AFGHANISTAN Emergency Food Security Project- Additional Financing (AF) (P178280)) OSRO/AFG/140/WBK Labour Management Procedure (LMP) for AF1 The designations employed and the presentation of material in this document do not imply the expression of any opinion whatsoever on the part of the Food and Agriculture Organization of the United Nations (FAO) concerning the legal or development status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries. This document is intended to be used solely for the purpose of FAO projects disclosure April 2024 1 Table of content Table of content ............................................................................................................................................ 2 1. INTRODUCTION ..................................................................................................................................... 3 2. OVERVIEW OF LABOR USE IN THE PROJECT .......................................................................................... 4 2.1. Type of Workers ........................................................................................................................... 4 2.2. Labor Requirement Forecast........................................................................................................ 4 3. ASSESSMENT OF KEY POTENTIAL LABOR RISKS ..................................................................................... 6 4. BRIEF OVERVIEW OF LABOR LEGISLATION: TERMS AND CONDITIONS ................................................ 11 4.1. National Labor Legislation .......................................................................................................... 11 4.2. The World Bank Environmental and Social Standard 2 .............................................................. 12 4.3. FAO Environmental and Social Standard 4 ................................................................................. 12 4.4. Key Gaps Between National Legislation, World Bank ESS2 and FAO ESS4 ................................. 13 5. POLICIES AND PROCEDURES ................................................................................................................ 15 6. AGE OF EMPLOYMENT ........................................................................................................................ 18 7. TERMS AND CONDITIONS .................................................................................................................... 18 8. TRAINING AND SENSITIZATION............................................................................................................ 19 9. Workers’ Grievance Redress Mechanism ............................................................................................ 19 9.1. UN Staff ...................................................................................................................................... 19 9.2. Implementing Partners Workers ................................................................................................ 20 9.3. Community workers ................................................................................................................... 22 9.4. FAO staff sanctions and appeals ................................................................................................ 22 10. CONTRACTOR MANAGEMENT ....................................................................................................... 22 Appendixes .................................................................................................................................................. 25 Appendix 1: individual code of conduct in case of contractor................................................................. 25 Appendix 2: Environment, social, health and safety incident tracker ..................................................... 27 Appendix 3: Employment, Health and Safety conditions Monitoring Form (Checklist) ........................... 28 Appendix 4: Matrix for Potential Risks Mitigation ................................................................................... 29 Annex 5 Managing COVID-19 risks on construction sites ...................................................................... 38 2 1. INTRODUCTION Under the World Bank Environmental and Social Standard 2 (ESS2): Labor and Working Conditions, the Borrower (in this case FAO as the grant receiver) is required to develop labor management procedures (LMP). The purpose of the LMP is to identify the main labor requirements and risks associated with the project and help the Borrower to determine the resources necessary to address project labor issues. The LMP will enable different project-related parties such as staff of the project implementing unit, consultants, and project workers, to have a clear understanding of what is required on a specific labor issue. Under FAO’s Framework for Environmental and Social Management (FESM) the 4th Environmental and Social Standard (ESS4) is on “decent work� and applies to all FAO-implemented projects and was used to develop these labor management procedures. The objectives of ESS4 on decent work is to: • Promote direct action to foster decent employment. • Promote, respect and realize fundamental principles and rights at work by: o supporting freedom of association and the effective recognition of the right to collective bargaining. o preventing the use of child labour and forced labour. o promoting fair treatment, non-discrimination and equal opportunity for all workers, including waged and salaried employees, self-employed workers and contributing family members; and o protecting and supporting workers, particularly categories of workers at heightened risk. • Protect and promote the safety and health of workers. • Ensure programs and projects comply with national employment and labour laws and international commitments. • Have in place effective measures to address emergency events, whether human-made or natural hazards. • Leave no one behind by protecting and supporting workers at heightened risk, with a special focus, as appropriate, on women workers, young workers, migrant workers, workers in the informal economy and workers with disabilities. The project implementation will involve direct workers (consultants and staff recruited by FAO to work specifically in relation to the project), contracted workers (workers of implementing NGOs/contractors, laborers), community workers and primary supply workers. There are certain labor related risks involved as the project will provide temporary employment opportunities for unskilled workers who have little or no knowledge or experience in applying Occupational Health and Safety (OHS) measures. Labor related issues could also include discrimination in recruitment, forced labor, child labor, unsafe working conditions, potential physical safety risks of the project actors due to Fragile, Conflict and Violence (FCV) context, Sexual Exploitation Abuse/Sexual Harassment (SEA/SH) risk, and the risk of Covid-19 transmission to workers. Further, labor who are likely to be employed by the project could also come from outside the local area, creating potential labor influx issues. Accordingly, this LMP has been prepared for the Emergency Food Security Project-Additional Financing (EFSP-AF). This simplified LMP will cover basic nondiscriminatory policies, OHS training, Personal Protective Equipment (PPE) and management measures and code of conduct to prevent SEA/SH. FAO and 3 implementing Non-Governmental Organizations (NGOs)/contractors will implement adequate OHS measures (including emergency preparedness and response measures) in line with the Environmental and Social Management Framework – Additional Finance (ESMF-AF) and the Environmental and Social Commitment Plan (ESCP). The OHS measures as spelled out in the ESMF-AF will cover all relevant aspects of the World Bank Group's General Environment, Health, and Safety Guidelines (EHSGs) and ESS2. The purpose of the LMP is to facilitate planning and implementation of the project. The LMP identify the main labor requirements and risks associated with the project and help the project to determine the resources necessary to address project labor issues. 2. OVERVIEW OF LABOR USE IN THE PROJECT 2.1. Type of Workers World Bank (WB) ESS 2 categorizes the workers into: direct workers, contracted workers, community workers, and primary supply workers (i.e., suppliers of goods to FAO). The LMP will apply to project workers including fulltime, part-time, temporary, and seasonal. The project will involve the following types of workers: 1. Direct Workers. People employed directly by FAO to work specifically in relation to the project in the Project Management Unit (PMU) at the Head Office as well as in FAO field offices across target countries. The category will also include field personnel directly contracted by FAO and based at various project sites within the states/counties. This category includes all FAO employees including international and national staff and consultants and Personal Services Agreement (PSA) subscribers. 2. Contracted Workers. People engaged through third parties to perform work related to core functions of the project, regardless of location. Under this category are included employees of implementing partners (including NGOs) that FAO contracts to implement project activities. 3. Primary Supply Workers. People engaged by FAO as primary suppliers. These include, for example, suppliers of construction materials including aggregates and precast concrete interlocking blocks, or other goods and material as required. 4. Community Workers. People employed or engaged in providing community-based project interventions. These will include community members who will be working in rehabilitation and improvement of irrigation schemes and watershed areas. 2.2. Labor Requirement Forecast EFSP-AF will be implemented by FAO with support from contracted implementation partners to deliver certain activities. ESS2 applies to all project workers, including full-time and part time contracted and direct hire workers. The table below (Table 1) gives an overview of indicative labor use in the project. 4 Table 1: Labor Requirement Analysis Type of project workers Characteristics of Timing of labor Indicative number of project workers requirements workers • Direct workers • PMU: International • PMU and PIUs: • PMU: approx. 50 • PMU permanent and national experts throughout project employees including staff/ consultants • PIU: National implementation 1 Project Manager; • Project consultants • Field workers: 1 Implementation Implementation • Field workers: during project Specialist; 1 Unit (PIU) National implementation– International consultants • Short term mainly during the Environmental and • Heads of field consultants are baseline surveys, Social (E&S) offices/ field staff experts in a specific community Specialist, 2 Senior • Short term field recruited for mobilization and E&S Specialists and consultants short term phases of training 16 E&S Assistants in • Support staff assignments and distribution of charge of • Support staff inputs Environmental and include • Short term Social Management, administrative staff consultants on need 1 International (procurement, basis (few weeks or Gender Specialist, 8 financial few months) Gender Assistants; 2 management, • Support staff usually M&E Officers; 1 human resources), on permanent basis Agricultural drivers, guards, etc. through Engineer;; 1 implementation Communications Officer; 1 National Seed Officer; 1 Natural Resource Management Officer; 12 operations/ admin/support staff and Security personnel • Contracted workers • Skilled permanent • Duration of several • The number of staff of the primary months to several contracted workers contractor years specified by will be identified (implementing contract or letter of during the project partners/NGOs, agreement signed implementation consulting company, with stage. They might be construction implementation of approximately 50- company): most partner / contractor. 100. likely national staff involved in community mobilization, agricultural practices and 5 extension, seed production marketing and in construction work of small facilities. • Skilled workers engaged by sub- contractors for construction work. • Employees of third- party monitoring agency / contractor • Unskilled workers engaged by contractors: Most likely local workers • Primary supply • Workers of local, • Project • The primary supply workers national, or implementation workers will be • Workers engaged by international identified during the primary suppliers suppliers providing project supplies/materials implementation for the project. stage • Community workers • This is labor that can • Project • Could be hundreds. be made available implementation The community by the community workers will be for the benefit of identified during the sub-projects (in kind project contributions to implementation community stage and the LMP activities) will be updated accordingly 3. ASSESSMENT OF KEY POTENTIAL LABOR RISKS The project activities under Components 1&2, could cause potential adverse labor impacts and risks. The focus of component 1 “Restoring Agriculture Production � will a) scale-up the distribution of wheat cultivation package and climate smart crop production training to new food insecure households in selected districts under the existing subcomponent 1.1; b) expand Technical Assistance (TA) for Private Seed Enterprises (PSE) under subcomponent 1.3 focusing on strengthening their capacity to diversify production of seed and marketing beyond wheat and c) add a new activity under subcomponent 1.2 to provides support for value addition for horticulture commodities�. . Component 2 “provision of water and resilience services� will include both the agronomic or bio-engineering measure as well as structural measure of watershed management interventions; on-farm climate resilient water management practices; restoration of irrigation systems and capacity building/training, research/studies.. The main labor risks assessed are related to working conditions and protection of the workforce in accordance with the requirements of World Bank ESS2 and community health and safety under ESS4. The 6 potential labor risks are highlighted in the table below (Table 2) and more details are provided in Appendix 4. Table 2: Labor Risk Identification and Analysis Risk/Impact Analysis (Magnitude, Extent, Risk Mitigation Measures Timing, Likelihood, Significance) ESS2: