures and should inspect work sites and the work of personnel on a regular basis to identify issues or non-conformity and enforce necessary actions where unsafe acts or processes that seem dangerous or unhealthy are detected. The environmental and social performance of contractors at all times should meet the project’s environmental and social requirements. ESSA recommends: the MoES Issue ministerial recommendation adopting the ES Checklist (Annex 1) for all the shelter subvention beneficiaries to be then included in the civil works contracts. The MoES should also issue guidance on the supervision/monitoring of civil works by beneficiaries (school and/or local government administrations). Operation of school shelters To determine whether the shelter available in the educational institution allows to start full-time training, at the level of local self-government bodies, the founder institution creates a special commission that examines buildings (buildings, premises) in order to establish the possibility of using them for shelter as dual-purpose structures and the simplest shelters. Specialists from the structural subdivisions on issues of education and science, civil protection, and urban planning are included in the composition of the commission by agreement and architecture, health care 32 of central and local executive bodies, local self-government bodies, as well as specialists of territorial bodies and local divisions of the State Emergency Service, the State Production and Consumer Service, etc.8 The requirements for the maintenance and operation of civil protection facilities were approved by the Order of the Ministry of Internal Affairs in 2018 and regulate matters related to the maintenance and operation of civil protection facilities, dual-purpose structures, rapidly erected civil protection facilities, and the simple design protection structures, as well as their accounting. According to the applicable technical standards, shelter facilities should be equipped so that participants in the educational process can stay there for up to 48 hours. For this, even the simplest shelters must be provided with9: • places to sit. • drinking water at the rate of 2 liters per day per person • non-drinking (technical) water for sanitary needs (in the absence of a centralized water supply). • containers for storing products. • portable sewage tanks (if the building does not have sewage) • backup lighting sources (electric lanterns, candles or kerosene lamps) • primary fire extinguishing means • means of providing medical assistance • means of communication and notification (telephone, radio receiver) • tools (bayonet and scoop shovels, crowbars, axes, hacksaws for wood, metal, etc.). All shelters should be equipped with adequate water supply and sanitation facilities, and designed for structural stability, energy efficiency, and universal access. In 2023, the Order of the Ministry of Internal Affairs of Ukraine and the Ministry of Education and Science of Ukraine, which approves the Procedure for early warning and evacuation of participants in the educational process in the event of an aerial missile alarm at an educational institution, entered into force. The Procedure determines the response mechanism of the founders, managers and employees of educational institutions, as well as the police and emergency services regarding early warning and evacuation of participants in the educational process in the event of an attack or risk of an attack. As per Procedure, the head of the educational institution in collaboration with its staff must10: • organize, ensure and control the implementation of measures aimed at creating safe conditions for students to stay in an educational institution. • develop and approve the evacuation plan, the procedure for notifying students and educators, and algorithms for their actions. • create a response team, approve its composition (at least three employees) and distribute responsibilities among them. • take measures to prevent unauthorized access to the territory of the educational institution. 8 Source: https://decentralization.ua/uploads/library/file/891/pdf.pdf 9 Source: https://finance.ua/ua/goodtoknow/ukryttia-dlia-szkil 10 Source: https://nus.org.ua/news/rannye-poperedzhennya-ta-evakuatsiya-iz-zakladu-osvity-v-razi-napadu-abo-ryzyku-napadu- nabuv-chynnosti-nakaz-mvs-i-mon/ 33 • to provide a comprehensive survey of the state of the objects of the fund of civil defense protective structures, the route of movement to them, signs, the reliability of the protection of the educational institution (at least once every six months) • ensure that the participants of the educational process are familiar with the evacuation plan and notification procedure. • ensure the proper functioning of the object's notification system (loudspeakers, school bells, sirens) and the fire protection system of the educational institution. • organize regular events regarding the actions of students and educators in the event of an aerial missile alarm at an educational institution (at least four times during the academic year). At the same time, there’s no centralized (MoES level) collection of data on shelter operation, servicing and any outstanding issues which would help with improvement of standards and guidance. Also, the MoES in collaboration with different international support programs and national CSOs has created a number of educational resources aimed at improving war hazards awareness and resilience, as well as response preparedness of school children and staff, for example, safety lessons11 and posters12, mine safety trainings13 - the mine safety lessons have become part of educational curriculum14 - as well as multiple resources on mental health support for children and adults15. These resources are not compiled in the same place (though most of them are available or referenced on the MoES website) making it harder for individual educational institutions to access them. ESSA recommends: the MoES should create a comprehensive knowledge sharing and supervision program to ensure that: • All the shelters are set up (including adequate water supply and sanitation facilities, requirements for structural stability, energy efficiency, and universal access), serviced and used in compliance with national legislation (including preparedness and response procedures and resources). • The health and safety incidents are reported, investigated and followed through to completion. • All supporting educational materials are known and available to all the beneficiary educational institutions. The supervision program may entail involvement of third-party monitoring, capacity building for local staff etc. DLI 2 foresees financing governmental subvention for the procurement of inclusive school busses. The Law of Ukraine "On Education" regulates many aspects of the provision of educational services, including transportation. The Article 13 of the Law states that persons who obtain a full general secondary education, live in rural areas, and need a ride to the educational institution and in the opposite direction, are provided with such a ride at the expense of local budgets, including ensuring the availability of 11 Source: https://nus.org.ua/news/bezpeka-pid-chas-vijny-dlya-uchniv-stvoryly-uroky/ 12 Source: https://nus.org.ua/news/minna-bezpeka-aktyvnist-v-ukrytti-pravyla-evakuatsiyi-shkoly-mozhut-otrymaty-bezplatni- plakaty/ 13 Source: https://bezpeka.info/ 14 Source: https://nus.org.ua/news/kurs-iz-minnoyi-bezpeky-uvijde-do-shkilnoyi-navchalnoyi-programy/ 15 Source: https://courses.zrozumilo.in.ua/courses/course-v1:EEF+EEF-029+sept2022/about and https://courses.zrozumilo.in.ua/courses/course-v1:eef+EEF-024+May2022/about and https://spilnoteka.org/broshura- mentalne-zdorovya-ditej-pid-chas-vijny-porady-batkam-ta-opikunam/ 34 appropriate transport for persons with impaired vision, hearing, locomotor apparatus and other less mobile population groups. The organization of transportation of children by school buses is carried out in accordance with the current legal acts of Ukraine on ensuring road traffic safety, transportation of passengers by buses, in particular the Law of Ukraine "On Road Traffic", the Law of Ukraine "On Road Transport" and the Rules for the Provision of Passenger Road Transport Services.16 Using your own school bus offers few advantages to schools. The school bus is specially equipped for students, it constantly travels along the set route specifically for the needs of children and teaching staff. It is always available and, in addition to regular daily transportation to and from school, it can also be used to transport children during extracurricular activities, festive events, sports competitions, for participation in student Olympiads, passing external examinations, etc. However, it is worth noting that maintaining a school bus involves costs that must be borne by the owner. Among them are planned costs, since the operation of vehicles requires both current and periodic maintenance costs, including insurance premiums (for the vehicle, for the driver), fuel costs (which may change during the year), scheduled technical inspection, lubricants, wages the driver's fee (including during the holiday period or on days when there are fewer flights), as well as unplanned expenses (in the event of bus malfunctions or road accidents), replacement of the driver in case of illness, etc. It is also necessary to have a proper parking place for the bus, to ensure its maintenance and the necessary conditions for preparing the vehicle for flights and the daily medical examination of the driver, and these concerns and responsibilities rest with the balance keeper of the bus, and therefore with the local education authority or the school principal. School buses must meet the requirements of the National Standard of Ukraine DSTU 7013:2009 "Buses specialized for the transportation of schoolchildren. Technical requirements", including for special school buses for the transportation of children with limited physical abilities who travel in wheelchairs. Buses must be new, technically sound, comply with environmental standards not lower than the Euro-5 level. Control over the intended use of school buses, compliance with the requirements of the current legislation regarding the organization of transportation of children and teachers by school buses is carried out by the head of the education management body and the head of the general educational institution. The head of an educational institution or the head of the educational management body (the founder of the educational institution) has additional duties related to this, including: • Determines the proper parking place for the bus, ensures its maintenance and creates the necessary conditions for passing the pre-trip technical inspection. • Ensures that the bus driver passes a pre-drive and post-drive medical examination. • Provides annual school bus driver training on road safety issues to the extent of the technical minimum. • Ensures availability of appropriate required documentation, such as: o route passport and school bus schedule. o instructions for the driver about the peculiarities of work in the spring-summer and autumn- winter periods; about safety measures during the transportation of students and teachers; on providing first aid to victims of a traffic accident. 16 Source: https://decentralization.ua/uploads/library/file/328/law.pdf 35 o instructions for the driver, teacher and accompanying persons on actions in the event of a traffic accident, etc. possible threats o logbook of trainings for the driver, tutor and attendants; trainings for students o record of violations by the driver of traffic rules and participation in traffic accidents, etc. Pick-up is organized at predetermined stops. According to the norms of the ‘Sanitary Regulations for institutions of general secondary education’, the distance from the place of residence of students to the meeting place at the bus stop should not exceed 500 m. The founder and head of the educational institution are responsible for compliance with the requirements of the Sanitary Regulations. However, in practice not all of these regulations are fully complied with – for example, number of reported cases17 confirm that sometimes bus stops are located too far away from children’s homes forcing them to walk for 1 km and more. Usually, such cases are related to bad road conditions and inability of the bus to reach all the homes. One of the main reported reasons for irregular transportation of children is the lack of funds for the purchase of fuel, the failure of outdated vehicles and lack of funds for maintenance and repair, the unsatisfactory condition of the roads - destroyed surfaces and untimely clearing of snow. Other issues include incompliances with traffic rules by the drivers (speeding, making dangerous maneuvers etc.) and children (not using seatbelts). ESSA recommends: the MoES should develop a capacity building program to support local educational departments and/or schools of in the following subjects: • health and safety incident reporting, investigation, and completion • cooperation with local authorities on the road infrastructure needs to ensure proper condition of road surface. • budgeting for school transport infrastructure (for servicing and repairing the buses timely). • information/training campaign on traffic rules for children and school staff. The capacity building program should also facilitate supervision by the local authorities and MoES, as well as nation-wide grievance redress mechanism for reporting incompliances or proposals. ESSA recommends: the MoES should ensure that all schools should develop safety protocols (Emergency Preparedness and Response Plans) for instances of war-related hazards (for example, aerial strikes) that occur during transportation. Protocols for technical maintenance and driver’s qualification requirements are covered by existing national legislation for traffic safety and others. 4.1. (b) Promote environmental and social sustainability in Program design The Program supports the Paris Agreement and strategies for climate change adaptation and mitigation, as well as national efforts for gender equality. The operation supports climate adaptation and mitigation in several ways: the use of shelters for climate-related emergencies, energy-efficient shelter designs, and reduced greenhouse gas (GHG) emissions from school transportation (see below an abbreviated table of Program co-benefits assessment): 17Source: https://nus.org.ua/articles/shkilni-avtobusy-skilky-potribno-zakupyty-yaki-ye-problemy-z-pidvezennyam-ditej-ta-yak- yih-vyrishuvaty/ 36 Area Adaptation Mitigation Shelters • The construction of shelters in schools • The energy-efficient design and will be climate informed, avoiding new materials used (energy-efficient design constructions in high-risk areas principles, sustainable and recycled (particularly flooding), and building materials, materials with high incorporating resilience measures in thermal efficiency) will be in line with existing constructions in high risk areas, the latest available technology and such as flood embankments, wider highest EU efficiency standards, as well drainage, heat resistant building as the use of renewable energy materials, rain water harvesting sources, water conservation through systems, etc., thereby allowing rainwater harvesting and on site educational institutions to count on treatment systems where feasible, and multi-purpose safe spaces in case of management principles will limit GHG extreme weather or natural disasters. emissions during shelter construction • School safety plans and evacuation by using energy efficient and low protocols will consider local climate emissions building materials, design, risks and exposure to floods, heat, and construction practices with locally water scarcity, and other context- sourced materials to the extent relevant disasters. possible. Buses • School buses provide a means of safe • Fuel-efficient modern buses, in line transport for students during extreme with the highest EU standards on weather events and support the efficiency, and electric where feasible, adaptation of the education system to reduce GHG emissions associated with climatic emergencies. traditional fossil fuel-powered vehicles • Climate-resilient fleet management and limit exposure to air pollution for strategies will ensure that school buses students. remain operational during extreme • Optimized route planning leads to weather events and are accessible as efficient use of resources and climatic changes might require contributes to the reduction of overall adjustments in school schedules. traffic congestion, emissions, and • School buses support access to pollution. education in remote and rural • The provision of school transportation communities that might be encourages the take-up of public disproportionately affected by climate transportation reducing the plying of change thereby reducing their private single household vehicles and vulnerability to climate impacts and resulting emissions and pollution from ensuring inclusion. private transport. Teacher • Incorporating climate change • Teachers will introduce concepts of training awareness and technical education, environmental stewardship and including environmental skills, into the sustainability in classrooms, emissions teacher training curriculum equips reduction, energy efficiency, students with an understanding of the environmental protection, reducing causes, impacts, and solutions to waste, and conserving resources. climate change. 