Labor and working conditions Labor disputes Given the generally high conflict The Project will provide workers’ GRM with over contracts potential, it is possible that additional support from sector specific or lack of a disputes over contracts emerge institutions, an independent legal third party or Grievance courts for cases unresolved within the GRM Redress Mechanism (GRM) for workers to raise workplace concerns. Poor working Due to the protracted conflict in Supervision of Contractor Labor Management conditions: Afghanistan and the weakness of Practices is essential to mitigate against this risk. Unsafe work formal justice institutions, The contractor checklist in Appendix 4 will be environment employees’ working conditions used. are poor and the project needs to The ESMP and ESMP checklist will include ensure that such working requirements for accommodation for workers, conditions are not accepted. The and workers’ access to potable water and impact is significant in that it may sanitation facilities. There will also be manifest in exploitation of the requirements and contractual obligations community that the project included regarding social insecurity in intends to benefit, community employment and adequate measures relating to workers, but also contracted the remuneration of temporary workers and workers may be affected. women. There will be Grievance Redress The project’s activities can cause Mechanism (GRM) for project workers in line with labor and working conditions ESS2. The worker’s GRM will be established prior issues (such as inadequate to the start of works. accommodation for workers, lack of access to potable water, sanitation facilities, occupational health and safety (OHS), Discriminatory The risk of discrimination in All workers should be recruited through a hiring recruitment and employment of transparent and non-discriminatory process. practices women and other marginalized The priority should always be given to local groups is a potential risk. If there employment, if they are able to fulfil the job is no deliberate effort by the requirements. project to encourage the local women to thrive in contracted IPs and Contractors are compelled to safeguard work or community work the risk the interests of women, including gender parity at 7 of missing them as beneficiaries of the workspace, prohibiting, preventing and potential employment is punishing sexual harassment and other forms of substantial. GBV towards female workers by other project workers, appropriate sanitation facilities at workplace, and appropriate PPE for women. The project has prepared an Action Plan to Address Sexual Exploitation Abuse to guide the SH/SEA and gender parity issues in project intervention areas. The activities under components 1 The SEA/SH action plan will include measures and Risks Sexual & 2 will mainly involve local actions which will be included in the ESMP. The Exploitation workers. The contractors are ESMP and ESMP checklist will also include codes Abuse/Sexual expected to involve a very limited of conduct for workers that will include Harassment workforce from outside the prohibitions against SEA/SH and potential (SEA/SH) Project’s area of influence to sanctions and penalties for non-compliance. The contractor will be obliged by the contract not to reside in the work camp. The use any violence, and the Code of Conduct (CoCs) contractors are likely to engage must clearly stipulate that the contractor and his some women workers for staff must respect and observe local customs and temporary employment, such as traditions, respect local women, women involved site cleaning, food service in the construction activities of the project and workers, etc. The female their privacy. The PIU will monitor and report any contracted workers will not stay at identified facts or absence of violations. the labor camp. Thus, the potential SEA/SH risks to female workers will be minimized. Likely There is a risk that child and forced The risk of child labor will be mitigated through incidents of labor, for example in the form of the application of age verification procedures. child and community workers. The Forced Labor contractor’s activities can also The project will not recruit any employee below involve child labor. the age of 18. FAO will enforce this measure through its implementing partners and contractors. This is in line with the FAO framework on ending child labour in agriculture (http://www.fao.org/3/ca9502en/CA9502EN.pdf) which aims to contribute to eliminating all forms of child labour by 2025 (target 8.7 of the 2030 Agenda). It is consistent with ESS2 in that it prohibits child work under the age of 14 and strictly restricts child labour between 14-17 in particular to situations where the work is hazardous or interfering with the child education and development. The FAO framework is also consistent with ESS4 on community health and safety. 8 The ESMP will include requirements for the application of age verification procedures by contractors for all employees. This will be done by using legally recognized documents such as the National Identification Card, and Birth Certificate. The contractor’s Code of Conduct will also contain provisions on no use of child and forced labor in the project activities. Further, awareness-raising sessions will be conducted regularly in the communities to sensitize on prohibition and negative impacts of child and forced labor. FAO projects will ensure that no forced labor is involved in carrying out project activities, which consists of any work or service not voluntarily performed that is exacted from an individual under threat of force or penalty. This covers any kind of involuntary or compulsory labor, such as indentured labor, bonded labor, or similar labor- contracting arrangements. The project will develop a methodology and a set of principles to assess the voluntary nature of the work. Contractors’ obligations will be spelled out in their respective contracts and the PMU will monitor full compliance. Injuries at the The risk comes from the fact that Contractor occupational risk assessments and workplace PPE may be scarce for contracted mitigation plans will be devised and workers or community workers, implemented to provide response and service for and health and safety regulations workplace injuries. The OHS measures could may not exist sufficiently or not be include identification of likely OHS risks enforced. associated with project activities, training of exposed workers to these risks and how these risks can be addressed by workers through i) implementation of Standard Operating Procedures, and ii) use of PPE. Excessive Workers may be exposed to FAO and all implementing partners and hours of work, pesticides and other chemicals contractors will comply with OHS mitigation lifting of heavy due to inadequate supply of PPE measures included in the updated ESMF and objects and or inappropriate use of PPE along generic ESMP. exposure to with poor adherence to safety chemicals guidelines. Provision of sufficient PPE and regular training on (such as safety practices will be ensured, with regular pesticides, compliance monitoring undertaken by FAO. chemical fertilizers) Working hours, whether normal or overtime shall not exceed 12 hours per day. 9 The use of chemicals should be avoided without proper monitoring/training by specialists. If necessary for its use, the safety of deliveries of hazardous substances, storage, transport, use and disposal should be controlled. ESS4: Community Safety and Health Labor influx There is likely to be internal FAO and all implementing partners and and movement of people from areas contractors will implement the Labor Influx GBV/SEA/SH outside the project areas to seek Management Procedure (see Annex 5); a employment and associated Framework for Violence and Harassment benefits from within targeted Protection Plan for Women and Children will be communities. Furthermore, implemented (see separate plan as part of the contracted workers may be ESMF-AF). brought into communities to conduct construction works. Population movement due to labor influx may result in GBV/SEA/SH cases. Spread of Population movement due to FAO and all implementing partners and diseases in labor influx may result in the contractors will implement the Labor Influx communities, spread of HIV and other diseases. Management Procedure at construction site (see including Annex 5), including sensitization on preventing COVID-19, HIV communicable diseases. Communication of risks etc. through will be conducted through locally appropriate labor influx means – targeting specific social groups and genders. Beneficiaries During the distribution of inputs, FAO and all implementing partners and exposed to cash for work activities, contractors will ensure, as far as possible, that thermal beneficiaries may be exposed to beneficiaries are protected under shade (trees, hazards that thermal hazards for long hours. porch, etc) during the input distribution process. involve Thermal hazards can directly In situations of extreme heat, ensure a supply of extreme heat cause injury or death due to water for drinking. They should also provide or cold. extreme temperatures, and adequate PPE to protect workers from exposure indirectly lead to dangerous to occupational injuries and diseases. situations like the spread of diseases. The magnitude of this risk is high, localized, short-term, likely to occur with moderate significance. Poisoning and The risk comes from likely Extensive stakeholder consultation will be carried other negative community exposure to pesticides out to ensure communities, and in particular health impacts especially school-going children, vulnerable groups are well informed about as a result of elderly, physically challenged operation timings and protection measures. drifting of persons, and expectant mothers. pesticides The drifting of pesticides unless from ground care is taken would harm and aerial livestock, game, birds and other 10 spraying ecosystem fauna and flora. There operations is also a likelihood of the same pesticides unless abated the seepage will find itself in water bodies thus contaminating the food chain through pollution. Poor and Households participating in food Training on good agricultural practices including unsafe production and aquaculture health and safety best practice will be provided. practices by activities may expose themselves project to hazards and injuries from poor beneficiaries handling of tools during their work in crop production/ aquaculture 4. BRIEF OVERVIEW OF LABOR LEGISLATION: TERMS AND CONDITIONS 4.1. National Labor Legislation Over the last two decades, the Government of Afghanistan has enacted several laws and policies relating to working conditions, promotion of safety and health at work, fair treatment and non-discrimination, prevention of forced labor and child labor and protection of vulnerable workers. Key among these are Afghanistan Labor Law 2007, Ensuring Health, and Safety Conditions (Article 107) and, have relevant clauses that support ESS2 to Project workers will be provided with information that is clear and understandable regarding their terms and condition of employment. The Afghanistan Labor Law 2007 is the main legislation that guide labor practices in Afghanistan. Terms and conditions provided by this law includes prohibition of child labor, prohibition of forced labor, freedom of association, prohibition of discriminations, employment standards i.e., maximum hours of work, night work standards, right to break during working day, leave and fair terminations. The above terms and conditions apply to the long-term consultants. Some of these terms and conditions also apply to community workers i.e. prohibition of child labor, prohibition of forced labor, prohibition of discriminations and maximum hours of work. The legislation requirements conform to guidance provided in the project Environmental and Social Management Framework (ESMF-AF) and WB Environmental and Social Standard 2 (ESS 2). Afghanistan Occupational Ensuring Health and Safety Conditions (Article 107) describe procedures to be followed to ensure workers safety. Furthermore, the law makes provisions on safety, and health of persons in places of work. Measures relating to OHS are for protecting workers from injuries, illness or impacts associated with exposure to hazards encountered in the workplace or while working. Such OHS measures include provision of PPE, awareness raising and guidance on how to prevent accidents at workplace. These align with the requirements of ESS2 and national laws on health safety and workplace conditions. 11 4.2. The World Bank Environmental and Social Standard 2 The World Bank’s stipulations related to labor are outlined in its Environmental and Social Standard 2 on Labor and Working Conditions (ESS2). This helps the Borrowers in promoting sound worker-management relationships and enhances the development benefits of a project by treating workers in the project fairly and providing safe and healthy working conditions. The key objectives of the ESS 2 are to: • Promote safety and health at work. • Promote the fair treatment, non-discrimination, and equal opportunity of project workers • Protect workers, including vulnerable workers such as women, persons with disabilities (PwDs), children (of working age, in accordance with this ESS) and migrant workers, contracted workers, community workers, and primary supply workers, as appropriate • Prevent SEA/SH at workplace • Prevent the use of all forms of forced labor and child labor • Support the principles of freedom of association and collective bargaining of project workers; in a manner consistent with national law; and • Provide project workers with accessible means to raise workplace concerns including GRM. ESS2 applies to project workers, saving in full-time, part-time, temporary, and seasonal capacities. Where government civil servants are working in connection with the project, whether full-time or part-time, they will remain subject to the terms and conditions of their existing public sector employment agreement or arrangement, unless there has been an effective legal transfer of their employment or engagement to the project. ESS2 will not apply to government civil servants. 