37 Area Adaptation Mitigation • Training teachers in emergency preparedness and response specific to climatic threats ensures the safety of students during climate-induced emergencies. Textbooks • The updated curriculum covers the • The curriculum incorporates activities environment and the basics of climate that encourage conservation, such as and change, the causes and impacts of recycling projects. curriculum climate change, laying the groundwork • Eco-friendly materials for textbook for understanding and responding to printing will be promoted, considering climatic threats, with a specific focus on sustainable paper sources, enhancing awareness of local climate environmentally friendly inks, and risk exposure. printing processes that minimize • New textbooks integrate climate environmental impact. education across various subjects and • Longer and sustainable lifecycle provide comprehensive information on management of textbooks will be climate change causes, impacts, and emphasized, with textbook reuse, adaptation measures, promoting recycling, and responsible disposal. sustainable practices, and addressing disaster preparedness and response. Digital • Providing equipment for blended • Digital equipment such as computers, equipment learning helps ensure learning tablets, and e-readers significantly continuity through online means in case reduce the need for printed of climate shocks. materials. All equipment will be the • Digital resources enrich the curriculum latest available technology and of the with interactive and engaging content highest energy efficiency standards in focused on climate change and line with EU norms. environmental sustainability such as • Digital tools enable remote working virtual labs, simulation software, and and learning capabilities, which can educational games for younger significantly reduce GHG emissions children. related to transportation. • Standards on e- and digital equipment usage, reuse, and especially recycling will be implemented to minimize ‘quick turnover’ of digital equipment and extend lifecycles. Education • Resilient data storage systems (with • Paperless administrative processes management regular backups and cloud-based (digitizing forms, reports, and information storage solutions) ensure the secure communication channels) reduce the system storage of educational data during and environmental impact associated with (AIKOM) after climate-induced disasters, with paper usage. minimal service outages and data loss. • The hardware infrastructure • New modules within AIKOM will help supporting AIKOM, such as servers and collect and analyze data related to data centers, will be energy efficient. 38 Area Adaptation Mitigation climate vulnerability in education infrastructure, including information on the susceptibility of schools to specific climate-related risks or on the resilience of education infrastructure to climate impacts. However, not all these features are clearly outlined in relevant standards and guidance, some of them are implied based on the current practices and EU standards that are being gradually implemented in Ukraine. ESSA recommends: the MoES should provide relevant guidance for technical requirements (for shelters, school busses and IT infrastructure) and knowledge requirements (curriculum for teacher training, textbooks etc.) to promote and implement feasible climate change adaptation/mitigation measures, sustainable development practices etc. 4.2. Assessment of Borrower E&S Systems against Core Principle 2 (Natural Habitats and Physical Cultural Resources) It is not foreseen that construction/reconstruction of shelters or operation of shelters/busses will have any adverse impacts on natural habitats under normal circumstances. Most of natural habitats in Ukraine either designated as Nature Protection Fund lands and are protected under relevant legislation, or (rarely) as forest lands with special use status. All civil works and operation of buses will be done within the lands allocated to school infrastructure and road infrastructure that do not intersect with natural habitats. It is possible that some of the schools where work will be ongoing are considered cultural heritage due to their historical architectural significance or cultural significance (for example, school where famous historical figures either studied or taught). Ukraine's cultural heritage sites are protected by regulations under the Law of Ukraine "On Protection of Cultural Heritage." The Law of Ukraine "On Protection of Cultural Heritage" provides the foundation for protecting cultural heritage objects, requiring developers to obtain necessary approvals and permits before commencing work that could affect these sites. National regulations mandate that developers take into account restrictions on economic activities in areas with cultural heritage objects. A Chance Find Procedure ensures that any unexpected discoveries of cultural artifacts during construction are handled appropriately, preserving the nation's cultural heritage while allowing for necessary development. Steps for Obtaining Permission and Handling Chance Finds Historical and Urban Planning Justification: before starting any project, developers must obtain a historical and urban planning justification, which includes a thorough investigation of the site for cultural heritage objects. 39 Project Documentation Approval: developers need to get their scientific and project documentation approved and obtain permits for construction works from cultural heritage protection authorities is carried out exclusively through the electronic office of the Unified State Electronic System in in the field of construction. Chance Find Procedure – actions upon discovering cultural heritage objects: • Stop Work Immediately: cease all construction activities in the vicinity of the discovery to prevent any damage. • Secure the Site: protect the area to ensure the find remains undisturbed. This might involve fencing off the site and monitoring it to prevent unauthorized access. • Notify Authorities: immediately inform the relevant cultural heritage protection authority about the find. Provide detailed information, including: • Location of the discovery: provide description and, if possible, photographs of the find. • Preliminary Report: document the discovery, including the date, time, and circumstances of the find, along with contact details of on-site personnel. • Assessment by Experts: Wait for the cultural heritage protection authority to send experts to the site. Their assessment will determine the significance of the find and recommend further actions. • Implementing Protective Measures. Based on expert recommendations, developers must implement measures to protect the discovered objects. This may include: o Provision of physical fence /barriers o Covering the objects to shield them from environmental factors. o Other site-specific measures as advised by the experts. • Detailed Reporting: submit detailed reports to the cultural heritage protection authority, documenting the find, protective measures taken, and any further risks identified. • Electronic Submission: use the Unified State Electronic System in the field of construction (Єдина державна електронна Ñ?иÑ?тема в Ñ?фері будівництва - EDESSB) to submit all documentation and reports, ensuring compliance with legal requirements. • Resumption of Work: obtain written approval from the cultural heritage protection authority to resume construction activities. Ensure all protective measures are in place and that the work will not endanger the cultural heritage objects. • Ongoing Monitoring: monitor the site continuously during further construction to ensure no additional cultural heritage objects are discovered or disturbed. Adhering to the Chance Find Procedure is crucial for preserving Ukraine's cultural heritage while facilitating development projects. Immediate action upon discovering cultural artifacts, proper notification and documentation, and compliance with the Law of Ukraine "On Protection of Cultural Heritage" ensure that cultural heritage objects are safeguarded. The use of the EDESSB system streamlines the approval process, making it more efficient and transparent. Chance Find Procedure is briefly outlined in the ES Guidance (Annex 1) under Core Principle 1. 4.3. Assessment of Borrower E&S Systems against Core Principle 3 (Public and Worker Safety) Ukrainian legislation on labor protection consists of the Law of Ukraine “On Labour Protectionâ€? and many bylaws (labor protection regulations, resolutions of the Ukrainian Government, sanitary standards, orders 40 of ministries that clarify the provisions of this law). Recent EU-ILO Project ‘Towards safe, healthy and declared work in Ukraine’ was aimed to improve the compliance of Ukraine’s occupational health and safety (OHS) legal framework with key international and European standards on OHS and labor relations, and, inter alia, to adequately and sustainably transpose into the national legal framework a set of EU Directives on OHS (such as Directive 89/391/EEC - OHS "Framework Directive" etc.), as foreseen in Article 424 and Annex XL to Chapter 21 of the EU-Ukraine Association Agreement. This work resulted in drafting the Law of Ukraine ‘On OHS’ which is now undergoing review by the Parliament. In addition, EU OHS Directives 2009/104/EC, concerning the minimum safety and health requirements for the use of work equipment by workers at work and 89/656/EEC, on the minimum health and safety requirements for the use by workers of personal protective equipment at the workplace, have been transposed to national legislation, through orders of the Ministry of Social Policy of Ukraine (MSP). The high incidence rates of work-related accidents and occupational diseases, however, indicate that a lot still remains to be done in Ukraine, when it comes to the prevention of occupational risks and the promotion of the safety, health and well-being of workers. According to the Background paper for the EU-ILO Project “Towards safe, healthy and declared work in Ukraineâ€? 18, in order to improve working conditions in Ukraine and ensure the quality, sustainability and success of the process of approximation of national legislation with the International and EU Labour Standards, some important challenges still need to be properly addressed. They include, inter alia, the following: • Downstream approach to OHS, focused on protection (rather than on prevention) and safety (instead of a more holistic approach, also including occupational health and hygiene). • Too detailed, complex and outdated OHS legal framework, composed of an excessive number of laws/regulations, some of which are contradictory. • Counterproductive legal provisions that set a threshold dollar value for OHS measures rather than ensuring safety and health of workers as an obligation of result. • National OHS legal framework does not provide for the employers’ non-transferable responsibility for ensuring the safety and health of workers in every aspect of their work. • National OHS legislation does not foresee the employers’ obligation to take, and continually adjust to changing circumstances, the necessary measures for ensuring the safety and health of workers, including assessment and prevention of occupational risks, consultation and participation of workers, health surveillance, provision of information, training and the necessary organization and means, with observance of the sequential and hierarchical General Principles of Prevention. • National OHS legislation does not apply to all economic sectors nor to all employers and workers. • The national statistics on occupational accidents and diseases are unreliable and present inconsistencies and high levels of underreporting. These gaps and shortcomings are further exacerbated by the ongoing situation and related military hazards. For the OHS management system, hostilities become real external threats factors that significantly change the external and internal context of the enterprise and increase the risks of additional accidents at work, which are uncharacteristic for peacetime and have consequences of varying severity. In Ukraine as of April 2024, accidents with fatal consequences caused by the conflict constitute almost half of the total fatal injuries at work.19. 18 Source: https://www.ilo.org/media/77226/download 19 Source: https://dsp.gov.ua/main-news/ukraina-vidznachaie-vsesvitnii-den-okhorony-pratsi-v-umovakh-viiny/ 41 To this end, State Labor Service of Ukraine has issued a series of recommendations on OHS practices. Also, EU-ILO Project ‘Towards safe, healthy and declared work in Ukraine’20 provides guidance on the most effective OHS methods and approaches s in the context of the situation in Ukraine and its humanitarian consequences. These documents outline hazards and their impact on business activities, proposed preparedness/response mitigation actions, necessary resources and capacity building. Public and worker safety against the potential risks associated with construction and/or operation; exposure to toxic chemicals, hazardous wastes, and other dangerous materials; infrastructure located in areas prone to natural hazards, will be ensured through ES management system covered under Core Principle 1 and Annex 1. ESSA recommends: the MoES should, through guidance, capacity building and supervision of construction sites, ensure implementation of OHS and community safety measures outlined in the ES Checklist (Annex 1) and other relevant guidance (both national and international, including WB) mentioned above. 4.4. Assessment of Borrower E&S Systems against Core Principle 4 (Land Acquisition) The Program does not involve land acquisition or resettlement. Hence, there will be no direct adverse impacts related to land acquisition or loss of access to natural resources. All shelters will be constructed within existing schools within the existing footprint. Thus, government systems for land acquisition are not further assessed. 4.5. Assessment of Borrower E&S Systems against Core Principle 5 (Indigenous Peoples and Vulnerable Groups) Within the education sector and the context of the program, the crisis is quickly revealing the different needs of women and men, girls and boys. The impact of the invasion is particularly disproportionate for marginalized groups, such as female-headed households, Internally Displaced Persons (IDPs), Roma people, LGBTQIA+ and people with disabilities. Mothers in particular are raising concerns over children’s schooling. Education has mostly moved online, with the burden of homeschooling falling mainly on mothers, who also must deal with air raids, evacuations, and continued displacement, all of which interfere with homeschooling21. Ukraine has a robust regulatory framework and supporting policies and plans, for inclusive education providing access to program benefits for vulnerable and marginalized groups, as described in the section below, with some areas for strengthening at the level of MoES and program implementation. The government should also have a well-developed information sharing and awareness campaign on the program benefits, mechanisms to participation and other program related activities. 4.5.1 Inclusion in Education Ukrainian regulatory framework contains a wide range of policies and legislation at various administrative levels, pertaining to gender and social inclusion within the education system, and relevant to inclusive 20 International and EU labour standards background paper, ILO 2020 21 UNWOMEN and CARE International “Rapid gender analysis of Ukraineâ€? (2022) https://www.unwomen.org/en/digital- library/publications/2022/05/rapid-gender-analysis-of-ukraine 42 access of program benefits for vulnerable groups22. Firstly, Section 53 of the Constitution of Ukraine guarantees the right to education. Section 3 of The Ukrainian Law on Education23 states that no one can be restricted in their right to obtain education. The right to education is guaranteed regardless of the age, sex, race, health status, disability, nationality, ethnic origin, political, religious, or other views, color, place of residence, language, origin, social and material position, criminal record, as well as other circumstances and characteristics. The 2017 Law on Education defines inclusive education as ‘a system of educational services guaranteed by the State which is based on the principle of non-discrimination, human diversities, effective involvement and engagement of all participants of the education process’ (Art.1.12). The 2013 Law on Principles of Prevention and Combating Discrimination in Ukraine endorses a general definition of discrimination, promoting the rights and freedoms of individuals discriminated against on the basis of sex, among other characteristics. Along these lines, the 2018–21 State Social Programme on Equal Rights and Opportunities of Women and Men intends to eliminate institutional and legal barriers to gender equality. Under Result Area 1, the program will support development and rollout of Textbooks and Teacher Training for the NUS curriculum. The MoES has a procedure that incorporates antidiscrimination and gender expertise into textbooks and training manuals. "Methodical recommendations for carrying out anti- discrimination examination of objects of branding for further giving them the seal of the Ministry of Education and Science of Ukraine" is a detailed document and the procedure described in it is a mandatory. It contains expertise on race, skin color, religion and other beliefs, gender, stereotypes based on a specific feature, language, disabilities, ethnic, marital status, property conditions, and other issues. It is widely used by teachers. The NUS web resource nus.org.ua contain materials on a different antidiscrimination issue and focus on an importance of it. 4.5.2 Gender As explicitly stated in the 1996 Constitution, amended in 2016, gender equality is assured by providing women with the same opportunities in areas including education and vocational training (Art. 24). The 2005 Law on Ensuring Equal Rights and Opportunities for Women and Men is entirely dedicated to the promotion of equal rights and opportunities in the education sphere in terms of access, assessment, grants and loan benefits (Art. 21). In education, both the 2017 Law on Education and the 2014 Law on Higher Education guarantee the right to free education regardless of gender. The former does not explicitly cover discrimination based on sexual orientation, gender identity and expression in education, while the latter specifically prohibits any restrictions in the exercise of the right, except in cases established by the Constitution and laws of the country24. Strategies for implementing gender equality in the field of education until 2030 have been approved by the Decree of Cabinet of Ministers of Ukraine25. The Strategy targets all relevant stakeholders including students, parents, teachers, administration and staff. The Strategy aims to creates a regulatory basis for 22 https://education-profiles.org/europe-and-northern-america/ukraine/~inclusion 23 The Law of Ukraine “On Educationâ€?, # 2866-IV. Official webpage of Verkhovna Rada of Ukraine § 3 (2017) https://zakon.rada.gov.ua/laws/show/en/2145-19 24 UNWOMEN and CARE International “Rapid gender analysis of Ukraineâ€? (2022) https://www.unwomen.org/en/digital- library/publications/2022/05/rapid-gender-analysis-of-ukraine Resolution of the Cabinet of Ministers of Ukraine from 20.12.2022 No. 1163-p https://zakon.rada.gov.ua/laws/show/1163- 2022-%D1%80#Text ). 