4.3. FAO Environmental and Social Standard 4 FAO is committed to support the implementation of internationally accepted labour standards. FAO vision for sustainable food and agriculture explicitly prioritizes decent work. ES4 7 recognizes that promoting decent work, preventing the use of child labour, exploitation, including sexual exploitation and forced labour is essential to achieving food security and reducing poverty. A number of international conventions and instruments underpin the requirements of ESS4. Objectives: • Promote direct action to foster decent employment. • Promote, respect and realize fundamental principles and rights at work by: o supporting freedom of association and the effective recognition of the right to collective bargaining; o preventing the use of child labour and forced labour; o promoting fair treatment, non-discrimination and equal opportunity for all workers, including waged and salaried employees, self-employed workers and contributing family members; and 12 o protecting and supporting workers, particularly categories of workers at heightened risk. • Protect and promote the safety and health of workers. • Ensure programmes and projects comply with national employment and labour laws and international commitments. • Have in place effective measures to address emergency events, whether human-made or natural hazards. • Leave no one behind by protecting and supporting workers at heightened risk, with a special focus, as appropriate, on women workers, young workers, migrant workers, workers in the informal economy and workers with disabilities. 4.4. Key Gaps Between National Legislation, World Bank ESS2 and FAO ESS4 Table 1. Summary of World Bank and FAO Requirements and Key Gaps with Afghanistan Legal Requirements Key Labour Major WB and FAO Key Principles to be followed by the Related requirements requirements/ Project Provisions gaps in Afghanistan legal framework Working The Borrower will develop and Article 13 and The Project will follow the conditions and implement written labor 15, Chapter 2 of national regulations and WB ESS management management procedures Labor Law 2007 2 and FAO Standard 4 of labor applicable to the project. These states the terms requirements. relations procedures will set out the way and conditions of in which project workers will be employment of The PIU will also initiate training managed, in accordance with workers. programs for the project workers the requirements of national in terms of applicable working law and this ESS (ESS 2). The conditions and management of procedures will address the labor relations in line with way in which this ESS will apply national labor law. to different categories of project workers, including direct workers, and the way in which the Borrower will require third parties to manage their workers in accordance with paragraphs 31–33 (GUIDANCE NOTE FOR BORROWERS: ESS2: Labor and Working Conditions). Grievance A grievance redress mechanism Decree No (94), An initial assessment of NGOs to Redress will be provided for all workers dated January be engaged and whether they Mechanism (and, where relevant, their 17, Labor Law have GRMs in place would be (GRM) organizations) to raise 2007 undertaken. Awareness training workplace concerns. Workers (including but not limited to 13 will be informed of the SEA/SH for GRM personnel) to be grievance mechanism at the provided to build capacity for time of GRM including escalation recruitment/involvement with timelines, reporting and the project and the measures decision-making timelines, put in place to protect them hotline etc. to be included as part against reprisal for its use. of training program. Measures will be put in place to make the grievance mechanism easily accessible to all project workers. Categories of The term “project worker� The Labor Law The categories of workers will be workers refers to: recognizes direct per this LMP; the terms and (a) People employed or (non-UN), conditions, training etc. would be engaged directly by the contracted and implemented according to Borrower (including the project service workers. International Labour proponent and the project Organization (ILO) standards, implementing agencies) to national regulation, and WB ESS2 work specifically in relation to and FAO Standard 4 the project (direct workers). requirement. (b) People employed or engaged through third parties to perform work related to core functions of the project, regardless of location (contracted workers). © People employed or engaged by the Borrower’s primary suppliers (primary supply workers). (d) People employed or engaged in providing community labor (community workers). Minimum age Fourteen years and above, Convention 138 FAO will allow deployment of of workers unless national law specifies a on Minimum people aged 18 years and above. higher age (World Bank ESS2: Age Convention FAO will apply a rigorous Labor & Working Conditions) (1973) has monitoring system to ensure that Persons 14-18 are prohibited specified that all the contractors adhere to the from work considered workers doing child and forced labor hazardous, that will interfere light types of requirement. The project will with their education or be work should require the implementation of harmful to their health or complete age of age verification procedures by development (physical, mental, 15 and those contractors for all its prospective spiritual, moral, or social). trying to learn a employees by use of National profession Identity Card and/or Passport. should complete The contractor's Code of conduct will also contain provisions on no 14 the age of 14. use of child and forced labor in (15 above). the project activities. FAO will develop public outreach Recruiting young materials which will be people less than disseminated in the project areas 18 years of age to sensitize the prohibition of for businesses child and forced labor. The QPR that are injurious by the FAO-PIU will include to their health details about child and forced and cause labor implementation physical damage compliance. or disability is prohibited. 5. POLICIES AND PROCEDURES The Labor Management Procedures (LMP) has been prepared to manage and mitigate worker related risks and impacts of the Project. The LMP sets out the approach to management of labor issues in the project and meeting requirements of applicable legislations and the World Bank Environmental and Social Framework (ESF). Policies and procedures applicable for this project are detailed as those related to: (i) Incidents and Accident; (ii) Occupational Health and Safety; (iii) SEA/SH; and (iv) COVID 19. i) As per the World Bank Environmental and Social Incident Response Toolkit (ESIRT 2023), FAO notify the World Bank within 48 hours of any incident or accident related to the Project which has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers, including, inter alia, cases of sexual exploitation and abuse (SEA) and sexual harassment (SH),and accidents that result in death, serious or multiple injury including injuries or fatalities to project workers that could result from armed conflict. Provide sufficient detail regarding the scope, severity, and possible causes of the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and/or supervising firm, as appropriate. Subsequently, at the Bank’s request, prepare a report on the incident or accident and propose any measures to address it and prevent its recurrence. A detailed report of the incident or accident shall be provided within thirty (30) days of making the initial report of the incident or accident. ii) SEA/SH: More than 95% of the contracted workers is expected to be men, and women’s participation as contract labor or community labor is going to be very low. Contractors will need to maintain harmonious relations with local communities by ensuring that workers adhere to the Code of conduct (CoC). The CoC commits all persons engaged by the contractor, including sub-contractors and suppliers, to acceptable standards of behavior. The CoC will include sanctions for non-compliance, including non- compliance with specific policies related to gender-based violence, sexual exploitation and abuse, and sexual harassment (e.g., termination). The CoC will be written in plain language and signed by each worker to indicate that they have: • received a copy of the CoC as part of their contract • had the CoC explained to them as part of induction process • acknowledged that adherence to this CoC is a mandatory condition of employment 15 understood that violations of the CoC can result in serious consequences, up to and including dismissal, or referral to legal authorities. To mitigate potential risks related to on-site safety and GBV/SEA/SH, the Contractor/ Main contractor will undertake actions as given in the Table 4 below: Table 4. Actions to Mitigate Risks related to on-site safety and GBV/SEA/SH S. No. Action Timelines 1. Inform project workers about SEA/SH responsive GRM. Upon joining 2. Separate, safe, and easily accessible facilities for women Throughout construction period and men in the place of work and the labor camps. (e.g., toilets should be in separate areas, well-lit) 3. Display signs that SEA/SH is prohibited on the project Throughout construction period 4. Ensure Codes of Conduct are clearly understood and Upon joining signed by those with a physical presence at the project site; 5. Train project staff on the behavior obligations under the Periodic; every six months CoCs and Disseminate CoCs (including visual illustrations) and discuss with employees and local communities. iii) Occupational Health and Safety: FAO is committed to: • Complying with legislation and other applicable requirements which relate to occupational health and safety hazards. • Enabling active participation in OHS risks elimination through promotion of appropriate skills, knowledge, and attitudes towards hazards. • Continually improving the OHS management system and performance. • Availing this policy statement to all interested parties To avoid work related accidents and injuries, the contractor will: • identification of potential hazards to project workers, particularly those that may be life- threatening. • provision of preventive and protective measures, including modification, substitution, or elimination of hazardous conditions or substances. • training of project workers and maintenance of training records; (d) documentation and reporting of occupational accidents, diseases and incidents. • emergency prevention and preparedness and response arrangements to emergency situations; and • remedies for adverse impacts such as occupational injuries, deaths, disability, and disease Further to enforcing the compliance of environmental management, contractors will be responsible and liable for safety of site equipment, labor and daily workers attending to the construction site and safety of citizens for each work site, as mandatory measures. Health and Safety Incidents would be registered and follow up through the Health and Safety Incidents Tracker (Appendix 2) Reference may also be made to applicable international conventions, and directives for addressing health and safety issues relevant to COVID-19, such as: 16 • World Bank’s Interim Note: COVID-19 Considerations in Construction/Civil Works Projects; • World Health Organization (WHO) interim guidance on use of PPE for COVID-19 • ILO Occupational Safety and Health Convention, 1981 (No. 155) • ILO Occupational Health Services Convention, 1985 (No. 161) • ILO Safety and Health in Construction Convention, 1988 (No. 167) • WHO International Health Regulations, 2005 • WHO Emergency Response Framework, 2017 • European Union OSH Framework Directive (Directive 89/391) iv) COVID-19: • Request details in writing from the Contractors of the measures being taken to address the risks. Construction contract should include health and safety requirements; the measures may be presented as a contingency plan and reflected in revisions to the project’s health and safety manual- see relevant links below1). This should include Standard Operating Procedures (SOPs) that cover the following aspects: ✓ Conducting pre-employment and frequent health checks ✓ Controlling entry and exit from site/ workplace ✓ General hygiene ✓ Cleaning and waste disposal ✓ Adjusting work practices ✓ Reviewing accommodation arrangements, to see if they are adequate and designed to reduce contact with the community ✓ Reviewing contract durations, to reduce the frequency of workers entering/ exiting the site ✓ Rearranging work tasks or reducing numbers on the worksite to allow social/ physical distancing, or rotating workers through a 24-hour schedule ✓ Providing appropriate forms of personal protective equipment (PPE) ✓ Putting in place alternatives to direct contact, like tele-medicine appointments and live stream of instructions. ✓ Measures in respect of instances of spread of virus ✓ Training and communication with workers ✓ Communication and contact with community ✓ Reviewing accommodation arrangements for workers coming from outside, to ensure that they are adequate and designed to reduce contact with the community ✓ Minimize contact of migrant workers with people near the site. Wherever possible, ensure workers coming from outside are accommodated on site • Request the Contractor to convene regular meetings with the project LMP Focal Point and to take their advice in designing and implementing the agreed measures. • Identify a senior person as a focal point to deal with COVID-19 issues • Request for coordination arrangements, particularly at site where there are a number of contractors and therefore (in effect) different work forces (PIU could request the main contractor to put in place a protocol for regular meetings of the different contractors) 1For 17 workplace-related advice, consult WHO guidance getting your workplace ready for COVID-19; and for guidance on water, sanitation and health care waste relevant to viruses, including COVID-19, consult WHO interim guidance • Check with Contractors on whether the workers are informed/ encouraged to use the existing project grievance mechanism to report concerns relating to COVID-19 6. AGE OF EMPLOYMENT Afghanistan has ratified to a number of core international labor conventions including the prevention of Child Labor (Minimum Age Convention, 1973 (No. 138) and - Worst Forms of Child Labor Convention, 1999 (No. 182) on 07 April 2010. Under Afghan law, the minimum age of employment is 18. Minors between the ages of 15 and 17 may work under certain conditions, provided that the work is not arduous, hazardous requires less than 35 hours per week and constitutes a form of vocational training. Children aged 14 and under are prohibited from working2. The PIU will adhere to the Afghan Labor Law and its definition of the minimum age, which will be verified through the national Identity card/the disclosure statement of age at the time of recruitment. All Implementing Partners prohibit recruiting any person below the age of 18. Any breach of Afghan Labor Law will subject to the disciplinary measures specified by the law. Child Labor: Based on the local legislation, workers between 15-18 years could be hired for office work, vocational training with shortened working hours, during out-of-school time, and with guardian permission as per national legislation. The Labor age has been verified by checking their National Identity Cards. Awareness raising sessions would be conducted with selected NGOs and CSOs and third-party contractors. Relevant project staff (FAO staff) will be responsible for the overall assessment of child labor in the project. If anyone below the prescribed age limits as per national legislation is discovered working on the project, measures will be taken to immediately terminate the employment or engage with the worker in a responsible manner, considering the best interest of the worker. 7. TERMS AND CONDITIONS i. The Direct Workers are governed by their employment agreements with their employer as well as the LMP ii. Contractors will also be required to comply with all applicable legal provisions The contractor shall be required to certify in writing that the wages, hour and conditions of work or persons to be employed by them on the contract are not less favorable than those contained in the latest laws. Where a contractor fails to comply with this requirement, the contract with the contractor may be 18 2 Article Thirteen: Labour Law 2007 (1) A person who meets the following qualifications can be recruited as worker: Holds the Afghan citizenship. Completes the age of 18 years. Workers doing light types of work should complete age of 15 and those trying to learn a profession should complete the age of 14. withdrawn. In ensuring full compliance with the law in this regard, contractors will be required to furnish with copies of any licenses requires and/ or copies of contract of all its workforce. As a monitoring mechanism, a contractor shall not be entitled to any payment unless he has confirmed that all employment conditions of the contract are being complied with. 8. TRAINING AND SENSITIZATION Training for workers shall include health promotion, hazards associated with their work (base on the OHS risk assessment), health risks involved or to which they are exposed to, preventive measures to eliminate or minimize risks, steps to be taken in case of emergency, and safety instructions for the jobs, activities, and tasks to be handled by workers; SEA-SH/GBV risks, policies, CoC. • All personnel engaged in any kind of hazardous works shall undergo specialized instructions and training on the said activities • All workers, including new hires, shall be provided training and information for all types of hazards in the workplace in a language and dialect that they can understand. Training and information materials used shall be made readily available and accessible to workers. • A re-orientation on safety and health for workers must be conducted regularly, not less than once a quarter, and to be conducted immediately following any changes in the operations and production process. • Appropriate training and certification specialised agencies shall be a requirement for operators before use of equipment, if applicable. • Employees shall participate in the OHS information and education program, trainings, and other related initiatives of the agency to contribute to the improvement and sustainability of the same. • Issuance of PPE shall be supplemented by training on the application, use, handling, cleaning, and maintenance of said PPE. • SEA/SH: All employees and workers shall attend awareness trainings on gender diversity, internal procedures regarding workplace sexual harassment, Code of Conduct, guidelines to prevent and punish harassment, and availability of SEA/SH responsive GRM, if applicable. 9. Workers’ Grievance Redress Mechanism The objective of this procedure is to settle the grievance between an employer and employee or between employees bilaterally before the intervention of a formal court, except in cases where the grievance constitutes a criminal offense that requires notifying law enforcement. Under the provisions of ESS2, the project will provide a grievance redress mechanism (GRM) for all workers to raise workplace concerns. Workers will be informed of this grievance mechanism at the time of recruitment and the measures put in place to protect them from any reprisal for its use. The project will put in place measures to make the worker grievance mechanism easily accessible to all project workers. 9.1. UN Staff The UN staff GRM procedure follows the FAO Manual section and the FAO policies. 1. FAO staff are informed of staff rules and regulation through the accessible FAO Manual while engaging with FAO 2. In case of violation, FAO Staff must capture and present the details of the grievance to the person they report to or the supervisor’s superior in case of conflict of interest 3. The supervisor will verify the details and seek to address the matter within the shortest time 19 4. The supervisor will escalate the matter if not resolved within 48 hours to the Country FAO Representative. 5. If not resolved at country level, the matter should be escalated through the appropriate channel to the HQ Office of Inspector General (OIG)3, which mandate is to provide oversight of the programmes and operations of the Organization, through internal audit, investigation and inspection. 6. If no resolution is found within FAO, the employee can escalate the matter to the jurisdiction cited in her/his contract, mostly the Jurisdiction of the ILO Administrative Tribunal (ILOAT) extends to allegations by staff members of non-observance of their terms and conditions of appointment, including all pertinent regulations and rules (section 332.2 of the FAO Manual). 7. PMU will include these grievances within the regular progress reports to the World Bank. Specific grievances (GBV-SEA, fraud and corruption) • All grievances of sexual nature (GBV/sexual harassment/Sexual Exploitation and Abuse) should only and directly be submitted to OIG who will investigate. • All misconduct, fraud or corruption, event should be reported to OIG and any relative retaliation would be as well investigate by the OIG according to the whistle-blower policy. 9.2. Implementing Partners Workers Implementation partner workers GRM procedure is defined as follows. 1. FAO contract only contractors with registered code of conduct or who sign an undertaking to comply with the provisions of the Labour Act for contracted workers and contractors who will comply with community meetings resolutions on applicable rules in the case of community workers. 2. Contractors induct the employees on the applicable Implementing Partners (IPs) workers’ grievance redress mechanism and make them aware of their rights. All records of induction shall be kept and made available for inspection by FAO or The World Bank. 3. In case of violation, the aggrieved employee must capture and present the details of the grievance to the person they report to or the supervisor’s superior in case of conflict of interest. 4. The supervisor will verify the details and seek to address the matter within the shortest time (up to 48 hours) and defined if complaint has regard with national law or with ESF standard. 5. The supervisor will escalate the matter if not resolved within 48 hours. 6.Where the formal courts are accessible and functional, when the complaint has regards with national law and when no resolution is found, the employee can escalate the matter to the sector specific institutions or courts who will resolve the matter between employer and employee. EFSP - AF will finance an independent legal third party to objectively decide if the court is accessible and functional according to each case and follow the process and insure both right from employee and contractors. 7. Legal Third Party will report to PMU on all decisions. 8. FAO through its Office of the Inspector General (OIG) inspection officer might engage sanction toward contractors according to the Vendor Sanction Policy. 9. Where the formal courts are not accessible, do not exist in an area, or cannot render a judgment, or if the complaint is based on the World Bank ESF standards but not the national law, the matter shall be reported to and handled under the PMU, through the Project Grievance Redress Mechanism (GRM). The PMU, in this case, will accommodate a fair agreement between the worker and the contractor. 10. The contractor shall keep records of all proceedings of grievance redress that are within their jurisdiction and provide all details as part of the periodic progress reports to FAO. 3 http://www.fao.org/aud/ 20 11. In case of risk of retribution, the employee may immediately escalate to the court system or to the PMU as noted under. If confidentiality is requested, the PMU will ensure it to avoid any risk of retribution, including in its follow-up actions. Specific grievances (GBV-SEA / SH) All grievances of sexual nature (GBV/sexual harassment/Sexual Exploitation and Abuse) should follow the GBV/SEA/SH Action Plan referral pathways and complaints resolution mechanism. The reporting process of incidents (or grievance redress mechanism) regarding GBV/SEA/SH related misconducts or prohibited practices involves in-country Focal Point on the matter, the Head of Office, the Ethics Officer based at the Headquarters and the OIG. This procedure is intended for all GBV/SEA/SH related matters involving FAO project personnel, including implementing partners and contractors. If any of the standards and policies are revised during the lifetime of the project, the latest versions will be respected. FAO should report allegation of SEA/SH through the UN� s SEA iTracker and inform the Bank within 48 hours of having opened an investigation into a SEA/SH case. For GBV-GRM and reporting, the incidence response guidance on SEA/SH will be followed. For ease of reference, specific guidance on considerations for GMs receiving SEA/SH complaints is included in the Interim Technical Note: Grievance Mechanisms for SEA/SH in World Bank-financed Projects. Guidance on effective response and reporting of cases to management is set out in Chapter 5 of the Civil Works GPN. Figure 2: EFSP GBV-SEA GRM Mechanism Some immediate actions to be taken at country level - Assess immediate needs of survivor/complainant and activate the referral pathways for needed services. - Inform the FAOR/PSEA Focal Point (if not the one receiving the complaint) about the situation so action can be taken. - Ensure that all records of communications regarding the complaint are secured and respecting confidentiality Figurerules. 2: EFSP GBV-SEA GRM Mechanism - Forward the case to the Ethics Officer as soon as possible. 21 9.3. Community workers Community workers shall apply to the Project GRM. All grievances of sexual nature (GBV/sexual harassment/Sexual Exploitation and Abuse) should follow the EFSP GBV/SEA/SH Action Plan referral pathways and complaints resolution mechanism. The community workers should be aware of the issues that will be addressed by the project GRM and the GBV/SEA/SH Action Plan referral pathways and complaints resolution mechanism, where the later should be investigated by a trained and particular set of committees. 9.4. FAO staff sanctions and appeals4 ➢ Legal framework. This section considers all staff members of the Organization, including field personnel, temporary conference staff, and other short-term personnel. FAO staff respect the Standard of Conduct for the International Civil Service (FAO Administrative Manuel Section 304), comply with the provisions of Administrative Circular N°2019/01 “Policy on prevention of sexual harassment�, administrative Circular N02015/08 “Policy against fraud and other corrupt practices� and Administrative Circular 2013/27 ‘Protection from Sexual exploitation and sexual abuse�. Nothing herein shall limit the right of FAO to refer any alleged breach of the foregoing standards of conduct to the relevant national authorities for appropriate legal action. The project workers will also comply with the World Bank legal framework related to sexual harassment, exploitation and abuse as well as fraud and other corrupt practices. ➢ Disciplinary measures from FAO. Non respect should be led according to the FAO Manual section 330 Disciplinary Measures that foresees a series of proportionate measure: (i) written censure, (ii) suspension without pay, (iii) demolition; (iv) dismissal for misconduct; (v) dismissal for serious misconduct. Informal actions and non-disciplinary measures are taken by the direct superior, while formal measures are strictly submitted by the HR director through confidential memorandum. The disciplinary measures will also be consistent with those foreseen in the World Bank relevant procedures. ➢ FAO and ILOAT appeals. Formal Appeal procedure might be done according to the FAO Manual section 331. Appeals may be addressed to (i) the FAO Director General; (ii) Appeal Committee. In any case, the final decision is taken by the Director General after consideration of the Appeal Committee’s report. An appellant who is not satisfied with that final decision may lodge a complaint with the International Labour Office Administrative Tribunal (ILOAT) which refers to the legal counsel of the FAO. ➢ Waiver of FAO staff immunity. While FAO staff members benefit from an immunity of legal process of every kind in the performance of their official functions, these privileges and immunities are granted to the experts in the interests of the Organization and not for the personal benefit of the individuals themselves. Therefore, the Organization shall have the right and the duty to waive the immunity of any expert in any cases where, in its opinion, the immunity would impede the course of justice, and it can be waived without prejudice to the interests of the Organization. A Legal Third Party would in this case be considering applying national justice. 