43 solving the problems of inequality and discrimination based on gender in Ukrainian society while acknowledging that domestic education as a social institution remains insufficiently sensitive to the problems of gender equality, inclusiveness, prevention and countering of discrimination on any grounds. The Strategy sets goals for: 1) comprehensive implementation of principles, policies and measures to ensure equal rights and opportunities for women and men, respect for human dignity and non- discrimination in regulatory and legal documents in the field of education; 2) strengthening the role of educational institutions in coordinating and implementing state policy on ensuring equal rights and opportunities for women and men in the field of education, preventing and countering violence and discrimination, and improving the educational process on the basis of equal rights and opportunities for women and men, respect for human dignity , non-discrimination, inclusiveness and countering violence, particularly on the basis of gender; 3) strengthening the competence and capabilities of the professional community of specialists in ensuring equal rights and opportunities for women and men; and, 4) ensuring equal rights and opportunities for women and men, preventing and countering any discrimination, implementing inclusive practices in the field of education as a basis for overcoming the consequences of military actions and reconstruction of Ukraine. The Strategy includes an approved, comprehensive operational plan of measures for 2022-2024 detailing a wide range of activities to increase staff qualifications and awareness in areas such as eliminating gender stereotypes, awareness about gender equality, and gender-based violence. Under the plan, MoES has developed a mechanism for gender audits in educational institutions26 to assess the state of ensuring equal rights and opportunities for women and men in educational institutions, to identify existing problems, determining ways to reduce the actual inequality between women and men. MoES is the lead agency for implementing most activities under the plan, although other ministries and agencies, and international organizations are involved. The implementation of the Operational Plan is tracked by established focal points and institutional ownership is with the Deputy Minister. ESSA recommends: the MoES should establish a gender function /unit with adequate staffing to support implementation of the Operational Plan. 4.5.3 Gender Based Violence (GBV) In 2020, Ukraine became a full member of the Biarritz Partnership aimed at prevention of gender-based violence (GBV), ensuring fair and quality education and health, promoting women’s economic empowerment, ensuring full equality between men and women in public policies. In June 2020, the Ukrainian Parliament ratified “The Istanbul Conventionâ€? 27focuses on protecting women against all forms of violence, contributes to the elimination of all forms of discrimination against women. Ukraine closely works with international partners on the issues of gender equality, equity and prevention of gender base and domestic violence. Since 2012, in Ukraine acts “Council of Europe Convention on the Protection of Children from Sexual Exploitation and Sexual Violenceâ€?28. 26Order of the Ministry of Education and Science of Ukraine #1182 â€?On the approval of the methodology and criteria for gender audit of educational institutionsâ€? (2021) https://mon.gov.ua/ua/npa/pro-zatverdzhennya-metodologiyi-ta-kriteriyiv- provedennya-gendernogo-auditu-zakladiv-osviti 27 Council of Europe Convention on preventing and combating violence against women and domestic violence (CETS No. 210) (2014) 28 Law of Ukraine # 4988-VI "On Ratification of the Council of Europe Convention on the Protection of Children from Sexual Exploitation and Sexual Violence" (2012) https://zakon.rada.gov.ua/laws/show/4988-17#n2 44 The Code of Ukraine “On administrative offensesâ€?29 identifies bullying in a process of education as the actions of participants of educational process, which consist of psychological, physical, economic, sexual violence and entails the imposition of a fine. Also, the law emphasizes failure by the principal of the educational institution to notify the police of cases of bullying of a participant of the educational process entails the imposition of a fine or corrective work. In 2019 MoES in the Order 164630 determine what should be identified as bullying, the procedure for all the participants of the incident and outlined the direction for prevention measures. Guidance on preventing all types of violence by the MoES was also developed in the “Methodology for teaching staff in prevention of violence in educational institutionsâ€?31, and “Preventing bullying in educational institutions: systematic approachâ€?32 These documents provide systematic approach in identifying manifestation of bulling or violence, at the grassroot level provide clear understanding of further steps of interaction with other government bodies. According to the “Methodological recommendations for identifying and responding to cases of domestic violence and the interaction of teaching staff with other bodies and servicesâ€?33 leading role in identifying manifestations of domestic violence responses to the teachers. The Operational Plan of measures for 2022-2024 for the implementation of the Strategy for the implementation of gender equality in the field of education until 2030, outlines a number of measures to prevent and combat against GBV, and address consequences, including appointing a special advisor and providing training to increase awareness and professional competencies of staff, about GBV. The plan envisions some measures for expanding cooperation with law enforcement, and other special areas of work such as psychosocial, medical and other services. Responding to GBV complaints is mainly handled at the school level, and MoES attests to the capacity and procedures to handle such sensitive GBV complaints. At the MoES level, the GRM does not appear to be equipped to handle such complaints. The legal framework requires mandatory reporting of instances of domestic violence; the authorized official of educational institution have to, within 24 hours, via telephone or email, inform the authorized division of the National Police and the Children's services (in cases if the victim and/or perpetrator is a child), ensure the provision of medical assistance (if needed), and record the necessary information in the Journal for the detection (reporting) of domestic violence 29 Code of Ukraine # 80731-X “On administrative offensesâ€? § 173 (1984) Official webpage of Verkhovna Rada of Ukraine. https://zakon.rada.gov.ua/laws/show/80731-10#Text 30 Order of The Ministry of the Education and Science of Ukraine #1646 “Some issues of response to cases of bullying (harassment) and the application of measures of educational influence in educational institutionsâ€? (2019) https://zakon.rada.gov.ua/laws/show/z0111-20#n16 31 Order of The Ministry of Education and Science of Ukraine. “Methodology for teaching staff in prevention of violence in educational institutionsâ€? #1047 (2018) https://mon.gov.ua/ua/npa/pro-zatverdzhennya-metodichnih-rekomendacij-shodo- viyavlennya-reaguvannya-na-vipadki-domashnogo-nasilstva-i-vzayemodiyi-pedagogichnih-pracivnikiv-iz-inshimi-organami-ta- sluzhbami 32 The Ministry of Education and Science of Ukraine “Preventing bullying in educational institutions: systematic approachâ€? (2019) https://mon.gov.ua/storage/app/media/zagalna%20serednya/protidia-bulingu/2019-11-25-protydiy-bullingy.pdf 33 Order of The Ministry of Education and Science of Ukraine #1047 “Methodological recommendations for identifying and responding to cases of domestic violence and the interaction of teaching staff with other bodies and servicesâ€? (2018) https://mon.gov.ua/ua/npa/pro-zatverdzhennya-metodichnih-rekomendacij-shodo-viyavlennya-reaguvannya-na-vipadki- domashnogo-nasilstva-i-vzayemodiyi-pedagogichnih-pracivnikiv-iz-inshimi-organami-ta-sluzhbami 45 and gender-based violence34. Documented procedures and referral protocols to qualified service providers (e.g. psychosocial, medical legal) for SEA/SH incidents that might incur in a school environment (involving students or staff), using a survivor-centered, and safety centered approach, and protecting the rights of children, are absent. There is no hotline or confidential, anonymous reporting channel for such complaints within the MoES GRM. There are no protocols for applicants giving their consent to report cases of complaints, especially sexual exploitation, violence and harassment. Issues of sexual exploitation, violence and harassment are not separated, in the case of such complaints, they are classified as a violation of individual rights. The ESSA recommends: the MoES should prepare GBV/SEA/SH complaint handling and referral protocol/checklist, based on good international practice, including guidance to schools. 4.5.4 Children with special needs or disabilities Regarding children with disabilities, Ukraine recognizes the action of Section 24 of Convention on the Rights of Persons with Disabilities35, which states the right of persons with disabilities to education without discrimination. The 2030 National Strategy on creating a barrier-free space in Ukraine36 is focused on creating equal opportunities for each person to exercise their rights, to receive services on an equal basis with others by integrating physical, informational, digital, social and civic, economic and educational accessibility into all spheres of public policy. For practical implementation, MoES has adopted the Order “Concept of development of inclusive educationâ€?37. and “The procedure for organizing inclusive education in institutions of general secondary educationâ€?. The Concept envisages a comprehensive approach to addressing issues related to ensuring inclusive education, namely: Normative and legal support, and the development of individually tailored educational plans and programs; Development of criteria for assessing the achievements of students with special educational needs enrolled in educational institutions; Provision of educational institutions with inclusive education with special textbooks and didactic materials. The procedure for organizing inclusive education derailed questions of admission procedures, duration of education, student class allocation, teaching organization process, individual program development, assessment. Within the overall secondary education reform, the 2016 NUS framework allows children with special needs to access schools at a different age, to extend the duration of their study at a primary school and to receive supplementary correctional assistance. The official web site of MoES (provide REF) also contains hundreds of documents in a subsection “For children with special educational needsâ€?. These documents regulate different components of the educational process for children with disabilities. 34 Resolution of the Cabinet of the Ministers of Ukraine #658, Section 39 “The Procedure for the Interaction of Subjects Carrying out Measures in the Field of Prevention and Counteraction of Domestic and Gender-based Violenceâ€? (2018) https://www.kmu.gov.ua/npas/pro-zatverdzhennya-poryadku-vzayemodiyi-subyektiv-shcho-zdijsnyuyut-zahodi-u-sferi- zapobigannya-ta-protidiyi-domashnomu-nasilstvu-i-nasilstvu-za-oznakoyu- stati#:~:text=Кабінет%20МініÑ?трів%20України%20ПоÑ?танова%20від%2022%20Ñ?ерпнÑ?%202018,протидії%20домашньому%2 0наÑ?ильÑ?тву%20Ñ–%20наÑ?ильÑ?тву%20за%20ознакою%20Ñ?таті 35 UN Convention on the Rights of Persons with Disabilities (2006). https://www.ohchr.org/en/instruments- mechanisms/instruments/convention-rights-persons-disabilities 36 Resolution of The Cabinet of Ministers of Ukraine # 336-Ñ€ “The 2030 National Strategy on creating a barrier-free space in Ukraineâ€? (2021). https://zakon.rada.gov.ua/laws/show/366-2021-Ñ€#Text 37 Order of The Ministry of Education and Science of Ukraine. “Concept of development of inclusive educationâ€? # 912 (2010) https://mon.gov.ua/ua/npa/pro-zatverdzhennya-kontseptsii-rozvitku-inklyuzivnogo-navchannya 46 Section 13 of the Law on Education guarantees transportation, including accessibility of transportation for visually impaired individuals, hearing-impaired persons, individuals with musculoskeletal disorders and other low mobility population groups, and individuals from rural areas. The program will support budget subventions for general secondary schools to purchase school buses to support in-person learning by addressing transportation constraints. As for the 2023/2024 academic year, the Ukrainian statistic service identifies the total number of pupils as 3 867 801 individuals, of which 1 902 280 are girls. 1 370 403 girls studied in urban areas and 531 877 in rural ones38. Based on the most current data in 2015/2016 academic year only 5,8% of people (2720) with disabilities had opportunity to study in classrooms. Among the reasons for this situation were school environments that lack physical aids such as ramps or elevators or braille floor navigation and signs and the lack of special transport for picking up children with physical disabilities. The situation improved in recent years (19/20 academic year - 18643 individuals; 2020/2021 - 25,78; 2021/2022 - 32686; 2022/2023 - 33861) and at the beginning of the 2023/2024 academic year, the total number of students with special needs enrolled in schools increased to 4025439. There were 40,147 students enrolled in classes equipped in accordance with CMU Resolutions40 and MoES regulatory acts41. According to official statistics, in the 2022/2023 academic year, out of 12,976 total general secondary education institutions (including special ones) in Ukraine, 10,067 institutions (77.6%) were provided with barrier-free access for individuals with special educational needs to the 1st floor. Access to the 2nd floor was available in 102 institutions (0.8%), to the 3rd floor in 94 institutions (0.7%), and to the 4th floor in 32 institutions (0.2%)42. In 2023/24 academic year 316,358 of 341,656 individuals who required transportation to school have it43. For this purpose, 6,175 buses are available, including 268 for transporting individuals in wheelchairs. Nevertheless, by the MoES assessment more than twenty-five thousand pupils have no opportunity to attend classes because of the lack of transportation. Additional requirements of buses are 1954 units (2687 for the end of 202344) and among them 194 units for pupils with disabilities. Special legislative acts (State Building Regulation) are applicable requiring that such structures have access for people with physical disabilities, namely the “Inclusiveness of Building and Constructionsâ€? DBN V.2.2- 40:2018; and “Protective Buildings of Civil Defenseâ€? DBN 2.2-5:2023. As per the resolution on shelter subventions, local authorities will be required to construct shelters in accordance with these regulations ensuring that persons with limited mobility will have access to shelters. School buses were an important component of providing access to quality secondary education for children from villages before the full-scale invasion. Now their role is becoming even more important: they can provide transportation not only to hub schools, but also to schools with shelters, from localities where the school was destroyed to those where it survived, etc. Hromadas45 need not only to restore their vehicle fleet but also to expand it46. 38 State Statistic Service of Ukraine “Nuber of students in 2023/2024 academic year“. Data are relevant as for the May 2024 ukrstat.gov.ua/operativ/operativ2020/m_w/zspto.htm 39 Ministry of Education of Ukraine. Statistic data https://mon.gov.ua/ua/osvita/inklyuzivne-navchannya/statistichni-dani 40 Resolution of the Cabinet of Ministers of Ukraine #957 â€?On the approval of the Procedure for the organization of inclusive education in institutions of general secondary educationâ€? (2021) https://zakon.rada.gov.ua/laws/show/957-2021-п#Text 41 Order of The Ministry of Ukraine #912 “Concept of development of inclusive educationâ€? (2010) https://mon.gov.ua/ua/npa/pro-zatverdzhennya-kontseptsii-rozvitku-inklyuzivnogo-navchannya 42 Statistic information from official MoES web page https://mon.gov.ua/ua/osvita/inklyuzivne-navchannya/statistichni-dani 43 SavED “War and Educationâ€? (2023) yearofwar_report_en.pdf (saved.foundation) 44 Same source page 98 yearofwar_report_en.pdf (saved.foundation) 45 A hromada is a basic unit of administrative division in Ukraine, similar to a municipality. It was established by the Government of Ukraine on 12 June 2020. 46 SavED “War and Educationâ€? page 105 (2023) yearofwar_report_en.pdf (saved.foundation) 47 The Program supports budget subventions to purchase buses. The resolution of the Cabinet of Ministers of Ukraine on “Issues of providing subvention from the state budget to local budgets for the purchase of school busesâ€? has been passed by the government and will be put into effect. The resolution on school buses references the requirements for such buses, and if the school has students with limited mobility and wishes to purchase a bus for transporting wheelchairs, it specifies the applicable Ukrainian standards. The ESSA recommends: the MoES should conduct additional needs assessment for transportation for children with disabilities with relevant stakeholders, and issue additional instructions to oblasts/districts in this regard. 