10. CONTRACTOR MANAGEMENT i) Contractual Provisions for Labour Management and OHS 4 22 and IOAT appeal and 125 Appendix 1 for waiver FAO Manual Sections 330 for Disciplinary measures, 331 for FAO immunity The environmental, social risks and impacts including labour management and OHS issues arising from implementation of this project have been identified and will be managed through implementation of ESMP through the contractors. The labour management and OHS of workers and related issues arising during construction works will be under direct control of contractors and will be managed by contractors. Therefore, ensuring effective management of OHS plan for contract workers by contractor(s) is core to implementation of the project. The ESHS (Environment, Social, Health and Safety) requirements would be specified and incorporated as special conditions and performance requirements in all agreements with the implementing partners. They can refer to the Matrix for all potential risks associated with health and safety issues in the project, the equipment and budget that will be needed to be costed in the contractor’s contract Appendix 4. ii) Monitoring of Performance of Contractors FAO will ensure that contractors monitor, keep records and report on terms and conditions related to labor management including accidents and incidents The contractor must provide workers with evidence of all payments made regardless of the worker being engaged on a fixed term contract, full-time, part-time, or temporarily, as per the terms of contract. The application of this requirement will be proportionate to the activities and to the size of the contract. • Labor conditions including forced labor: records of workers engaged under the Project, including contracts, registry of induction of workers including CoC, hours worked, remuneration and deductions (including overtime), collective bargaining agreements. • Safety: recordable incidents and corresponding Root Cause Analysis (lost time incidents, medical treatment cases), first aid cases, high potential near misses, and remedial and preventive activities required (for example, revised job safety analysis, new or different equipment, skills training, and so forth). • Workers: number of workers, indication of origin (local and migrant), gender, age with evidence that no child labor is involved, and skill level (unskilled, skilled, supervisory, professional, management). Forced labor. • Training/ induction: dates, number of trainees, and topics. • Details of any security risks: details of risks the contractor may be exposed to while performing its work. • Worker grievances: details including occurrence date, grievance, and date submitted; actions taken and dates; resolution (if any) and date; and follow-up yet to be taken; grievances listed should include those received since the preceding report and those that were unresolved at the time of that report. The following procedures are to be adhered for contractor management, but have been adjusted to adhere to LMP provisions: • Ensure that Contractors have valid contracts with clearly defined service level agreement in accordance with all environmental and social clauses, as applicable • Contractor induction to ESF and LMP • Quarterly submission of records including, managing incidents and accidents and Contractor employees recorded • Monthly site visits (at a minimum) and quarterly reports 23 • Concerns or issues tracking using monitoring register • Evaluation of contractor requirements - This includes training, OH&S files, certifications and other. Additionally, as part of Contractor management, the contract provision might need to include: • Provision of medical insurance covering treatment for COVID-19, sick pay for workers who either contract the virus or are required to self-isolate due to close contact with infected workers and payment in the event of death • Appointing a COVID-19 focal point with responsibility for monitoring and reporting on COVID-19 issues, and liaising with other relevant parties The Employment, Health, and Safety conditions Monitoring Form (Checklist) in Appendix 3 can be used by contractors. 11. Responsible Staff The Project will set up and maintain a PMU with qualified staff and resources to support the management of ESHS risks and impacts on the Project. The PMU will include a dedicated environmental specialist, one social specialist, and one community health and safety specialist. The table below outlines responsibility of E&S staff: Activity Responsible staff/party Engagement and management of project workers FAO and implementing NGOs Implementation of Occupational Health Safety FAO and implementing NGOs (OHS) Plan, Monitoring, supervising, and reporting on health FAO and implementing NGOs and safety Engagement and management of FAO and implementing NGOs CDC/contractors/subcontractors, including coordination and reporting arrangements between contractors Training of workers, including raising awareness FAO and implementing NGOs and training of workers in mitigating the spread of COVID-19 Assessment, training of workers on risk and FAO and implementing NGOs measure about COVID-19 Addressing worker grievances FAO and implementing NGOs 24 Appendixes Appendix 1: individual code of conduct in case of contractor Implementing Environmental, Social Health and Safety (ESHS) and Occupational Health and Safety (OHS) Standards Preventing Gender Based Violence (GBV) I, ______________________________, acknowledge that adhering to environmental, social health and safety (ESHS) standards, following the project’s occupational health and safety (OHS) requirements, and preventing gender-based violence (GBV) is important. All forms of GBV/SEA/SH are unacceptable, be it on the work site, the work site surroundings, at worker’s camps, or the surrounding communities. The company considers that failure to follow ESHS and OHS standards, or to partake in GBV/SEA/SH activities, constitute acts of gross misconduct and are therefore grounds for sanctions, penalties or potential termination of employment. Prosecution of those who commit GBV/SEA/SH may be pursued if appropriate. No children under 18 would be considered as project workers. Nevertheless, precaution toward children under 18 in contact with project workers are presented below. I agree that while working on the project I will: • Attend and actively partake in training courses related to Environmental and Social Occupational Health and Safety (ESOHS), SEA/SH. • Shall wear my personal protective equipment (PPE), in the correct prescribed manner, at all times when at the work site or engaged in project related activities. • Take all practical steps to implement the contractor’s ESMP and OHS Plan. • Adhere to a zero-alcohol policy during work activities, and refrain from the use of illegal substances always. • Consent to a police background check. • Treat women, children (persons under the age of 18), and men with respect regardless of race, color, language, religion, political or other opinion, national, ethnic, or social origin, property, disability, birth, or other status. • Not use language or behavior towards women, children or men that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate. • Not participate in sexual contact or activity with children—including grooming or contact through digital media. Mistaken belief regarding the age of a child is not a defense. Consent from the child is also not a defense or excuse. • Not engage in sexual harassment—for instance, making unwelcome sexual advances, requests for sexual favors, and other verbal or physical conduct, of a sexual nature, including subtle acts of such behavior. Ex. Looking somebody up and down; kissing, howling or smacking sounds; hanging around somebody; whistling and catcalls; giving personal gifts; making comments about somebody’s sex life; etc. • Not engage in sexual favors—for instance, making promises or favorable treatment dependent on sexual acts—or other forms of humiliating, degrading or exploitative behavior. • Unless there is the full consent1 by all parties involved, I shall not have sexual interactions with members of the surrounding communities. This includes relationships involving the withholding or promise of actual provision of benefit (monetary or non-monetary) to community members in exchange for sex—such sexual activity is considered “nonconsensual� within the scope of this Code. 25 • Consider reporting through the GRM (Grievance Redress Mechanism) or to my manager any suspected or actual GBV or VAC by a fellow worker, whether employed by my employer or not, or any breaches of this Code of Conduct. • With regard to children under the age of 18 in contact with project workers: • Wherever possible, ensure that another adult is present when working in the proximity of children. • Not invite unaccompanied children unrelated to my family into my home unless they are at immediate risk of injury or in physical danger. • Not sleep close to unsupervised children unless necessary, in which case I must obtain my supervisor's permission, and ensure that another adult is present if possible. • Use any computers, mobile phones, or video and digital cameras appropriately, and never to exploit or harass children or to access child pornography through any medium (see also “Use of children's images for work related purposes� below). • Refrain from physical punishment or discipline of children. • Refrain from hiring children for domestic or other labor, which is inappropriate given their age or developmental stage, which interferes with their time available for education and recreational activities, or which places them at significant risk of injury. • Comply with all relevant local legislation, including labor laws in relation to child labor. Use of children's images for work related purposes when photographing or filming a child for work related purposes, I must: • Before photographing or filming a child, assess and endeavor to comply with local traditions or restrictions for reproducing personal images. • Before photographing or filming a child, obtain informed consent from the child and a parent or guardian of the child. As part of this I must explain how the photograph or film shall be used. • Ensure photographs, films, videos and DVDs present children in a dignified and respectful manner and not in a vulnerable or submissive manner. Children should be adequately clothed and not in poses that could be seen as sexually suggestive. • Ensure images are honest representations of the context and the facts. • Ensure file labels do not reveal identifying information about a child when sending images electronically Sanctions I understand that if I breach this Individual Code of Conduct, my employer shall take disciplinary action which could include: • Informal warning and additional Training. • Formal warning. • Loss of up to one week’s salary. • Suspension of employment (without payment of salary), for a minimum period of 1 month up to a maximum of 6 months. • Termination of employment. • Report to the police if necessary. I understand that it is my responsibility to ensure that the environmental, social, health and safety standards are met. That I shall adhere to the occupational health and safety management plan. That I shall avoid actions or behaviors that could be construed as GBV or VAC. Any such actions shall be a breach this Individual Code of Conduct. I do hereby acknowledge that I have read the foregoing Individual Code of Conduct, do agree to comply with the standards contained therein and understand my roles and responsibilities to prevent and respond to ESHS, OHS, GBV and VAC issues. I understand that any action inconsistent with this Individual Code of Conduct or failure to act mandated by this Individual Code of Conduct may result in disciplinary action and may affect my ongoing employment. 26 Signature: _________________________ Printed Name: _________________________ Title: _________________________ Date: _________________________ Appendix 2: Environment, social, health and safety incident tracker Safety incident tracker Class of incidents Class 1 (Indicative) Class 2 (Serious) Class 3 (Severe) • No injuries • minor injury with short term • GBV/SEA/SH related incident • Relatively minor and small-scale impairment without revealing the identify of localized incident that • Failure to remedy Indicative those involved. negatively impacts a small non-compliance that may • Any fatality geographical areas or small potentially cause significant • Incidents that caused or may number of people impacts cause great harm to the • Does not result in significant or • May result in some level of environment, workers, irreparable harm lasting damage or injury communities, or natural or • Grievances due to project use of • Cases of mistreatment of cultural resources public roads communities potentially, • May result in high levels of • Minor instances of including vulnerable groups, by lasting damage or injury inappropriate behaviour of project workers, including • Requires an urgent and Contractor personnel incidents such as sexual immediate response. harassment • Abuses of community members • GRM not functioning (including vulnerable groups e.g., women, children, youth, elderly, disabled/sick) by project workers, including but not limited to GBV • Human trafficking and child labour Reference Class of Brief Cause of Date Action Due Responsible Progress Status number incident description the to be date incident taken INC001 Open INC002 Closed 27 Appendix 3: Employment, Health and Safety conditions Monitoring Form (Checklist) Contractor’s name: ……………………… Site name:……………. Date: ……………. Instructions: Tick (√) if available, put a cross(X) if unavailable. Tick (√) if there’s evidence, put a cross(X) if there’s no evidence. N0 Monthly Checklist: EHS items Available Unavailable Type of Comment evidence 1 Current Employee List 2 Valid Working Contract 3 Appointment letters 4 Inductions - all contractor staff 5 Reporting: Incident’s accidents tracker/register. 6 Grievance redress mechanism 7 Health and Safety Committee Sanitary facilities: toilets (separate for men and women), hand washing facilities, waste collection points. 9 PPE (boots, gloves, helmets, masks, etc.): Branded & Properly worn at all times, 10 Awareness on prevention of GBV/SEA/SH and communicable diseases and worker CoC. 11 Valid First Aid Kit 12 Valid Fire extinguishers 13 The incident register 28 Appendix 4: Matrix for Potential Risks Mitigation Potential OHS impacts Mitigation measures PLANNING AND PRE-CONSTRUCTION PHASE Lack of GRM for workers to - Establish a functional GRM for worker and for each raise workplace issues, implementing entities and subcontractor entities The siting of rehabilitation, if - Site selection for the various infrastructure will be undertaken not carefully planned and by FAO in consultation with the main stakeholders (CDCs, agreed upon with Irrigation Associations, women groups, farmers etc.) stakeholders will lead to - All sites will be screened for their environmental and social underutilization of the suitability prior to their approval infrastructure and high - GRM will be functional and accessible rehabilitation cost when completed. Sites may also be close to environmentally sensitive areas Lack of a selection criteria for - A selection criterion shall be prepared for Seed Producers for the selection of private Seed the Bank’s approval Producers can lead to - The selection criteria shall include social and environmental complaints of unfairness and criteria favoritism as well as the - Environment and Social Due Diligence will be undertaken to selection of firms with poor ensure that Seed Companies conform to the WB and FAO environmental and social requirements ESSs performance records Poorly designed irrigation - All facilities will be designed and supervised by competent schemes can lead to professionals e.g., Architects and Engineers together with excessive water losses and/or agronomists using the approved Building Code. waterlogging - All design drawings for the proposed irrigation schemes, rain Structural failure due to poor harvesting and soil conservation infrastructure to be design and supervision of rehabilitated will be vetted and approved by the appropriate irrigation systems. professional - Construction materials will be approved by FAO - Based on technical assessment the canals will be lined with concrete, stone masonry, mass concrete, and in some case PVC pipes will be considered - In case earthen canals are to be rehabilitated, they will be lined with clay material to minimize seepage - Gates and other installations that regulate the water flow within the irrigation system will be installed as part of the rehabilitation and extension of the irrigation schemes - Develop waste management plan for various specific waste General waste that may exist streams before or generated during - Prohibit burning of waste the site installation - Maintain all construction sites in a cleaner, tidy, and safe condition - Provide and maintain appropriate facilities as temporary 29 storage of all wastes before transportation and final disposal. Dust emissions or and health - Notify the workers before starting the demolishing work or hazard during the excavation excavation works, works, dismantling works or - water spraying on the bear surface or dust pollution source site clearance - Proper health and safety measures for the workers such as using of appropriate PPE (helmet, Earplug, musk, safety shoes, hand gloves etc.) should be taken to avoid any accidents; Removal of vegetation or tree - workers should be sensitized about the nature of the works and cutting in the project sites precautionary measures to be taken may expose workers to - construct noise barrier around the dismantling site; stop the accident risk, noise level engine when it is not required; monitor noise level as per increase and vibration effects existing guidelines Removal of utilities such as - Prevent accidents and injury to health by minimizing hazards in electrical cables may expose the working environment workers to injury or killing by - Contractor will cut only trees if have been agreed electric shock (electrocution) - with the district local authorities and the environmental Exposure to faulty electrical - officer devices, such as circuit - A vegetation restoration plan will be implemented breakers Eye hazards due to solid - Use of machine guards or splash shields and/or face and eye particles from a wide variety protection devices, such as safety glasses with side shields, of preliminary construction goggles, and/or a full-face shield operations CONSTRUCTION PHASE Risk of non-compliance with - Comply with the measures recommended by the sub- project performance standards Environmental and Social Management Plan (ESMP). Limited workers access to - Employers must provide welfare facilities and a working workplace facilities. environment that's healthy and safe for everyone in the workplace, including those with disabilities. Damage to the health and - To make workers aware of the risks of accidents linked to the safety of workers and the non-observance of safety instructions and their activities. population - Ensure, where possible, social distancing to reduce risk of disease transmission (particularly for COVID-19) - Equip the construction site basements with a first-aid unit equipped with necessities. - To sensitize the staff, workers, and the population on the risks of contamination by sexually transmitted infections (STIs) and HIV- AIDS. - Provide proper sanitation and waste disposal facilities based on a site-specific Waste Management Plan (WMP) - Carry out training/awareness campaigns for the prevention of communicable diseases - Empty/drain all areas that may hold standing water - Raise awareness among the population and drivers of lorries and machinery about the risks of accidents when driving through built-up areas. 30 - Develop and implement a contingency plan for each sub- project - Ensure implementing partners and contractors are included in security risk mitigation measures under the Security Management Plan Security risks for local staff - Code of conduct, behavior commitments, clear and accessible disciplinary process, and grievance process. - Regular training requirements on security Discrimination and - Establish criteria for fair competition for hiring, marginalization of certain - Respect the provisions of the Labor Code groups in employment Air quality can be affected by - Fit vehicles with appropriate exhaust systems and emission vehicle exhaust emissions and control devices combustion of fuels or by - Maintain vehicles and construction equipment in good working emissions from construction condition including regular servicing and make the truck drivers machineries, causing air aware of it pollution, respiratory and - Covering loads of powdery materials with tarpaulins- Operate other diseases the vehicles in a fuel-efficient manner Dust generation from earth - Impose speed limits at 30 km/hour on vehicle movement at the excavation, earth & sand worksite to reduce dust emissions stockpiles during dry period - water spraying on the bear surface or dust pollution source Work-related accidents - Proper health and safety measures for the workers such as using of appropriate PPE (helmet, mask, safety shoes, hand gloves etc.) should be taken to avoid any accidents - Focus special attention on containing the emissions from generators - Construction equipment causing excess pollution (e.g., visible smoke) will be banned from construction sites immediately prior to usage - Water spray to the dry earth/ material stockpiles, increase the watering frequency during periods of high risk (e.g., high winds) - Stored materials such as: excavated earth, dredged soil, gravel, and sand shall be covered and confined to avoid their wind drifted. - The Air quality monitoring should be carried out by the contractor following the National Air Quality Standard Vibration and noise quality - Strict measures for noise pollution control need to be will be deteriorated due to undertaken during construction activities. vehicular traffic, blasting and - Create noise barrier and consider the minimum noise levels at construction equipment sensitive receptor sites - Stone breaking machine should be confined within a temporary shed so that noise pollution could be kept minimum - Protection devices (ear plugs or earmuffs) and masks shall be provided to the workers operating in the vicinity of high noise generating machines during construction - Construction equipment and vehicles shall be fitted with silencers and maintained properly. - Instruction to the drivers to avoid unnecessary horning. - The Noise level monitoring should be carried out by the 31 contractor following the national noise quality standards - Board Vibration monitoring should be carried out by the contractor. Lack of proper infrastructure - Train all construction workers in basic sanitation and health care facilities, such as water issues and safety matters and on the specific hazards of their supply and sanitation facilities work may expose workers to - The contractor will provide movable toilets for both men and hygiene-related diseases or women lack of potable water - The contractor will provide drinking water meeting the national -Accidental spillage of standards hazardous liquid from the - pH and coliforms contents should meet standards for drinking construction camps water - The water quality monitoring should be carried out by the contractor following the national water quality standards - Regular health check-up of the workers - Handling and storage of the potential contaminants has to be organized under strict condition to avoid water pollution during construction - Handling of hazardous liquid should be done carefully by the designated experienced person Inappropriate handling or - workers to be mindful of the occupational exposures that accidental - could arise from working environment spillage/leakage of these - workers on construction sites should receive special health and substances can potentially safety training specific to remediation activities lead to safety and health - Handling and storage of the potential contaminants has to be hazards for the construction organized under strict condition to avoid water pollution during workers construction - Handling of hazardous liquid should be done carefully by the designated experienced person - The ground water quality monitoring should be carried out by the contractor following the National Water Quality Standard Road Traffic and Accidents - Proper Traffic Management Plan (TMP) should be prepared by the contractor during starting of construction and follow it strictly. - - In this TMP, the road safety measures such as speed breakers, - warning signs/lights, road safety signs, flagman etc. should be prepared and implemented - Avoid total blockage of traffic by providing temporary diversions if necessary. Solid, liquid and hazardous - Appropriate mitigation and protective measures are to be Wastes (paint, fuel, included in the ESMP chemicals, oil, petroleum - Sensibilization of community workers on solid, liquid and products, bitumen etc. may hazardous waste avoidance and mitigation harm the health of - Hazard communication and training programs to prepare construction workers) - workers to recognize and respond to workplace chemical generation hazards - Waste management and pollution control plan - Minimize the production of waste materials by 3R (Reduce, 32 Recycle and Reuse) approach - Prohibit burning of solid waste - Ensure proper collection and disposal of solid wastes within the construction camps - Insist waste separation by source; organic wastes in one container and inorganic wastes in another container at sources - Dispose organic wastes in a designated safe place on daily basis - The organic wastes should be always covered with a thin layer of sand so that flies, mosquitoes, dogs, cats, rats, etc. are not attracted - Train the relevant construction personnel in handling of fuels and spill control procedures - Training workers on the correct transfer and handling of fuels and chemicals and the response to spills GBV/SEA/SH (sexual - ESMP should identify risks of labor influx and propose general harassment of women and mitigation measures girls, exploitative sexual - Application of the Codes of Conduct on Sexual Exploitation and relations, sex work, etc.) Abuse (SEA) provided in the ESMF-AF - Establish a mechanism for reporting and resolving cases of sexual exploitation, abuse and harassment and ensure that beneficiaries are aware of it. - Ensuring codes of conduct or behavioral standards are put in place. Expected behavior for zero-tolerance of SEA/SH should be clear along with communication on consequences. - Develop and implement a national level GBV Action Plan with an accountability and Response Framework - Training and awareness on unacceptable conduct toward female workers - -informing workers about national labor law that makes sexual harassment and gender-based violence a punishable offence which is prosecuted - Introduce a worker code of conduct as part of the employment contract including sanctions - contractors to adopt a policy to cooperate with law enforcement agencies in investigating complaints about GBV - Ensure that women are given equal employment opportunities during recruitment and job postings. Increased risk of work crews - Provide HIV awareness programming, including STI (sexually spreading transmitted infections) and HIV information, education and communicable/sexually communication for all workers on regular basis; transmitted infections (i.e., - Train workers on health and safety, on communicable diseases COVID-19 and HIV/ AIDS). - Regular health check-up of the workers and awareness training Lack of first aid facilities and - about the communicable diseases health care facilities in the - Educating project personnel, and area residents on risks, immediate vicinity will prevention, and available treatment for vector-borne diseases aggravate the health - Provide the workers a safe and healthy work environment conditions of the workers. - Provide health care facilities and first aid facilities readily available. 