4.5.5 Ethnic and Linguistic Groups There are no Indigenous Peoples in Ukraine. According to the last recorded census (2001), the main minority groups include Russians, Belarusians, Moldovan, Crimean Tatars, and Bulgarians. Ukraine also has smaller populations of Poles, Jews, Romanians, Armenians, Hungarians, Roma and other nationalities. An updated census planned for 2020 wasn't carried out because of the COVID19 pandemic. MoES data in the 2020/21 academic year in Ukraine indicates that there were 874 schools which included instruction in national minorities languages. The article 21 of the Law On Supporting the Functioning of the Ukrainian Language as the State Language guarantee that persons from ethnic minority peoples of Ukraine shall be guaranteed the right to study at communal educational institutions, in order to receive preschool and secondary general education, in the language of the respective groups of Ukraine, along with the State language. To protect rights of Crimean Tatars, the MoES has translated textbooks into native language of this minority. Prior to the escalation, Roma women and men experienced discrimination in the labour market. There is a lack of civil status documentation and low education levels particularly among Roma women. Roma girls and women, who were already disadvantaged in terms of access to schooling, will most likely face further challenges that will have long-term effects on their access to opportunities, including livelihoods and services. 4.5.6 Internally Displaced Persons Other vulnerable groups are Internally Displaced Persons (IDPs). Though the right of education by IDPs is enshrined in the Law47, the real situation with accessing education in a new place of living can differ owing to lack of available space. In general, according to the IOM data48 for the end of March 2024, total number of IDPs equals 3,387,291 persons, among them 60% are female, 26% are individuals under 18 and 4% are individuals with disabilities. The highest number of IDPs are registered in areas, such as Lvivska, Ivano- Frankivska, Zakarpatska and Kyivska oblasts. 47 The Law of Ukraine #1706-VII “On ensuring the rights and freedom of internally displaced personsâ€? § 7 (2014) https://zakon.rada.gov.ua/laws/show/1706-18#Text 48 International Organization for Migration. “Registered IDP area baseline assessmentâ€?. Ukraine. Round 34. (March 2024) https://dtm.iom.int/reports/ukraina-bazova-teritorialna-ocinka-zareestrovanikh-vpo-raund-33-lyutiy-2024 48 4.6. Assessment of Borrower E&S Systems against Core Principle 6 (Avoid exacerbating social conflict. Distributional Equity) The program is not expected to exacerbate social conflict. However, the program supports subventions to local authorities who submit funding applications to MoES , and demand exceeds supply of funds. This can create social tensions if the program lacks transparency and fails to deliver distributional equity. The resolution of the Cabinet of Ministers of Ukraine on the procedure for granting and using subventions to local self-government bodies, which are founders of preschool and school education institutions, is adopted annually. For each type of project activity (New Ukrainian School, construction of shelters, procurement of school buses), there will be a separate resolution of the Cabinet of Ministers of Ukraine. For 2024 Shelters: The adopted resolution describes the procedure and criteria of selection in all details and is available at https://zakon.rada.gov.ua/laws/show/417-2024-%D0%BF#n2. The Resolution will set out geographic areas where shelters can be constructed based on approved security and safety zones (i.e. proximity to conflict areas). The 2024 resolution introduces new criteria for scoring and decision-making regarding applications based on the following: • Transparency –The national Unified Digital Integrated Information and Analytical System for managing the process of reconstruction of real estate objects, construction, and infrastructure (DREAM) electronic platform will be used for shelter application, selection, and monitoring. This system provides increased transparency and diminished human interference into the results of funding allocation and a single ‘window’ into all subvention works. The scoring criteria are disclosed on the MoES and CMU official website . The information about the commencement of the selection procedure along with the selection criteria will be published on the websites, and a distribution will be made to the local self-government bodies, which will be the main stakeholders and beneficiaries. • Efficiency - Enables funding the shelters whose works started last year and that are ready at minimum of 40% of their total cost, thus increasing the chances for high disbursement rate of the subvention.  • Equity - Focus on the regions that need subvention funds most: The subventions will be allocated among 8 regions49 only, selected primarily based on the development of the security situation (except for completion of the last year's works); continuity of the study process is the most challenging for those 8 regions, as they are outside conflict areas but border the frontline and/or have had some unoccupied territories, which require rehabilitation of learning spaces. • Equity – o Subvention funds will only be allocated for schools that work in distance/hybrid mode (study actually takes place there).  o The municipal co-financing requirement is adjusted for municipalities with low tax- capacity. The municipal tax capacity index is a measure of communities’ economic capacity to pay taxes, and thus is also utilized as a proxy for the socioeconomic status of the local community. In both 2023 and 2024, this tax capacity index has been incorporated into the subvention criteria to afford more lenience to lower-SES communities in terms of the expected share of co-financing for shelter project eligibility (i.e. lower-SES communities contribute smaller shares of co-financing). This means that 49 Kharkiv, Dnipropetrovsk, Zaporizhzhia, Mykolaiv, Kherson, Odesa, Sumy, Chernihiv regions 49 community-level SES as a measure of equity has already been incorporated in the shelter subvention. • Efficiency - Hub schools – This regulation refers to hub schools as being a priority criterion for funds allocation. The shelter resolution references this in Annex 6 'Criteria determining the priority of the selection of projects related to the new construction of protective structures of civil protection and the reconstruction or major repair of other objects that constitute the fund of protective structures of civil protection in institutions of general secondary education'. The ESSA concludes that the program has a number of policies and underlying systems for transparent and equitable subventions, which are continuously improving, supported by the Program. ESSA recommends: the MoES should continue to incorporate socioeconomic considerations in targeting criteria for future shelter subventions. 4.7. Assessment of institutional systems The Ministry of Education and Science has an on-going World Bank supported project, with established PIU and experience implementing projects under ESF (Ukraine Improving Higher Education for Results Project). However, as of recently, the ES staff has resigned from the PIU and the PIU is currently in the process of recruiting one Social/SE Specialist and one Environmental/OHS Specialist. The ToRs for these positions have been cleared with the Bank. The MoES PIU ES staff will be responsible for implementation of the ESF instruments (IPF) and environmental and social aspects of the PForR including the related activities under the Program Action Plan. For example, they will be tasked with capacity building measures (development of relevant guidance, templates etc.), as well as regular supervision and monitoring activities to support local governments and beneficiaries. The MoES PIU will be funded through the IPF component of the PforR. It is expected that further staffing needs will be assessed during implementation. ESSA recommends: ES staff should be hired 1 month after the Program effectiveness date and maintained throughout Program implementation. 50 5. Stakeholder Engagement and Information Disclosure One of the important components of state governance is communication and interaction with citizens. Openness, complete and timely information, involvement in discussions are important components of the successful implementation of state initiatives. There are a number of national policies and regulations that comprise MoES cross cutting systems for stakeholder engagement and information disclosure across all the program activities. The right to information is a fundamental and protected by a law. In accordance with the Law of Ukraine "On Information,"50 guarantees equal rights and opportunities for access to information to all subjects of information relations. At the national level, information dissemination and communication channels include official websites of government bodies such as the Verkhovna Rada of Ukraine, the President, and the Cabinet of Ministers, where all official information is posted. All government websites allow for electronic submission of inquiries directly through the site. Accessibility modes for citizens with visual and hearing impairments are available on all sites. The issue of digital accessibility of web resources is regulated by DSTU EN 301 549:202251. In addition to obligations imposed to the MoES by national laws, the Ministry has its own communication mechanisms at various levels. For example, MoES actively utilizes social media platforms. The Ministry also operates a Hotline regarding educational issues for citizens from conflict-affected areas. The Ministry actively conducts online consultations and has a dedicated webpage on the ministry's website providing summaries of active and archived consultations. The Ministry also has several grievance channels, and an Ombudsman responsible for mediating and addressing complaints (see sub-section on Grievance Mechanism). Other general methods used by MoES to engage with the public and representatives from CSOs organizations include on-line public consultations. Announcement inviting participation in such consultations are posted on the Ministry's website along with information about how to submit written proposals and contact information52. The Ministry publishes report of such consultations on the official website detailing the proposals received and the resolution of applying or rejecting them, within two weeks. At the regional level, where active engagement of program beneficiaries should take place, several entities responsible for organizing dialogue with the public. These include Regional State Administrations and their units (regional, district, local), and departments or educational administrations. At the educational institution level, this responsibility falls upon the heads of education departments at all levels and school principals, who, according to the law, bear a range of duties related to organizing the school process. 50 The Law of Ukraine #2657-XII â€?On Informationâ€? (1992) https://zakon.rada.gov.ua/laws/show/en/2657-12#Text 51 State Standard of Ukraine 301 549:2022 â€?Information Technology. Requirements for the availability of products and services“ (2022) https://online.budstandart.com/ua/catalog/doc-page?id_doc=97742 52 Announcement â€?MoES Proposes for Public Discussion the Draft Procedure for Establishment and Conditions of Functioning of Special Classes in General Secondary Education Institutionsâ€? https://mon.gov.ua/ua/news/mon-proponuye-dlya-gromadskogo- obgovorennya-proyekt-poryadku-utvorennya-ta-umov-funkcionuvannya-specialnih-klasiv-u-zakladah-zagalnoyi-serednoyi-osviti 51 Teacher training and textbooks activities supported under the Program are being rolled out under a broader rollout of the New Ukrainian School (NUS) curriculum. As described in the technical assessment, NUS was designed and initiated in 2018, is aligned with EU norms and underwent extensive public consultation. A wide range of stakeholders were involved in the development of the New Ukrainian School strategy, including non-governmental organizations, parent committees, professional organizations, government agencies, and international donors. As part of the reform, a communication campaign was organized, several round tables and forums were held, and a set of informational brochures was released. Concerning outreach on the funding application process (shelters and buses), the Mininfra, which currently serves as the administrator of the DREAM system. They are actively engaging all stakeholders in training on how to operate within the DREAM system. The MoES team has also been involved in seminars where the principles of the system's operation were explained, and its capabilities were demonstrated in practice. The ESSA concludes that there are robust borrower systems to support stakeholder engagement and information disclosure for program activities. The MoES needs to pay special attention to working with representatives of CSOs. MoES works closely with many CSOs. However, communication mechanisms and timing of engagement with CSO’s are not systematized and require continued strengthening. There should be particular focus on issues of inclusivity and education for children with disabilities for CSOs and parents. For the component of procuring special transport vehicles, special attention should be paid to informing families raising children with disabilities. They should be informed about the possibility to request special transport and the obligation of the local community to procure such transport under the subsidy. The ESSA recommends: MoES to prepare a stakeholder engagement and communication plan for the program. The stakeholder engagement and communication strategy should consider the accessibility and effectiveness of various communication channels for different beneficiary groups, and CSOs, including use of social media. Further the ESSA recommends that the PIU recruit a social/stakeholder engagement specialist to implement the plan. 5.1. Program Grievance Mechanism National and Subnational Systems for Grievance Redress applicable to the Program The Law of Ukraine “On Informationâ€? declares that the main areas of the state information policy shall include ensuring that every person has access to the information. The Law of Ukraine "On Citizen Appeals" provides the right to file observations, complaints and proposals with the government authorities, local governments, citizens associations, enterprises, institutions, organizations. The Law on Citizens Appeals and the Law "On Access to Public Information," guarantees the citizens' right to address government bodies and define the duties and timelines for handling such appeals by government bodies. The issues of record management and citizen appeals is also regulated by The Resolution of The Cabinet of Ministers. This document approves "Standard Instruction for Documentation of Management Information in Electronic Form and organization of work with electronic documents in record-keeping" and "Standard Instruction for Record-Keeping in Ministries, Other Central and Local Executive Bodies". 52 Standard Instruction for Record-Keeping establishes requirements for documenting management information and organizing document work. The Resolution of The Cabinet of Ministers approves the “Classifier of Citizen Appealsâ€? , This document establishes a typology for categorizing appeals according to the following criteria: by form of submission (via mail, in person, through government authorities, through the media, etc.); by submission characteristic (initial, repeated, multiple, mass); by type (suggestion, application, complaint); by gender (male, female); by subject (individual, collective, anonymous), and others. The practical realization of citizens' rights to access on public information and submission of appeals and complaints, ensured through a 24/7 Government contact Centre “National hotline 1554â€? , which provides various options for submitting inquiries, including options for people with disabilities (hearing and visual impairments). The hotline website is also used for conducting national surveys on matters of general importance. For instance, surveys regarding the New Ukrainian School (NUSh) have been conducted on it. Each local self-government body must also ensure the availability of a channel for citizens to submit complaints. All inquiries received by local executive authorities or state institutions of other levels will be registered and classified according to the established state standards and internal document circulation procedures. All inquiries and responses will be stored in the authority to which they were addressed, and which provided the response. Appeals to the authorities do not deprive applicants of the right to address to appeal to the Ministry of Education or the Cabinet of Ministers of Ukraine. Appeals can be submitted to all authorities simultaneously and repeatedly. Ukrainian legislation, relative to international good practice, is absent the possibility of anonymous grievances. Section 8 of the Law "On Citizens' Appeals" directly specifies that anonymous appeals are not considered. Based on this provision, Article 9 of the Instruction on Document Management for Citizens' Appeals in the Ministry of Education and Science of Ukraine also defines anonymous appeals as not subject to consideration. Within MoES, handling of citizen appeals is regulated by a separate Order of the MoES, which defines the procedure of appeals registration, their consideration, review timelines, and monitoring of appeal consideration. Recording of citizen appeals is carried out in accordance with the procedure established by the Cabinet of Ministers of Ukraine (Instructions on recordkeeping of appeals from citizens in bodies of state power and local self-government, associations of citizens, at enterprises, in institutions, organizations regardless of the forms of ownership, in the media, approved by the resolution of the Cabinet of Ministers of Ukraine dated April 14, 1997 No. 348). All appeals are directed to the Department of Document Management, Control and Information Technologies of the Ministry of Education and Science, whose separate unit - the Department for Control and Citizen Appeals – deals with issues of registration, accounting of citizen appeals, reporting, and manually assigns the received appeals based on the subject matter of the letter. The Ministry uses an electronic document management system used by the majority of state bodies to log and track grievances. All citizen appeals, including complaints received by the Ministry of Education and Science, are grouped according to the following possible categories: 1) Industrial policy 2) Agrarian policy and land relations 53 3) Transport and communication 4) Economic, price, investment, foreign-economic, regional politics and construction, entrepreneurship 5) Financial, tax, customs policy 6) Social policy. Social protection of the population 7) Work and wages 8) Labor protection and industrial safety 9) Health care 10) Communal economy 11) Housing policy 12) Ecology and natural resources 13) Ensuring compliance with legality and protection of law and order, realization of rights and freedoms of citizens 14) Family and gender policy. Protection of children's rights 15) Youth. Physical culture and sports 16) Culture and cultural heritage, tourism 17) Education, scientific, scientific and technical, innovative activity and intellectual property 18) Information policy, activity of mass media 19) Activities of citizens' associations, religion and interfaith relations 20) Activities of the Verkhovna Rada of Ukraine, the President of Ukraine and the Cabinet of Ministers of Ukraine 21) Activities of central bodies of executive power 22) Activities of local executive authorities 23) Activities of local self-government bodies 24) Activities of enterprises and institutions 25) Defense capability, sovereignty, interstate and international relations 26) State construction, administrative and territorial organization In 2023, the Ministry of Education and Science of Ukraine received 586 appeals, in 2024, as of May 24, 2024 - 286 appeals. The received appeals are disaggregated by region, gender and categories of applicants, e.g., student, pedagogical worker, scientific and pedagogical worker, pensioner, or by status (internally displaced person, etc.). Disaggregation of appeals by age is not carried out, since not all applicants indicate their age. Processing of appeals is carried out in the following way: In the Ministry of Education and Science, all appeals, including complaints, are considered within the limits of the mandate of the Ministry of Education and Science of Ukraine, as defined by its Regulation. In accordance with the Regulation, the Ministry of Education and Science is the main body in the system of central executive bodies, which ensures the formation and implementation of state policy in the fields of education and science, scientific, scientific and technical activities, innovative activities in the specified areas, transfer (transfer) of technologies, and also ensures formation and implementation of state policy in the field of state supervision (control) of the activities of educational institutions, enterprises, institutions and organizations that provide services in the field of education or conduct other activities related to the provision of such services, regardless of their subordination and form of ownership. All appeals received by the Ministry of Education and Science are considered within the time limits set by the law. In case of grievances that belong to the mandate of the Ministry of Education and Science of Ukraine, the appeal is processed by staff of the Ministry of Education and Science. If the grievance raises 54 issues that do not belong to the mandate of the Ministry of Education and Science, such appeal is re- directed to the appropriate body or institution for consideration. The Department for Control and Citizen Appeals prepares and submits reports on review of citizen appeals, including complaints, to the Cabinet of Ministers of Ukraine (quarterly) and to the Office of the President of Ukraine (twice a year). For the LEARN Program for Results operation, the grievance mechanism will operate in accordance with Ukrainian legislation regulating citizen appeals and access to public information, as well as subordinate acts that regulating the process of complaint submission and review timelines. The program GRM will build on experience and procedures from the GRM established for the World Bank supported IPF Ukraine Improving Higher Education for Results Program, expanding to cover the activities under the LEARN PforR Operation and IPF. Program beneficiaries and stakeholders will be able to submit enquiries and grievances to multiple uptake channels: • by email mon@mon.gov.ua By sending written grievance or request by address: 01135, Kyiv, Beresteiska Avenue, 10 • by telephone: (044) 481-47-57 • Each local self-government body must also ensure the availability of a channel for citizens to submit complaints. The Program’s Social Specialist will coordinate resolution of any grievances related to the program working with the Department of Document Management, Control, and Information Technologies of MoES. The ESSA recommends: the Program should establish a GRM and detail procedures in the Operations Manual and stakeholder engagement planning document. The Program will establish an additional uptake channel for anonymous grievances and ensure the GRM is equipped to handle complaints related to SEA/SH. The Program will establish a mechanism for regular reporting on grievance receipt and resolution covering the activities under the Program. 55 6. Conclusions and Recommendations Based on the above assessment, the ESSA concludes that the environmental and social risks of the program are considered to be adequately mitigated, through additions to the design, operation procedures and through committed actions in the Program Action Plan. All recommendations will be supervised throughout bank implementation: Actions to be incorporated in project design and procedures. Incorporation into project design Action and OM Develop knowledge requirements (curriculum for teacher To be incorporated into project training, textbooks etc.) to promote and implement feasible verification protocols and OM climate change adaptation/mitigation measures, sustainable development practices etc. Develop guidance for technical requirements (for shelters, To be incorporated into project school busses and IT infrastructure) to promote and verification protocols and OM implement feasible climate change adaptation/mitigation measures, sustainable development practices etc. Actions will be incorporated into the Program Action Plan (PAP). Indicators for Action Responsibility Timeline completion of actions Project management unit should The MoES ES staff should be Regular ES maintain requisite environmental and hired 1 month after reporting social staffing (1 social/stakeholder the Program (quarterly) engagement specialist and 1 effectiveness date environmental/OHS specialist) and maintained throughout Program implementation Issue a ministerial recommendation in The MoES 3 months after the ES Checklist connection to subvention for shelters, Program dissemination annually, to adopt the Environmental effectiveness date evidence and Social Checklist (Annex 1) for all shelter subvention beneficiaries, and ensure it is included in the civil works contracts. Create a comprehensive capacity The MoES 6 months after the Supervision Plan building and supervision program in Program Capacity building line with scope outlined in Annex 3 of effectiveness date and supervision the ESSA. program and regular reporting on its implementation 56 Indicators for Action Responsibility Timeline completion of actions Develop safety protocols (Emergency The MoES 3 months after the Report on safety Preparedness and Response Plans) for Program protocols instances of war hazards effectiveness date preparation and implementation Prepare guidance checklist for The MoES 3 months after the Completion of handling GBV complaints in a Program procedures and confidential, sensitive, survivor- and Effectiveness date dissemination of safety-centered manner consistent guidance with good international practice, including referral protocols to qualified providers and guidance to schools. Prepare a stakeholder engagement The MoES October 2024 Plan delivered and and communication planning report document for the Program including implementation the grievance mechanism equipped thereafter. to handle anonymous complaints and SEA/SH complaints. Further to the resolution on buses, The MoES 1 month after the Instructions issued conduct needs assessment on program transporting children with disabilities effectiveness date and issue instructions accordingly on purchasing buses with accessibility for children with limited mobility Confirm targeting criteria for shelter The MoES Prior to issuance of To be integrated subventions includes socioeconomic 2025 and 2026 into 2025 and 2026 factors (e.g. municipal tax capacity) subventions subvention respectively Establish a gender function /unit with The MoES 6 months after the Unit staffing to support implementation of program established/staff the Operational Plan. effectiveness date recruited as per organizational chart (supported under the IPF) 57 Annexes Annex 1. Environmental and Social Checklist Requirements for construction, reconstruction, restoration, major repair projects of the civil defense shelter objects within schools These general Environmental & Social (E&S) guidelines are presented in abbreviated form with the main objective to avoid and minimize the potential risks and negative impacts on health and safety of the community and workers, as well as the natural environment, during construction works. The checklist also considers that works will take place on school premises, and extra precautions are needed to protect children. The E&S Checklist was developed to ensure that good practice mitigation measures are recognized and considered during the project’s activities implementation. The E&S Checklist was developed to provide “best practice examplesâ€? and is intended for the convenience of users and is compatible with the requirements of national law. This E&S Checklist is intended to support the project administrator with the following tasks throughout project implementation: 4) Procuring Works: The E&S Checklist will be included in the works contract, as well as in the services contract with supervising entity for the execution of construction works under the project. If the project site has specific conditions or project activities envision risks not covered by this E&S Checklist, the project’s administrator will take an effort to expand and update this Checklist to cover all additional E&S risks and impacts and should incorporate these requirements into construction contracts. 5) Before Works begin: Project Administrator (as advised by the Supervising Entity if applicable) ensures the contractor has the requisite environmental and social risk management measures and/or plans, before start of works. No project’s implementation activities (no physical works including site preparation, offloading equipment and materials, civil works etc.) are allowed to start before the required environmental and social risk management measures are in place. 6) Monitoring Works: The project’s administrator directly or through a contracted supervising entity should receive regular reports on implementing the environmental and social mitigation measures and should inspect work sites and the work of personnel on a regular basis to identify issues or non-conformity and enforce necessary actions where unsafe acts or processes that seem dangerous or unhealthy are detected. The environmental and social performance of contractors at all times should meet the project’s environmental and social requirements. 58 POTENTIAL NEGATIVE EFFECTS ON THE SURROUNDING NATURAL MEASURES ENVIRONMENT AND HUMAN HEALTH TO MINIMIZE THE NEGATIVE IMPACT ON THE NATURAL ENVIRONMENT AND HUMAN HEALTH Air pollution and dust generation • Ensure low emission and well-maintained equipment will only be used. • All machinery should have timely technical inspections at maintenance stations regarding CO emissions and smoke, idle construction equipment with engines turned on at the sites is not allowed. • During excavation works the methods of dust control are applied, e.g. water spraying or land wetting. • During pneumatic drilling or removal of the surface layer of the pavement and foundation, dust should be suppressed by constant irrigation and / or protective screens should be installed at the facility. • Avoid combustion and disposal or destruction of materials/products which generate air quality issues associated with emissions of carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen oxide (NOx), and particulate matter (PM). • The wet scrubbers, cyclonic particle collectors or even exhausts with dust bags can be installed to prevent any particulate matter being sent out of premises. These dust traps need to be cleaned or replaced periodically for efficiency. • Keep outdoor stockpile of aggregate/sand materials covered to avoid suspension or dispersal of fine soil particles during windy days or disturbance from stray animals. • Workers who carry out the work must wear protective clothing and breathing masks. Water quality/water use and pollution • Consider measures for resource efficiency. • Activities should not affect the availability of water for drinking and hygienic purposes. • No soiled materials, solid wastes, toxic or hazardous materials should be poured or thrown into water bodies for dilution or disposal. • Ensure the organization of the collection and removal of surface wastewater at the construction site (if available). • Ensure the organization of storage places for construction products (materials, products or kits) in such a way as to avoid pollution of surface and underground waters. Surface Drainage and Possible Water • Carry out overall storm water management in the premises during construction using temporary ditches, sandbag Stagnation barriers etc. • Avoid temporary flooding due to excavation. • Proper drainage arrangements to be made, to avoid the overflowing of existing drains due to excavation during the laying of pipes, cables, cutting activities. 59 POTENTIAL NEGATIVE EFFECTS ON THE SURROUNDING NATURAL MEASURES ENVIRONMENT AND HUMAN HEALTH TO MINIMIZE THE NEGATIVE IMPACT ON THE NATURAL ENVIRONMENT AND HUMAN HEALTH Waste generation and management • Waste collection and disposal pathways and sites will be identified for all major waste types expected from demolition activities. • Mineral/solid demolition wastes will be separated from general refuse, organic, liquid and chemical wastes by on- site sorting and stored in appropriate places. • Promote reuse, recycling, or energy recovery. • Debris generated due to the dismantling of the existing structures shall be suitably reused, to the extent feasible, in the proposed construction. • Waste that cannot be reused / recycled / recovery will be disposed of at the ecological landfill. • Provide separate collection of waste from construction and demolition (dismantling) by main component (brick and concrete, glass, plastic, metal)53. • Ensure no solid waste gets into any water body. • During site clearance activities, demolition and debris removal must be carried out swiftly and in well-planned manner. • Consider large container and/or bulk systems for fuels, oils, chemicals to reduce the volume of waste containers. • The organization of storage places for building materials (products) should be carried out in such a way as to avoid soil, surface and underground water pollution. • Observe during the handling of waste from construction and demolition (dismantling) measures to protect soils from clogging and pollution. • Construction waste will be collected and transferred to facilities for use, neutralization in accordance with the Register of objects for use, neutralization, storage and disposal of waste in Ukraine. • Ensure that the transportation of demolition waste is carried out properly. • Cover the transportation vehicles for demolition or excavation materials. • Clean wheels of vehicles at the exit from working site. 53 Management of waste from destruction, in particular the organization of places for their temporary storage, is carried out in accordance with the “Procedure for handling waste generated in connection with damage (destruction) of buildings and structures as a result of hostilities, acts of terrorism, sabotage or carrying out work on their liquidation consequencesâ€?, approved by the resolution of the Cabinet of Ministers of Ukraine dated September 27, 2022 No. 1073 (Official Gazette of Ukraine, 2022, No. 80, Article 4841). 