33 Exploitation of workers - Ensure that all workers have contracts with terms and conditions that are consistent with national labor laws and policies as well as ESS2 - Every worker should be trained on as well as sign a Code of Conduct Child and forced labour - Ensure no children are employed on site in accordance with national labor laws and ESS2 - All workers should be able to demonstrate their age by use of national identity cards or other official documentation - Inform communities and stakeholders that the use of child labor/ students (including for community contributions) is not permitted on the project - All workers must have an employment contract, be paid for their work and have the right to resign if they wish Pollution of water - No garbage or refuse, waste oils should be discharged into drains or onto site grounds - Fuel storage tanks or sites should be properly secured to contain any spillage - Toilet facilities should be provided for construction workers to avoid indiscriminate defecation in nearby bush or local water bodies Loss of vegetation cover - When rehabilitating/constructing site access roads, tree felling should be limited to areas strictly necessary for the widening of roads and machinery movement. - Avoid spillover of quarry trucks and construction equipment onto the surrounding fields by marking the right-of-way and access roads to the borrow sites and sensitizing truck and equipment drivers in this respect. - Redistribute the wood from the clearing of rights-of- way to the populations of the villages concerned. - Carry out compensatory reforestation in the project area (1 ha of reforestation per ha of developed perimeter in the commune). - Offsetting losses of cash crops and trees with economic value Modification of soil structure - Avoid overflowing the routes of quarry trucks and construction machinery on the surrounding fields by marking out the right-of- way and access roads to the borrow sites and make truck and machinery drivers aware of this. Loss of arable land - Proceed with the rehabilitation of borrow material sites as soon as the project is completed. - On each site, carry out several pumping tests in the water tables Poor siting of boreholes present and only retain the borehole (s) with sufficient flow rates that can always meet the water requirements of the project. Reduction of grazing areas - Carry out compensatory reforestation in the project area (1 ha of nationally reforestation per ha of perimeter developed in the municipality) Unintentional destruction of - Stop the work and put in place devices to secure the remains archaeological remains discovered and inform the competent authorities of the appropriate measures to be taken. 34 Sanitary wastewater - Adequate portable sanitation facilities serving all workers should discharges be provided at all construction sites. Sanitary wastewater in construction sites should be properly managed Disturbance, destruction of - Mark out the work rights-of-way and avoid any unnecessary wildlife habitat and poaching overflow, especially when opening new access roads to the sites. - Prohibit raiding and poaching practices by staff and workers - Screen out proposed site in protected areas or sites of natural/cultural importance within the broader region or landscape - Limit clearing of trees or grass to the construction site. Operation Phase Risk of non-compliance with - Comply with the measures recommended by the sub- project performance standards ESMP. - Conducting E&S Trainings - Third Party Monitoring of noncompliance and corrective measures Child employment, Forced - Sensitize parents on the prohibition of child labor labor - Use Project Labor Management Procedures Soil Salinization - Periodically monitor salt concentration levels in irrigation water - Ensure that drainage systems are in good condition and working order. - Soil leaching (remediation) after harvesting Disruption of ecosystem - Ensure effective implementation of the FAO Guidance services Document for Pest and Pesticide Management in Field Projects (annex 8) - Use only registered pesticides - Use non-chemical fertilizers - Raise awareness among project beneficiaries about the risks of soil, air, and water pollution due to the massive and - uncontrolled use of agrochemicals Pollution and degradation of - Lagoon drainage water before it is released into the wild. surface and groundwater quality - Establish, on each site, a periodic maintenance system for water collection and distribution installations and equipment Lack of effective water - Replace, as soon as possible, defective, damaged, or dilapidated management mechanisms installations and equipment - Locally train, among the beneficiaries of the project, young technicians capable of urgently carrying out certain small jobs such as closing a valve and replacing a broken pipe letting water flow, etc. - Train and raise awareness among farmers on the optimal use of agrochemicals (nitrogen fertilizers) and on the harmful effects of phytosanitary treatments. - Sensitize the plant protection brigadiers on the wearing of Impacts on the health of protective equipment (nasal masks) when applying pesticides. populations - Inform and sensitize project beneficiaries on water- related 35 diseases (malaria, typhoid fever, amoebic dysentery, etc.) - Include the project site villages in the intervention program of the epidemiological surveillance system. Proliferation of invasive - Incorporate IPM approaches plants and pests - Regular weeding of the fields. - Cut and pull-out unwanted seedlings - Apply FAO’s E&S Management Guidelines Use chemical or biological control in consultation with the specialized services - Training of farmers on IPM and correct techniques of agrochemical application, particularly where they cannot be avoided) - Apply rotational and intercropping practices to preserve greater diversity in habitat to reduce possible impact of pest and diseases - Install, outside the irrigated perimeters, water points intended Lack of water points for for the watering of the livestock of local herders and nomadic watering livestock herders during their seasonal transhumance Unintentional destruction of - Stop the work and put in place devices to secure the remains archaeological remains discovered and inform the competent authorities of the appropriate measures to be taken. Incidence of Gender Based - Implement the measures recommended in the project’s Sexual Violence/Sexual Exploitation Exploitation, Abuse, and Sexual Harassment (SEA/SH) Action Abuse and Sexual Harassment Plan - Contractual Clauses on mandatory and regular training for workers on required lawful conduct and legal consequences for failure to comply with laws on non-discrimination and GBV will be inserted in Contract Documents. - Contractual Clauses with a commitment to cooperate with law enforcement agencies investigating cases of gender-based violence shall be inserted into the Contract documents of the contractor and Supervising Consultant - The Contractor shall be required to consider alternative work schedules or shifts to accommodate the hiring of more female workers. - Contractual clauses against rape, defilement and other Gender based Violence as well as child and forced Labor shall be inserted into the contract of the Contractor and Supervising Consultant in adherence to national laws - Workers on site will sign Codes of Conduct on Sexual Exploitation and Abuse (SEA) provided in annex 15 for Sample Code of Conduct) with sanctions on rape defilement, abuse and other gender-based violence - Sensitization workshops shall be undertaken for employees of the Contractor/Supervising Consultant and Sub-Contractors as well as persons working or living in the immediate project environs - The Contractor shall provide contact numbers of the nearest law enforcement Agency Office, gender specialist and gender 36 focal points under the project, Project level GRM channels/numbers, the Grievance Redress Committee Members to offices, schools, and clinics within the project zone. 37 Annex 5 Managing COVID-19 risks on construction sites The issues set out below include a number that represent expected good workplace management but are especially pertinent in preparing the EMSF response to COVID-19 in annex 12 Managing COVID-19 risks on construction sites ASSESSING WORKFORCE CHARACTERISTICS Many construction sites will have a mix of workers e.g. workers from the local communities and workers from a different part of the country. Workers will be employed under different terms and conditions and be accommodated in different ways. Assessing these different aspects of the workforce will help in identifying appropriate mitigation measures: • The Contractor should prepare a detailed profile of the project work force, key work activities, schedule for carrying out such activities, different durations of contract and rotations (e.g. 4 weeks on, 4 weeks off). • This should include a breakdown of workers who reside at home (i.e. workers from the community), workers who lodge within the local community and workers in on-site accommodation. Where possible, it should also identify workers that may be more at risk from COVID-19, those with underlying health issues or who may be otherwise at risk. • Consideration should be given to ways in which to minimize movement in and out of site. This could include lengthening the term of existing contracts, to avoid workers returning home to affected areas, or returning to site from affected areas. • Workers accommodated on site should be required to minimize contact with people near the site, and in certain cases be prohibited from leaving the site for the duration of their contract, so that contact with local communities is avoided. • Consideration should be given to requiring workers lodging in the local community to move to site accommodation (subject to availability) where they would be subject to the same restrictions. • Workers from local communities, who return home daily, weekly or monthly, will be more difficult to manage. They should be subject to health checks at entry to the site (as set out above) and at some point, circumstances may make it necessary to require them to either use accommodation on site or not to come to work. ENTRY/EXIT TO THE WORK SITE AND CHECKS ON COMMENCEMENT OF WORK Entry/exit to the work site should be controlled and documented for both workers and other parties, including support staff and suppliers. Possible measures may include: • Establishing a system for controlling entry/exit to the site, securing the boundaries of the site, and establishing designating entry/exit points (if they do not already exist). Entry/exit to the site should be documented. • Training security staff on the (enhanced) system that has been put in place for securing the site and controlling entry and exit, the behaviors required of them in enforcing such system and any COVID - 19 specific considerations. • Training staff who will be monitoring entry to the site, providing them with the resources they need to document entry of workers, conducting temperature checks and recording details of any worker that is denied entry. 38 • Confirming that workers are fit for work before they enter the site or start work. While procedures should already be in place for this, special attention should be paid to workers with underlying health issues or who may be otherwise at risk. Consideration should be given to demobilization of staff with underlying health issues. • Checking and recording temperatures of workers and other people entering the site or requiring self- reporting prior to or on entering the site. • Providing daily briefings to workers prior to commencing work, focusing on COVID-19 specific considerations including cough etiquette, hand hygiene and distancing measures, using demonstrations and participatory methods. • During the daily briefings, reminding workers to self-monitor for possible symptoms (fever, cough) and to report to their supervisor or the COVID-19 focal point if they have symptoms or are feeling unwell. • Preventing a worker from an affected area or who has been in contact with an infected person from returning to the site for 14 days or (if that is not possible) isolating such worker for 14 days. • Preventing a sick worker from entering the site, referring them to local health facilities if necessary or requiring them to isolate at home for 14 days. GENERAL HYGIENE Requirements on general hygiene should be communicated and monitored, to include: • Training workers and staff on site on the signs and symptoms of COVID-19, how it is spread, how to protect themselves (including regular handwashing and social distancing) and what to do if they or other people have symptoms (for further information see WHO COVID-19 advice for the public). • Placing posters and signs around the site, with images and text in local languages. • Ensuring handwashing facilities supplied with soap, disposable paper towels and closed waste bins exist at key places throughout site, including at entrances/exits to work areas; where there is a toilet, canteen or food distribution, or provision of drinking water; in worker accommodation; at waste stations; at stores; and in common spaces. Where handwashing facilities do not exist or are not adequate, arrangements should be made to set them up. Alcohol based sanitizer (if available, 60- 95% alcohol) can also be used. • Review worker accommodations, and assess them in light of the requirements set out in IFC/EBRD guidance on Workers’ Accommodation: processes and standards, which provides valuable guidance as to good practice for accommodation. • Setting aside part of worker accommodation for precautionary self-quarantine as well as more formal isolation of staff who may be infected (see paragraph (f)). CLEANING AND WASTE DISPOSAL Conduct regular and thorough cleaning of all site facilities, including offices, accommodation, canteens, common spaces. Review cleaning protocols for key construction equipment (particularly if it is being operated by different workers). This should include: • Providing cleaning staff with adequate cleaning equipment, materials and disinfectant. 39 • Review general cleaning systems, training cleaning staff on appropriate cleaning procedures and appropriate frequency in high use or high-risk areas. • Where it is anticipated that cleaners will be required to clean areas that have been or are suspected to have been contaminated with COVID-19, providing them with appropriate PPE: gowns or aprons, gloves, eye protection (masks, goggles or face screens) and boots or closed work shoes. If appropriate PPE is not available, cleaners should be provided with best available alternatives. • Training cleaners in proper hygiene (including handwashing) prior to, during and after conducting cleaning activities; how to safely use PPE (where required); in waste control (including for used PPE and cleaning materials). • Any medical waste produced during the care of ill workers should be collected safely in designated containers or bags and treated and disposed of following relevant requirements (e.g., national, WHO). If open burning and incineration of medical wastes is necessary, this should be for as limited a duration as possible. Waste should be reduced and segregated, so that only the smallest amount of waste is incinerated (for further information see WHO interim guidance on water, sanitation and waste management for COVID-19). ADJUSTING WORK PRACTICES Consider changes to work processes and timings to reduce or minimize contact between workers, recognizing that this is likely to impact the project schedule. Such measures could include: • Decreasing the size of work teams. • Limiting the number of workers on site at any one time. • Changing to a 24-hour work rotation. • Adapting or redesigning work processes for specific work activities and tasks to enable social distancing, and training workers on these processes. • Continuing with the usual safety trainings, adding COVID-19 specific considerations. Training should include proper use of normal PPE. While as of the date of this note, general advice is that construction workers do not require COVID-19 specific PPE, this should be kept under review (for further information see WHO interim guidance on rational use of personal protective equipment (PPE) for COVID-19). • Reviewing work methods to reduce use of construction PPE, in case supplies become scarce or the PPE is needed for medical workers or cleaners. This could include, e.g. trying to reduce the need for dust masks by checking that water sprinkling systems are in good working order and are maintained or reducing the speed limit for haul trucks. • Arranging (where possible) for work breaks to be taken in outdoor areas within the site. • Consider changing canteen layouts and phasing meal times to allow for social distancing and phasing access to and/or temporarily restricting access to leisure facilities that may exist on site, including gyms. • At some point, it may be necessary to review the overall project schedule, to assess the extent to which it needs to be adjusted (or work stopped completely) to reflect prudent work practices, potential exposure of both workers and the community and availability of supplies. PROJECT MEDICAL SERVICES 40 Consider whether existing project medical services are adequate, taking into account existing infrastructure (size of clinic/medical post, number of beds, isolation facilities), medical staff, equipment and supplies, procedures and training. Where these are not adequate, consider upgrading services where possible, including: • Expanding medical infrastructure and preparing areas where patients can be isolated. Guidance on setting up isolation facilities is set out in WHO interim guidance on considerations for quarantine of individuals in the context of containment for COVID-19). Isolation facilities should be located away from worker accommodation and ongoing work activities. Where possible, workers should be provided with a single well-ventilated room (open windows and door). Where this is not possible, isolation facilities should allow at least 1 meter between workers in the same room, separating workers with curtains, if possible. Sick workers should limit their movements, avoiding common areas and facilities and not be allowed visitors until they have been clear of symptoms for 14 days. If they need to use common areas and facilities (e.g. kitchens or canteens), they should only do so when unaffected workers are not present and the area/facilities should be cleaned prior to and after such use. • Training medical staff, which should include current WHO advice on COVID-19 and recommendations on the specifics of COVID-19. Where COVID-19 infection is suspected, medical providers on site should follow WHO interim guidance on infection prevention and control during health care when novel coronavirus (nCoV) infection is suspected. • Training medical staff in testing, if testing is available. • Assessing the current stock of equipment, supplies and medicines on site, and obtaining additional stock, where required and possible. This could include medical PPE, such as gowns, aprons, medical masks, gloves, and eye protection. Refer to WHO guidance as to what is advised (for further information see WHO interim guidance on rational use of personal protective equipment (PPE) for COVID-19). • If PPE items are unavailable due to world-wide shortages, medical staff on the project should agree on alternatives and try to procure them. Alternatives that may commonly be found on constructions sites include dust masks, construction gloves and eye goggles. While these items are not recommended, they should be used as a last resort if no medical PPE is available. • Ventilators will not normally be available on work sites, and in any event, intubation should only be conducted by experienced medical staff. If a worker is extremely ill and unable to breathe properly on his or her own, they should be referred immediately to the local hospital (see (g) below). • Review existing methods for dealing with medical waste, including systems for storage and disposal (for further information see WHO interim guidance on water, sanitation and waste management for COVID-19, and WHO guidance on safe management of wastes from health-care activities). LOCAL MEDICAL AND OTHER SERVICES Given the limited scope of project medical services, the project may need to refer sick workers to local medical services. Preparation for this includes: 41 • Obtaining information as to the resources and capacity of local medical services (e.g. number of beds, availability of trained staff and essential supplies). • Conducting preliminary discussions with specific medical facilities, to agree what should be done in the event of ill workers needing to be referred. • Considering ways in which the project may be able to support local medical services in preparing for members of the community becoming ill, recognizing that the elderly or those with pre-existing medical conditions require additional support to access appropriate treatment if they become ill. • Clarifying the way in which an ill worker will be transported to the medical facility, and checking availability of such transportation. • Establishing an agreed protocol for communications with local emergency/medical services. • Agreeing with the local medical services/specific medical facilities the scope of services to be provided, the procedure for in-take of patients and (where relevant) any costs or payments that may be involved. • A procedure should also be prepared so that project management knows what to do in the unfortunate event that a worker ill with COVID-19 dies. While normal project procedures will continue to apply, COVID-19 may raise other issues because of the infectious nature of the disease. The project should liaise with the relevant local authorities to coordinate what should be done, including any reporting or other requirements under national law. INSTANCES OR SPREAD OF THE VIRUS WHO provides detailed advice on what should be done to treat a person who becomes sick or displays symptoms that could be associated with the COVID-19 virus (for further information see WHO interim guidance on infection prevention and control during health care when novel coronavirus (nCoV) infection is suspected). The project should set out risk-based procedures to be followed, with differentiated approaches based on case severity (mild, moderate, severe, critical) and risk factors (such as age, hypertension, diabetes) (for further information see WHO interim guidance on operational considerations for case management of COVID-19 in health facility and community). These may include the following: • If a worker has symptoms of COVID-19 (e.g. fever, dry cough, fatigue) the worker should be removed immediately from work activities and isolated on site. • If testing is available on site, the worker should be tested on site. If a test is not available at site, the worker should be transported to the local health facilities to be tested (if testing is available). • If the test is positive for COVID-19 or no testing is available, the worker should continue to be isolated. This will either be at the work site or at home. If at home, the worker should be transported to their home in transportation provided by the project. • Extensive cleaning procedures with high-alcohol content disinfectant should be undertaken in the area where the worker was present, prior to any further work being undertaken in that area. Tools used by the worker should be cleaned using disinfectant and PPE disposed of. • Co-workers (i.e. workers with whom the sick worker was in close contact) should be required to stop work, and be required to quarantine themselves for 14 days, even if they have no symptoms. • Family and other close contacts of the worker should be required to quarantine themselves for 14 days, even if they have no symptoms. • If a case of COVID-19 is confirmed in a worker on the site, visitors should be restricted from entering the site and worker groups should be isolated from each other as much as possible. 42 • If workers live at home and has a family member who has a confirmed or suspected case of COVID- 19, the worker should quarantine themselves and not be allowed on the project site for 14 days, even if they have no symptoms. • Workers should continue to be paid throughout periods of illness, isolation or quarantine, or if they are required to stop work, in accordance with national law. • Medical care (whether on site or in a local hospital or clinic) required by a worker should be paid for by the employer. CONTINUITY OF SUPPLIES AND PROJECT ACTIVITIES Where COVID-19 occurs, either in the project site or the community, access to the project site may be restricted, and movement of supplies may be affected. • Identify back-up individuals, in case key people within the project management team (PIU, Supervising Engineer, Contractor, sub-contractors) become ill, and communicate who these are so that people are aware of the arrangements that have been put in place. • Document procedures, so that people know what they are, and are not reliant on one person’s knowledge. • Understand the supply chain for necessary supplies of energy, water, food, medical supplies and cleaning equipment, consider how it could be impacted, and what alternatives are available. Early pro-active review of international, regional and national supply chains, especially for those supplies that are critical for the project, is important (e.g. fuel, food, medical, cleaning and other essential supplies). Planning for a 1-2 month interruption of critical goods may be appropriate for projects in more remote areas. • Place orders for/procure critical supplies. If not available, consider alternatives (where feasible). • Consider existing security arrangements, and whether these will be adequate in the event of interruption to normal project operations. • Consider at what point it may become necessary for the project to significantly reduce activities or to stop work completely, and what should be done to prepare for this, and to re-start work when it becomes possible or feasible. TRAINING AND COMMUNICATION WITH WORKERS Workers need to be provided with regular opportunities to understand their situation, and how they can best protect themselves, their families and the community. They should be made aware of the procedures that have been put in place by the project, and their own responsibilities in implementing them. • It is important to be aware that in communities close to the site and amongst workers without access to project management, social media is likely to be a major source of information. This raises the importance of regular information and engagement with workers (e.g. through training, town halls, tool boxes) that emphasizes what management is doing to deal with the risks of COVID-19. Allaying fear is an important aspect of work force peace of mind and business continuity. Workers should be given an opportunity to ask questions, express their concerns, and make suggestions. 43 • Training of workers should be conducted regularly, as discussed in the sections above, providing workers with a clear understanding of how they are expected to behave and carry out their work duties. • Training should address issues of discrimination or prejudice if a worker becomes ill and provide an understanding of the trajectory of the virus, where workers return to work. • Training should cover all issues that would normally be required on the work site, including use of safety procedures, use of construction PPE, occupational health and safety issues, and code of conduct, taking into account that work practices may have been adjusted. • Communications should be clear, based on fact and designed to be easily understood by workers, for example by displaying posters on handwashing and social distancing, and what to do if a worker displays symptoms. COMMUNICATION AND CONTACT WITH THE COMMUNITY Relations with the community should be carefully managed, with a focus on measures that are being implemented to safeguard both workers and the community. The community may be concerned about the presence of non-local workers, or the risks posed to the community by local workers presence on the project site. The project should set out risk-based procedures to be followed , which may reflect WHO guidance (for further information see WHO Risk Communication and Community Engagement (RCCE) Action Plan Guidance COVID-19 Preparedness and Response). The following good practice should be considered: • Communications should be clear, regular, based on fact and designed to be easily understood by community members. • Communications should utilize available means. In most cases, face-to-face meetings with the community or community representatives will not be possible. Other forms of communication should be used; posters, pamphlets, radio, text message, electronic meetings. The means used should take into account the ability of different members of the community to access them, to make sure that communication reaches these groups. • The community should be made aware of procedures put in place at site to address issues related to COVID-19. This should include all measures being implemented to limit or prohibit contact between workers and the community. These need to be communicated clearly, as some measures will have financial implications for the community (e.g. if workers are paying for lodging or using local facilities). The community should be made aware of the procedure for entry/exit to the site, the training being given to workers and the procedure that will be followed by the project if a worker becomes sick. • If project representatives, contractors or workers are interacting with the community, they should practice social distancing and follow other COVID-19 guidance issued by relevant authorities, both national and international (e.g. WHO). 44