60 POTENTIAL NEGATIVE EFFECTS ON THE SURROUNDING NATURAL MEASURES ENVIRONMENT AND HUMAN HEALTH TO MINIMIZE THE NEGATIVE IMPACT ON THE NATURAL ENVIRONMENT AND HUMAN HEALTH Hazardous waste – asbestos containing • Store hazardous waste, such as paint cans, in separate skips/waste containers. materials (ACM) • The containers of hazardous substances shall be placed in a leak-proof container to prevent spillage and leaching. • Paints with toxic ingredients or solvents or lead-based paints will not be used. • Any contaminated soil must be immediately removed, placed in plastic bags and disposed of as hazardous waste. • If asbestos is located on the project site (i.e. heating pipes with ACM insulation), it shall be marked clearly as hazardous material. • When possible, the asbestos will be appropriately contained and sealed to minimize exposure. • The asbestos prior to removal (if removal is necessary) will be treated with a wetting agent to minimize asbestos dust. • Asbestos will be handled and disposed by skilled & experienced professionals. • If asbestos material is stored temporarily, the hazardous waste should be securely enclosed inside closed containments and marked appropriately. Security measures will be taken against unauthorized removal from the site. • The removed asbestos/ACM will not be reused. • Transportation and disposal of hazardous wastes should be done through licensed contractors and in close coordination with the relevant local authority and in compliance with the legal requirements and instructions. Noise and vibration • Noise generating work should be limited to daytime (8:00 to 21:00). Other type of construction work which will not disturb the environment by noise or vibration could be carried out during the nighttime. • During operations the engine covers of generators, air compressors and other powered mechanical equipment shall be closed, and equipment placed as far away from residential areas as possible. • All equipment and machinery should be operated at noise levels that do not exceed the permissible level of 75 dB (during construction) for the daytime. For all construction activities undertaken during the nighttime, it is necessary to maintain the noise level at below 50 dB as per the noise control regulations. • Temporary sound barriers also should be erected around buildings or premises as appropriate to shield residents if there are complaints from them. • Providing appropriate Personal Protective Equipment (PPE) for all workers. Soil pollution from fuel and lubricants • Ensure that all construction vehicle parking location, fuel/lubricants storage sites, vehicle, machinery and equipment maintenance and refueling sites shall be located away from rivers and irrigation canal/ponds. • Arrange for collection, storing and disposal of oily wastes to the pre-identified disposal sites. • The machine equipment and mechanisms will be checked regularly regarding possible leak of fuel. • In case of carrying out repair works involving the removal of a fertile layer of soil, ensuring its storage, preservation and use during land reclamation, improvement of unproductive lands and landscaping. 61 POTENTIAL NEGATIVE EFFECTS ON THE SURROUNDING NATURAL MEASURES ENVIRONMENT AND HUMAN HEALTH TO MINIMIZE THE NEGATIVE IMPACT ON THE NATURAL ENVIRONMENT AND HUMAN HEALTH Vegetation, green spaces • Protect all trees and vegetation from damage by construction operations and equipment, except where clearing is required for permanent works, approved construction roads, or excavation operations. • Revegetate damaged areas on completion of the works, and for areas that cannot be revegetated, scarifying the work area to a condition that will facilitate natural revegetation. • Use, as much as possible, local species for replanting and species that are not listed as a noxious weed or invasive species. • Repair, replant, reseed or otherwise correct, at the Contractor’s own expense, all unnecessary destruction, scarring, damage, or defacing of the landscape resulting from the Contractors operations. Interruptions, damages to local utilities • Coordinate with local authorities and locating service utilities before starting works. facilities • Provide timely information about construction and work schedules and related interruption of services. With few days in advance of any service interruption (including water, electricity, telephone, bus routes), advice community through postings at the work site, at bus stops, and in affected homes/businesses. • Carefully remove the utilities that are connected to any structures. • Alternative temporary sources of water, electricity or other critical resources should be provided, if possible. Historical buildings/cultural heritage • Ensure compliance with national and local legislation in the field of cultural heritage protection during construction works. • Ensure that provisions are put in place so that artifacts or other possible “chance findsâ€? encountered in excavation or construction are noted and registered, responsible officials contacted, and works activities delayed or modified to account for such finds. Social awareness and risk • Ensure that all works activities will be carried out in a safe and disciplined manner designed to minimize impacts management on neighboring residents and environment. • Ensure that timing of works is established to avoid children interacting with construction sites. • Ensure that extra precautions for child safety are taken near excavations and vehicle movements, for example, by isolating the site with fencing. • Ensure presence of notice boards at the construction sites with the information about the type (reinforced concrete shelter) and objective of works (protection of school’s pupils and personnel), a nd about the schedule of construction and installation works. • Provide timely information about construction and work schedules, about interruption of services, traffic detour routes, blasting and demolition. • Inform the community adjacent to the construction area about the compliance with environmental protection and safety measures. • When necessary, ensure that night work is carefully scheduled, and the community is properly informed, so they can take necessary measures. 62 POTENTIAL NEGATIVE EFFECTS ON THE SURROUNDING NATURAL MEASURES ENVIRONMENT AND HUMAN HEALTH TO MINIMIZE THE NEGATIVE IMPACT ON THE NATURAL ENVIRONMENT AND HUMAN HEALTH • Ensure that contractor has a channel to accept grievances from the public and to report to the project’s administrator about grievance processing. Human health, occupational safety, • Comply with the rules of labor protection, safety equipment and fire safety during the performance of works. and non-disturbance of communities • Ensure appropriate safety equipment, tools and protective clothing are provided to workers and that safe working methods are applied. • Adhere established occupational safety requirements as well as simple rules, e.g.: a) water spaying twice a day during construction to avoid dust b) permanent ventilation of internal areas c) timing of work • Workers should wear reflective vests to avoid being hit by moving vehicular traffic. • Welder’s protective eye-shields shall be provided to workers who are engaged in welding works. • Earplugs shall be provided to workers exposed to loud noise, and workers working in crushing, compaction, or concrete mixing operation. • Ensure rehabilitation of trenches progressively once work is completed. • Ensure/supply all necessary safety appliances such as safety goggles, helmets, safety belts, ear plugs, mask etc. to workers and staffs. • Safety signboards should be displayed at all necessary locations. • Contractor should put in place requirements for workers prohibiting contact with children and all forms of sexual exploitation and abuse/sexual harassment. Traffic management and pedestrians’ • Ensure proper fencing of construction site, barriers and clear warning signs displayed for the public and workers safety about all potentially hazardous works. • Install signaling of routes, of restricted access of unauthorized persons onto the construction site and of speed limits on site. • Organize the transport related to the construction works as to avoid the hours with high pedestrian traffic next to school (early morning/afternoon). • Separate pedestrian access to the school from construction vehicles accessing the site. • Ensure that truck drivers are accompanied by a flagman or watchman while reversing, unloading and loading. • Ensure safe walkways and passages for pedestrians in places of transport traffic and construction vehicles; traffic should be controlled on site to ensure safe passage of people. • Safe and continuing access of the population to all nearby offices, commercial and residential buildings during construction works should be provided. • Keep access roads in good condition and free from deposits, waste, construction material. 63 POTENTIAL NEGATIVE EFFECTS ON THE SURROUNDING NATURAL MEASURES ENVIRONMENT AND HUMAN HEALTH TO MINIMIZE THE NEGATIVE IMPACT ON THE NATURAL ENVIRONMENT AND HUMAN HEALTH Fire prevention and control, accidental • Take all reasonable and precautionary steps to ensure that fires are not started as a consequence of construction explosions during construction works activities. • Ensure strict compliance with the storage conditions for fuels and lubricants, as well as compliance with the rules of operation using open flames, explosives, etc. • Ensure storage of flammable materials under conditions that will limit the potential for ignition and the spread of fires. • Ensure fire-safe operation of heating devices, heat generating units, power grids and electrical installations. • Ensure that all premises have been equipped with fire extinguishers and the required number of firefighting equipment boards has been installed on the territory. • Ensure before the start of any excavation works that the construction site has been preliminarily inspected for unexploded ordnance. • Develop an emergency procedure in order to keep under control potential related risks. • Emergency equipment will be present on site and ready to be used. • Ensure a no smoking policy throughout the site with the exception of designated areas where smoking may be allowed. These areas should be established as far as reasonably practical from any building or structure and be provided with metal ashtrays and a fire extinguisher. Child labor • All workers should be more than 18 years old. • Verifying age of workers by checking IDs and official documents should be mandatory. Incidents management and reporting • Immediately inform appropriate authorities in compliance with local regulations about any major injuries or fatalities; secure the safety of workers, public, and provide immediate care. • Immediately investigate any serious or fatal injury or disease caused by the progress of works by the Contractor and submit a comprehensive report to appropriate authorities in compliance with local regulations. Emergency preparedness and response • An evacuation plan for workers and visitors to bomb shelters in the event of an air raid, artillery shelling and Since February 2022 there has been bombing must be in place to apply. significant and often irreparable damages from aerial missiles and • All workers/personnel who are planned to be allowed to work at the subproject site, should be instructed on the shelling, and there are also significant action plan in case of an air raid alert. ongoing risks due to the landmines and unexploded ordinances on • Consult with local administration for the list of available shelters for personnel and check the closest to make agricultural land. sure they are operational. • Facilities or construction sites should provide visible places schemes that indicate the path to bomb shelters/shelters. 64 POTENTIAL NEGATIVE EFFECTS ON THE SURROUNDING NATURAL MEASURES ENVIRONMENT AND HUMAN HEALTH TO MINIMIZE THE NEGATIVE IMPACT ON THE NATURAL ENVIRONMENT AND HUMAN HEALTH Education infrastructure is also • Facilities or construction sites should provide in visible locations a list of emergency and support services contact affected by unexploded mines and numbers (see below). pollution caused by military activities. • In the event of an air raid, it is necessary to make an organized transition to shelter, without leaving tools, equipment and machinery in working condition, and to help those who find it difficult to get to a safe place on their own. • For the timely evacuation of workers, all workers should install an alarm application on their smartphone (ПовітрÑ?на тривога or similar) and strictly follow evacuation instructions in the event of a corresponding ale rt. • All workers should study the Guide for Personal Preparedness in Case of Emergency developed by the Centre for Strategic Communication and Cybersecurity. The Guide is regularly updated on a website Dovidka.info and can also be downloaded on a smartphone as a chatbot. Actions in case of detection of unexploded shells or missiles – Explosive Remnants of Was (ERW) In case of detection of explosive objects, it is prohibited to: • Touch them (do not do this in any case); • Move, roll over from one place to another; • Collect and store, heat and hit; • Try to discharge and disassemble; • Use charges for making fire and lighting; • Bring indoors, bury in the ground, throw into a well or river. • Stop all activities on site/field, to evacuate all other workers/personnel at a minimum 50 m from the hazard area and position them behind available cover (vehicles, equipment, etc.) • Territorial authorities of the State Emergency Service and the Ministry of Internal Affairs should be informed immediately by calling '101' and '102'. • Secure the area and keep personnel/workers out until response personnel arrive. At a minimum, secure the area within approximately 50 m around the suspect explosive item. Actions in case of detection of Unexploded Ordnance (UXO) - are items used (fired, thrown, dropped) for their intended purpose but failed to function as designed • The whole personnel of education facility, as well as all workers who are planned to be allowed to work at the construction site or in the adjacent field, must be instructed in the provision of first aid. 65 POTENTIAL NEGATIVE EFFECTS ON THE SURROUNDING NATURAL MEASURES ENVIRONMENT AND HUMAN HEALTH TO MINIMIZE THE NEGATIVE IMPACT ON THE NATURAL ENVIRONMENT AND HUMAN HEALTH • Education facility and/or construction site should be equipped with first-aid kits with all appropriate first-aid equipment. • All employees (staff) should know the location of first-aid kits, personal protective equipment and fire extinguishers. Contact numbers of emergency and rescue services and support services • 112 – Universal call number of all emergency services. By calling this number, the dispatcher will call the team of the required service. • 101 — Fire service. • 102 or 0 800 500 202 — Police (can be used to report war crimes, including crimes such as sexual exploitation and sexual harassment). • 103 — Ambulance. • 104 — Emergency service of gas network. • 1547 – Government Hotline (can be used to report war crimes, including crimes such as sexual exploitation and sexual harassment). • 0 800 501 482 — Ukrainian Security Service Hotline. 66 Annex 2: Program Stakeholder Mapping Internal/ Group/Entity Role in Project Interest in Project E&S Issues External Ministry of Education (MoES) Directorate of International Cooperation Internal Implementation/ Ensuring complementarity with other MoES partners. Regulatory Department of record service, supervision Internal Implementation GRM management and supervision. and IT Directorate of Preschool and Inclusive Internal Implementation/ Education Regulatory for Supervision of the Project activities under IPF Component 2 as DLI5 applicable (development of infrastructure plans). Department for Financing of Public Internal General Timely and accurate communication of MoES financial needs for the Expenditures information NUS reform to MoF. provision Directorate for School Education Internal Implementation/ General duties: Regulatory Evaluation of participant applications; Procedures development; Supervision of the Project activities; Supervision of development of new programs/materials/standards. E&S issues: Empowerment of procedures for students with special learning needs; GRM management and supervision. Department of record service, supervision Internal Implementation GRM management and IT. Institute of Education Content Modernization: External Implementation Coordination of the selection process, printing, and delivery of NUS textbooks; − Department of Scientific and Ensuring anti-discrimination approach to education content produced Educational-Methodological Support as part of the NUS reform. for Content of Preschool and Primary Education in the New Ukrainian School; − Department of Scientific- Methodological Support for Publication of Educational Literature; 67 − Department of Scientific- Methodological Support for Integration into the European Educational Area; − Department of Accounting and Financial Reporting; − Legal Department; Department of Competitive Bidding and Procurement. Institute of Educational Analytics: External Implementation Coordination of AIKOM modernization; Ensuring availability and retrieval of information from AIKOM on − IEA Director; students and teachers for project monitoring. − IEA Deputy Director for IT; − Department of Administration of Educational Information Systems; − Department of Educational Information Support; Sector of Analysis of Educational Financing of the Department of Educational Statistics and Analytics. Ukrainian Center for Educational Quality External Implementation Coordination of the software development for testing under IPF Assessment: Component. − UCEQA Deputy Directors; − Department of Evaluations Content in Primary Education; Department of Research and Analytics. In-Service Teacher Training Institutes External Implementation Organization and delivery of the teacher training according to the NUS programs. Regional state administrations: External Implementation Implementation of all state subventions on the local level (budgeting, co-financing, procurement, supervision of works and/or goods delivery, − Departments of Education and oversight of ESF). Science of Amalgamated Territorial Communities; 68 Departments of Education and Science of Regional State Administrations. Ministry of Finance (MoF) − International Financial Projects Department; Internal Implementation/ Interest: − Humanitarian Expenditures Department; Regulatory • Transactions of subventions from the Central to local budgets. − Documents Flow and Execution Control Department; E&C Issues − Legal Department. • GRM supervision. *More detail will be determined after consultations with IA and MoF Direct Beneficiaries − Principals; Internal Implementation/R Interest: All these direct beneficiaries will be directly benefiting from − Teachers; egulatory projects’ interventions in different areas: − Students (pupils); • Inclusive, attractive and comfortable for learning and academic − School Staff; career HEIs; − Families of mention above groups; • Safe, modern and inclusive educational environment; − Locals. • Continuous of professional development (CPD); • EU standards in education; • Access to safe in-personal education; • Access to free transportation; • Access to textbooks and equipment; • Equality. E&S issues or E&S concerns • Protection from climate change hazards affecting their livelihoods; • Unequal access to training programs; • Unequal access to participation of the government program. Other interested Parties − Authors of school textbooks; External Indirect Interest: − Manufacturers of textbooks; beneficiaries • Access to financial resources; − Manufacturers of buses; • Access to high standards and requirements which helps to improve − Manufacturers of other equipment. the quality of their goods and business. − Government; External Implementation/C Interest: − Local Governments and Municipalities. oordination • Increase scientific stuff capacity; • State policies and legislation in harmonized with EU acquis; 69 • Increase territory attractiveness for IDPs and labor force; • improve local milieu for immigrants and be ready to get them back in safe environment. E&S issues • Climate change and disaster risks; • GRM supervision. Development Partners and UA Agencies − (TBC) European Commission, UNICEF, External Consultation and Interest: UNESCO, UNOPS, The Global Partnership for coordination • Increase efficiency in the educational sector; Education (GPE), EBRD, EIB, Council of • Building on experience/coordination with on-going projects; Europe Development Bank (CEB). • Protect vulnerable groups; • Holistic approach and synergy in development and project realization; • Improvement of legislation. Vulnerable Groups and CSO’s that represents them − Students with disabilities; External Beneficiaries Interest: − Teachers with disabilities. • Access inclusive and safe in-person education. E&S issues • Unequal access to career opportunities and professional education. Civil Society Organizations (CSOs) representing the Private Sector − Foundation “savEDâ€?; External Consultation and Interest: − Ukrainian Education platform; outreach • Protection of vulnerable groups; − Ukrainian Child Rights Network; • Improvement of safe and security conditions for in-person − Social Synergy; education. − Fight for Right; − Barrier-Free. E&S issues or E&S concerns • Lack of information and time about discussions and impossibility, to take part in. • Concerns about equitable access to funding shelters (co-financing) 70 Annex 3. Scope of the capacity building and supervision program MoES comprehensive capacity building and supervision program should ensure that: • All the shelters are set up (including adequate water supply and sanitation facilities, requirements for structural stability, energy efficiency, and universal access), serviced and used in compliance with national legislation (including preparedness and response procedures and resources); • The health and safety incidents are reported, investigated and followed through to completion; • All supporting educational materials are known and available to all the beneficiary educational institutions. • Local educational departments and/or schools have necessary methodological guidance and sufficient practical knowledge of the following subjects: o supervision/monitoring of civil works on site; o health and safety incidents reporting, investigation and completion; o cooperation with local authorities on the road infrastructure needs to ensure proper condition of road surface; o budgeting for school transport infrastructure (for servicing and repairing the buses timely); o information/training campaign on traffic rules for children and school staff. The capacity building and supervision program should provide clear guidance on the supervision/ monitoring of civil works by beneficiaries (school and/or local government administrations). The capacity building and supervision program should also facilitate supervision by the local authorities and MoES, as well as nation-wide grievance redress mechanism for reporting incompliances or proposals. The capacity building and supervision program should include third-party monitoring/spot checks during shelter construction and capacity building for local staff. The capacity building and supervision program should include budget for program implementation, as well as templates for regular reporting on program implementation. 71 Annex 4 Consultation Summary Report 1. Introduction The World Bank prepared the Environmental and Social Systems Assessment (ESSA) for the “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? (LEARN). In accordance with the requirements of Program for Results Financing, the ESSA has been consulted with program stakeholders. The objectives of the ESSA consultations were as follows: - Provide meaningful opportunities to engage Program stakeholders with information about the scope, timing, expected effects, and proposed management measures of the Program; - Seek inputs, feedback, and/or confirmation from stakeholders on the factual basis and assumptions used to prepare the ESSA Report, for example, in relation to the application of laws and regulations in practice; - Provide an opportunity for stakeholders to seek clarifications about the basis for any judgments made by the Bank team about the adequacy or acceptability of any aspect of the Program’s E&S effects or proposed management actions; and - Offer an opportunity for stakeholders to suggest alternative management measures The consultations were hosted jointly by the World Bank and the Ministry of Education and Science. Consultations were conducted on July 3rd, 2024. Given the synergies in objectives and issues, the events also covered the ESF instruments prepared and presented by MoES (Stakeholder Engagement Plan and Environmental and Social Commitment Plan (ESCP) ) for the Investment Project Financing (IPF) component of the Operation. The consultation summary is focused on environmental and social issues relevant to the PforR and ESSA, including where those issues are relevant to the IPF and how the two scopes are delineated. However specific comments from stakeholders pertaining to ESF instruments is not addressed in this consultation summary. Based on security considerations and recommendations for holding public meetings under martial law, as well as taking into account that virtual events are common and accessible in Ukraine ),54 consultations the consultations were conducted using an an online format. Two events were organized, one that was tailored for national stakeholders, and a second session tailored for sub- national governments and local entities. The consultations were publicly announced. In addition, personalized invitations for the events were sent to a wide range of stakeholders including government, schools, and civil society representing women’s organizations, people 54 Analytical Report “Opinions and Views of the Population of Ukraine on State Electronic Servicesâ€? https://www.undp.org/uk/ukraine/publications/analitychnyy-zvit-dumky-i-pohlyady-naselennya-ukrayiny-shchodo- derzhavnykh-elektronnykh-posluh-u-2023-rotsi 72 Also, information about the event was with disabilities and ethnic minorities, and international donors. disseminated through the internal official channel of the MoES. The presentation materials were in in Ukrainian and English, with simultaneous translation available for the speakers. The presentations delivered by World Bank and MoES covered the program objectives, components, implementation arrangements as well as stakeholder engagement mechanisms, and information about the grievance mechanism. The environmental and social risks with recommendations for mitigating such risks were elaborated. The ESSA and ESF documents were disclosed on World Bank and MoES website over a 3-week period from June 17 and written comments were accepted at the email address listed. Representatives of the following groups took part in the consultations: management of regional departments of education, representatives of school education institutions including teachers and principals, parents of those getting school education, representatives of professional educational institutions for teachers. 126 participants took part in online consultations. 2. Record of Consultation Events Consultation event (national) Wednesday, July 3, 2022, 15:00 p.m. The discussion of social and environmental management of the World Bank supported Program for Results Operation “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? Present: • Yevhen Kudriavets MoES First Deputy Minister • Ihor Khvorostianyi, Director General for the Directorate of School Education, Ministry of Education and Science of Ukraine • James Gresham, Senior Education Specialist, World Bank • Deborah Beth Berger, Senior Social Development Specialist, World Bank • Oksana Rakovych, Senior Environmental Specialist, World Bank Group Moderator: • Sergiy Artemenko – Project Manager – Head of the Project Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€? 73 AGENDA for the discussion of social and environmental management of the World Bank supported Program for Results “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? Date and time: 3rd of July 2024, 15:00-16:30 1. Presentation of the Project “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? Speakers: Yevhen Kudriavets, First Deputy Minister of Education and Science of Ukraine, Enrique Alasino, Senior Education Specialist, World Bank, James Gresham, Senior Education Specialist, World Bank Moderators: Ihor Khvorostianyi, Director General for the Directorate of School Education, Ministry of Education and Science of Ukraine, Sergiy Artemenko – Project Manager – Head of the Project Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€? 2. Information on the Environmental and Social Assessment of the Project “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? Speakers: Deborah Beth Berger, Senior Social Development Specialist, World Bank, Oksana Rakovych, Senior Environmental Specialist, World Bank Group, Moderators: Ihor Khvorostianyi, Director General for the Directorate of School Education, Ministry of Education and Science of Ukraine, Sergiy Artemenko – Project Manager – Head of the Project Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€? 3. Discussion with meeting participants. Moderators: Ihor Khvorostianyi, Director General for the Directorate of School Education, Ministry of Education and Science of Ukraine, Sergiy Artemenko – Project Manager – Head of the Project Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€? 74 Consultation Summary (sub-national/regional) Wednesday, July 3, 2024, 16:30 p.m. The discussion of social and environmental management of the World Bank supported Program for Results Operation “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? Present: • Ihor Khvorostianyi, Director General for the Directorate of School Education, Ministry of Education and Science of Ukraine • James Gresham, Senior Education Specialist, World Bank • Deborah Beth Berger, Senior Social Development Specialist, World Bank • Oksana Rakovych, Senior Environmental Specialist, World Bank Group Moderator: • Sergiy Artemenko – Project Manager – Head of the Project Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€? AGENDA for the discussion of social and environmental management of the World Bank supported Program for Results “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? Date and time: 3rd of July 2024, 16:30-18:00 1. Presentation of the Project “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? Speakers: Ihor Khvorostianyi, Director General for the Directorate of School Education, Ministry of Education and Science of Ukraine, Enrique Alasino, Senior Education Specialist, World Bank, James Gresham, Senior Education Specialist, World Bank. Moderator: Sergiy Artemenko – Project Manager – Head of the Project Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€?. 2. Information on the Environmental and Social Assessment of the Project “Lifting Education Access and Resilience in Times of Need in Ukraineâ€? Speakers: Deborah Beth Berger, Senior Social Development Specialist, World Bank, Oksana Rakovych, Senior Environmental Specialist, World Bank Group. Moderators: Ihor Khvorostianyi, Director General for the Directorate of School Education, Ministry of Education and Science of Ukraine, Sergiy Artemenko – Project Manager – Head of the Project Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€?. 75 3. Discussion with meeting participants. Moderators: Ihor Khvorostianyi, Director General for the Directorate of School Education, Ministry of Education and Science of Ukraine, Sergiy Artemenko – Project Manager – Head of the Project Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€? 3. Summary of Feedback and Responses The following key points alongside their responses explaining how taken into account, were raised during the consultation sessions: Issue Response/How considered Whether the program will address educational The program supports the implementation needs and equipment for individuals with of NUS. Inclusion is one of the foundational special needs, consistent with international principles of the NUS reform; inclusiveness will norms. be considered a central approach and priority in the content and subventions. The issue of inclusion will be considered broadly [and not limited to those with physical disabilities]. MoES has ensured that it will continue to prioritize inclusivity and schooling of students with special learning needs, as relevant and central to the NUS reform concept. Inclusive learning and teaching arrangements will be considered for both subvention management for the NUS rolling-out under the PforR component and enhancing learning environment for the NUS pilot under the investment component. Implementation arrangements for the Program MoES, local communities and Ministry of and involvement of public Finance will implement the system component organizations/consultants/NGOs regarding of the program, PforR. For the investment special equipment for children with special project, project implementation unit at the MoES will be working with corresponding educational needs. directorates. Additional expertise would be hired as needed, including both international and local companies and individual technical experts. Program activities including where there are considerations for students with special needs, will be consulted by MoES on an ongoing basis, including with NGOs and other stakeholders. The Stakeholder 76 Engagement Planning Document is required to be prepared under the Program Action Plan, and will set out the consultation program in more detail. In accordance with World Bank requirements, special attention is paid to needs of disadvantaged groups. How will the E&S recommendations for The recommendations [in the ESSA] are already contractors [constructing bomb shelters] be consistent with, and provided by Ukrainian enforced? legislation. They are mandatory according to the current legislation. So, there will be no separate enforcement. The contractor must fulfill their contractual obligations. The contract can be suspended until the contractor starts working properly. MoES to focus on the quality, consistency and Both parts of the LEARN project (PforR and sustainability of in-service teacher training, as IPF) will support teacher training. Under the aligned with NUS. PforR there is a focus on grades 7 and 8 and under the IPF there will also be support for teacher training for the NUS pilot grades. During the project implementation, MoES will also liaise with pre-service teacher training institutions (e.g., pedagogical universities) as part of the project effort to improve quality of teacher training. Additional feedback on this topic is welcome since it’s an important aspect of the program. 4. Minutes of Meetings (Q&A Sessions of On-Line consultation events) Session I. National stakeholders Question (Founder of INGO "Child with Future"): Does the program include a real re-certification of teachers from pedagogical universities, considering modern education requirements, including inclusion? Answer: Both parts of the Project will be aimed at the NUS reform. There is no provision for involvement of the higher education institutions, but the work with teachers will be conducted through both in-service and pre-service teacher training. Question (Founder of INGO "Child with Future"): 77 Does the program provide for the creation of conditions and educational programs for children with special educational needs (especially mental disabilities)? If so, will programs legalized in Europe and the USA but not in Ukraine be implemented? Answer: Inclusion is one of the foundational principles of the NUS reform; inclusiveness will be considered a central approach and priority in the content and subventions. Question (Founder of INGO "Child with Future"): Will there be control over the real improvement of teacher qualifications? There are many fake qualification improvement services on the market today. Answer: The Ministry of Education and Science (MoES) has issued an order to create a working group to develop proposals for the Cabinet of Ministers Resolution 800. MoES is aware of the need to control the quality of the service providers. The developed recommendations aim to change this situation. Question (Founder INGO "Child with Future"): Will specialists from public organizations be involved as consultants regarding the special equipment, for example, for children with special educational needs? Answer: All procurements will be performed according to World Bank rules. If there is a need for specialists, the corresponding specialists will be selected according to national legislation and World Bank rules. Question (Deputy director for educational work, geography teacher Vyshniv Lyceum "IDEAL"): Kyiv Region How the recommendations for contractors be enforced? What will happen if requirements are violated? Fines in the contract? Answer: We are making recommendations because they are already provided by Ukrainian legislation. They are mandatory according to the current legislation. So, there will be no separate enforcement. The contractor must fulfill their contractual obligations. The contract can be suspended until the contractor starts working properly. Question (Deputy director for educational work, geography teacher Vyshniv Lyceum "IDEAL"): What is the implementation period - construction? How do you plan to overcome the risk associated with contractors - lack of staff in construction companies? Answer: The period of construction will be defined by the design documentation. The Ministry cannot impact the problem with the staff in the construction companies. Question (Founder of INGO "Child with Future"): 78 The Institute of Educational Content has not responded to the letter about including art books on inclusion in the program for two months. Answer: The comment is noted and will be discussed outside today's agenda. Question (Head of the "Maintaining access to school education" initiative SURGe Project (Canada)) How will this project be implemented? Through which providers? Will the Ministry of Education and Science directly implement it through a project office/project offices for the main directions, or will providers, including NGOs, be selected? Answer: MoES, local communities and Ministry of Finance will implement the system component of the program, PforR. For the investment project, project implementation unit at the MoES will be working with corresponding directorates. Additional expertise would be hired as needed, including both international and local companies and individuals following the approach of other World Bank-funded projects. Question (Director of The Academic Lyceum "Harmony"): Kyiv Region When is the digital State Final Examination planned? Answer: The State Final Examination is canceled during the martial law period. It has been determined that piloting for grades 4 and 9 will take place. During the pilot, the process will be digitized. Question (Founder of INGO "Child with Future"): There are problems the ministry may not be aware of. For example, special headphones that reduce noise levels. We are currently receiving them as humanitarian aid, but it would be good to purchase them for schools, especially in regions with many shellings, so specialists from public organizations are needed. It would be unfortunate if all accessibility were only for children with musculoskeletal problems, and children with sensory and mental issues were left "overboard." Answer: The issue of inclusiveness will be considered very broadly. Question (Anonymous participant): How many shelters are planned to be built with project funds? Answer: The plan is now for 57 shelters. It depends on the available financing in subsequent years and the Ministry of Finance. Investment funds foreseen in this project will not finance the construction. Session II. Sub-National/Regional stakeholders Question (Vice-rector for scientific and methodical work of Kharkiv Academy of Continuous Education): 79 Kharkiv Region In your presentations the indicators for the quality of the construction of shelters was presented in detail. Is there any view in this project about the indicators of the quality of training of teachers under the NUS reform. That would be important to consider for the representative of the In-service Teacher Training Institute. Answer: Yes, the project is intended to, and as you know, the NUS subvention is also aimed at increasing the qualifications of teachers in Ukraine through the In-service Teacher Training Institute. Therefore, these indicators and criteria are considered in both parts of the project. It is important to emphasize, that this also impact not only the teachers, but also the administration of the educational institutions. Therefore, this should be considered in systemic way of the New Ukrainian School reform combining preparation of the teachers, and the management of the educational institutions to share the ideas and principles of the new Ukrainian school. Therefore, the project components pay special attention to local education community, quality of the educational content, professional development of teachers and administration of educational institutions as well as improvement of educational environment. Question (Department of Education and Science of the Kirovohrad Regional State Administration): Kirovohrad Region There is a question about the subject ‘Defense of Ukraine’. According to the paragraph 2 of the order of the Ministry of Education and Science of Ukraine No.731, MoES has to approve the methodical recommendations within a week after issuing the order. We are unable to locate them, and we are expecting these recommendations. This constrains the distribution of the subvention between the territories, and there was also a question of update of the list of typical equipment. Answer: This component regarding the subject ‘Defense of Ukraine’ is not foreseen in the project. The development of the methodical recommendations is currently in progress. They will be released soon, as well as the list of equipment, which is currently under review by the Ministry of Justice. As soon as they appear, we will immediately publish them. Question (Representative of Regional Institute of Postgraduate Education for Pedagogical Workers): Cherkassy Regional There was sufficient financing for the first cycle of basic and secondary education. Now, on September 1, 2024, a full-scale implementation of the NUS concept in the 7th grade is scheduled and there is no subvention for the preparation of teachers yet. We have already, on the voluntary basis and with our own financing start preparing a large cohort of teachers who will start working in the grade 7th from September 1, 2024. Is it possible, at least in the summer period, at least in August, that we have already completed the preparation of teachers of the 7th classes to work for the NUS concept? Are the subvention funds will be provided? Answer: There will be a subvention of the NUS this year. It will provide for the use for the promotion of the qualification of teaching. The draft of the order on use of the NUS subvention in the Cabinet of Ministers of Ukraine. Now, the draft resolution in the Cabinet of Ministers has already passed all necessary review. As soon as the Cabinet of Ministers of Ukraine approves the relevant normative act, the funds will be distributed to the region and teacher trainings will take place, especially for teachers of the 7th grade. 80 Teacher training is a very important part of the New Ukrainian School reform. Teacher training is one of the areas that is going to be supported under both parts of the LEARN project, under the PforR especially with a focus on grade seven and eight. There will also be support for teacher training for the pilot grades where the New Ukrainian School reform is being supported in the grades that will be rolled out in the years ahead. Regarding quality how the ministry is ensuring that level of quality, how they are able to manage and monitor this, the Bank is discussing with MoES about this exact point, on the planning for the teacher training aspects, as well as instruments that the Ministry, as well as some of the specialized agencies like the Ukrainian institute for Education Development, for example, could use to help support the quality of teacher training as well. These points are well-taken and additional feedback is welcome on teacher training quality or any other concerns to raise, either now or separately in writing to the Ministry. Since we know this is an important aspect of the program. 5. List of the participants Session 1 â„– Name Position Organisation 1 Dr. Yevhen Kudriavets First Deputy Minister MoES 2 Ihor Khvorostianyi Director General for the Directorate of MoES School Education, Ministry of Education and Science of Ukraine 3 Kateryna Suprun Education specialist UIHERP 4 Serhiy Artemenko Project Manager – Head of the Project UIHERP Implementation Unit “Ukraine Improving Higher Education for Results Projectâ€? 5 Dmytro Shmondenko Lawyer UIHERP 6 Mykola Horbovtsov Assistant UIHERP 7 Anastasiia Bihun Specialist World Bank 8 Deborah Berger Senior Social Development Specialist World Bank 9 Oksana Rakovych Senior Environmental Specialist World Bank 10 Kirsi Marianne Lindroos Educaton Specialist World Bank 11 James Gresham Senior Education Specialist World Bank 12 Enrique Alasino Senior Education Specialist World Bank 13 Sheburenkov Oleksandr STC World Bank 14 Margaryta Rymarenko Coordinator of the Education Cluster of Save the Children Ukraine 15 Olena Shevchuk Student's mother "Zhmeryn Lyceum No. 4" of Vinnytsia region 16 Vira Shchehol Director Boiarka Academic Lyceum "Harmony" of the Boiarka City Council 81 17 Nataliia Andreeva Head Charity and public organization "School-stairs" 18 Sofia Andriivna Tsvik Student of the 9th grade Communal institution "Rossoshensk gymnasium of Shcherbanivsk village council of Poltava district of Poltava region" 19 Vovk Tetyana Yuriivna Mathematics teacher, trade union Communal institution secretary "Rossoshensk gymnasium of Shcherbanivsk village council of Poltava district of Poltava region" 20 Oleksandr Dmytrovych Director Communal institution of general Dubina secondary education "Lutsky Lyceum No. 9 of the Lutsk City Council of the Volyn Region 21 Vira Rybak Representative Council of Europe 22 Anastasiia Nenka Representative Information and Consultation Women's Center 23 Inna Sergienko Founder INGO "Child with Future" 24 Institute of Education Representative Institute of Educational Content Content Modernization Modernization of the Ministry of Education and Science of Ukraine 25 Anastasia Donska Head of the direction for overcoming NGO "Teach for Ukraine" educational losses 26 Marharyta Chaika Head People In Need, Ukraine Education Cluster 27 Sofiy Natalia Zinovievna Director State Institution "Ukrainian Institute for Education Development" 28 Dubovik Olena Deputy director for educational and State Institution of Education "The Anatolyivna methodological support of the content Institute for the Modernization of of education the Content of Education" 29 Andrii Lytvynchuk (IEA) Acting Director of the State Scientific State Scientific Institution "Institute Institution "Institute of Educational of Educational Analytics" Analytics" 30 Yuriychuk Ivan Deputy Chairman for digital State Service of Education Quality Yaroslavovych development, digital transformations of Ukraine and digitization 31 Baibuza Iryna Serhiivna Teacher Support institution "Reshetyliv Lyceum named after I. L. Oliynyk of the Reshetyliv City Council" of the Poltava region 32 Zadorozhnyy Nazar Student of the 9th grade Support institution "Reshetyliv Lyceum named after I. L. Oliynyk of the Reshetyliv City Council" of the Poltava region 33 Rak Zhanna Vitalyivna Director Support institution "Reshetyliv Lyceum named after I. L. Oliynyk of the Reshetyliv City Council" of the Poltava region 82 34 Olena Zaplotynska Head of the "Maintaining access to SURGe Project (Canada) school education" initiative 35 Teach For Ukraine Representative Teach For Ukraine 36 Yuliana Nishchyk Representative The main institution of general secondary education "Rakovo-Lisky Lyceum" of the Kamin-Kashir city council of the Volyn region 37 Viktor Viktorovych Sapalov Deputy director for educational work, Vyshniv Lyceum "IDEAL" of Vyshniv geography teacher city council, Buchan district, Kyiv region 38 Olga Shevchenko deputy director for educational work Zhmerinka Lyceum No. 4 39 Ruslan Olegovich Teacher of history, law and civic Zhmerinka Lyceum No. 4 Nazarinsky education 40 Oleksandr Fedorovych Acting director Zhytomyr Regional Sports Lyceum Stashenko 41 Doljko Oksana Anatolyivna Teacher of foreign language and Zinkiv Support Lyceum No. 1 of German language Zinkiv City Council, Poltava Region 42 Dmytros Vladyslava Student of the 10th grade Zinkiv Support Lyceum No. 1 of Valeriivna Zinkiv City Council, Poltava Region 43 Ruslan Representative BF «Krylati UA» 44 Dariia Representative 45 Roman Kulchynskyi Interpreter 46 Artur Scevchuk Not identified 47 Tetiana Not identified 48 Julia Not identified 49 iphone NVL Not identified 50 Tetiana Rodionova Not identified 51 Anastasia Parubets Not identified 52 Ivanna Vikhtynska Not identified 53 Natali M-K Not identified 54 Diana Nazarenko Not identified 55 Віталій Дмитрук Not identified 56 Not identified Not identified 57 Rehub Not identified 58 Andrianna Lukach Not identified 59 Not identified Not identified 60 Lyudmyla Lisohor Not identified 61 Marusynets Mariana Not identified Session 2 â„– Name Position Organisation 1 Ihor Khvorostianyi Director General for the MoES Directorate of School Education 2 Kateryna Suprun Representative UIHERP 83 3 Mykola Horbovtsov Assistant UIHERP 4 Serhiy Artemenko Project Manager of the World UIHERP Bank Project Implementation Unit 5 Dmytro Shmondenko Representative UIHERP 6 Anastasiia Bihun Representative World Bank 7 Deborah Berger Senior Social Development World Bank Specialist 8 James Gresham Senior Education Specialist World Bank 9 Oksana Rakovych Senior Environmental Specialist World Bank 10 Anatolii Zaliskyi Rector Chernihiv Regional Institute of Postgraduate Pedagogical Education named after K.D. Ushynsky 11 Olha Khudenko Vice-rector Communal Higher Educational Institution "Kherson Academy of Continuous Education" 12 Svitlana Odaynik Vice-rector for external Communal Higher Educational Institution assessment and quality "Kherson Academy of Continuous monitoring of education Education" of the Kherson Regional Council 13 Yulia Fedorova Representative Communal Institution "Kirovohrad Regional Institute of Postgraduate Pedagogical Education named after Vasyl Sukhomlynsky" 14 Halyna Anatoliyivna Representative Communal Nonprofit Institution Nazarenko "Cherkasy Regional Institute of Postgraduate Education for Pedagogical Workers of the Cherkasy Regional Council" 15 Hordunovska L.V. Representative Department of Education and Science of the Cherkasy Regional State Administration, L.V. Hordunovska 16 Oksana Hryniuk Representative Department of Education and Science of the Chernivtsi Regional Military Administration 17 Liudmyla Pavlivna Representative Department of Education and Science of the Dnipropetrovsk Regional State Administration 18 Department of Education Representative Department of Education and Science of and Science of the the Kirovohrad Regional Military Kirovohrad Regional Administration Military Administration 84 19 Urdei Olena Ivanivna Representative Department of Education and Science of the Lviv Regional State Administration 20 Department of Education Representative Department of Education and Science of and Science of the Odesa the Odesa Regional State Administration Regional State Administration 21 Maryna Pashkovska Rivne Representative Department of Education and Science of the Rivne Regional Military Administration 22 Svitlana Bodnar Representative Department of Education and Science of the Ternopil Regional Military Administration 23 Natalia Osypovych Representative Department of Education and Science of the Zhytomyr Regional Military Administration 24 Department of Education Representative Department of Education of the Bilovodsk of the Bilovodsk Settlement Council Settlement Council 25 Larisa Suprun Representative Department of Education of the Executive Committee of the Bilovodsk Settlement Council of the Luhansk Region 26 Maryana Dmytriv Representative Department of Education of the Lviv Regional Military Administration 27 Yulia Kurpas Representative Department of Education of the Lysychansk City Military-Civil Administration of the Sievierodonetsk District of the Luhansk Region 28 Kseniia Rozuvaieva Representative Department of Education of the Novoaidar Settlement Council 29 Tetiana Representative Department of Education of the Novopskov Settlement Council of the Luhansk Region 30 Department of Education Representative Department of Education of the Poltava of the Poltava Regional Regional Military Administration Military Administration 31 Oksana Donchenko Representative Department of Education of the Sievierodonetsk City Military Administration of the Sievierodonetsk District of the Luhansk Region 32 Natalia Havvina Representative Department of Education of the Sievierodonetsk Military Administration 85 33 Olha Popova Representative Department of Education of the Starobilsk City Council 34 Alina Tverdokhlib Representative Department of Education of the Zhmerinka Territorial Community 35 Daria Ihnatieva Representative Department of Education, Culture, Sports, and Healthcare of the Shchastia District State Administration of the Luhansk Region 36 Viktoria Representative Department of Education, Culture, Youth, and Sports of the Shyrokivska Military- Civil Administration of the Shchastia District of the Luhansk Region 37 Alla Ostapenko Vice-rector for scientific and Kharkiv Academy of Continuous methodical work Education 39 Anna Tishchenko Representative Pluhatarskyi Communal Preschool Educational Institution 40 Olena Sobol Chief specialist of the Starobilsk District State Administration Department of Education, Healthcare, Culture, and Sports 41 Dariia Not identified 42 DON KODA Not identified 43 Kirsi Marianne Lindroos Not identified 44 Larisa Suprun Not identified 45 Liudmyla Komlyk Not identified 46 Liudmyla Kybenko Not identified 47 Liudmyla Not identified Myroshnychenko 48 Liudmyla Zaporozhets Not identified 49 Maryna Pashkovska Rivne Not identified 50 Mira Melomedova Not identified 51 Natalia Dankiv Not identified 52 Oksana Babii Not identified 53 Oleksandra Vystorobska Not identified 54 Olena Polovenko Not identified 55 Polovenko Not identified 56 Roman Zubiak Not identified 57 Sachovska (IF-DON) Not identified 58 Tamila Petrovna Not identified Lebedeva 59 Tetiana Not identified 60 Vadym Pylypenko Not identified 61 Valentyna Franchuk Not identified 62 Viktoria Not identified 86 63 Vitalii Bilash Not identified 64 Yulia Sirotkova Not identified 65 Roman Kulchynskyi interpreter 87 6. Screenshots from the meetings 88