ESWATINI ELECTRICITY COMPANY (EEC) Eswatini Accelerating Sustainable and Clean Energy Access Transformation (Ascent) (P508960) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) Draft November 2024 1 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Kingdom of Eswatini (the Borrower) through Eswatini Electricity Company (EEC), is implementing the Eswatini Accelerating Sustainable and Clean Energy Access Transformation Project (P508960) (the Project), with the involvement of the Ministry of Natural Resources and Energy. The International Development Association (the Bank) has agreed to provide financing for the Project, as set out in Agreement. 2. The Borrower, through ECC) shall ensure that the Project is carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Bank. The ESCP is a part of the Agreement[s]. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the Agreement[s]. 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Borrower shall carry out or cause to be carried out, including, as applicable, their respective timeframes; institutional, staffing, training, monitoring and reporting arrangements; and grievance management. The ESCP also sets out the environmental and social (E&S) documents that shall be prepared or updated, consulted, disclosed and implemented under the Project, consistent with the ESSs, in form and substance acceptable to the Bank. Said E&S documents may be revised from time to time with prior written agreement by the Bank. As provided for under the referred Agreement[s], the Borrower shall ensure that there are sufficient funds available to cover the costs of implementing the ESCP. 4. As agreed by the Bank and the Borrower, this ESCP will be revised from time to time, if necessary, to reflect adaptive management of Project changes or unforeseen circumstances or in response to Project performance. In such circumstances, the Bank and the Borrower agree to update the ESCP to reflect these changes through an exchange of letters signed between the Bank and the Borrower specified in the Agreement[s]. The Borrower shall promptly disclose the updated ESCP. 5. The subsection on “Indicators for Implementation Readiness” below identifies the actions and measures to be monitored to assess Project readiness to begin implementation in accordance with this ESCP. Nevertheless, all actions and measures in this ESCP shall be implemented as set out in the “Timeframe” column below irrespective of whether they are listed in the referred subsection. 2 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY IMPLEMENTATION ARRANGEMENTS AND CAPACITY SUPPORT A ORGANIZATIONAL STRUCTURE Maintain the NRAP PIU with E&S EEC staff throughout Project Maintain the existing Network Reinforcement and Access Project (NRAP) PIU with qualified staff implementation. and resources to support management of environmental, social, health and safety (E&S) risks and impacts of the Project, including a health and safety specialist, an environmental specialist and a social specialist. B CAPACITY BUILDING PLAN/MEASURES Throughout the implementation of EEC Prepare and implement the following capacity building measures: the project. • training for Project workers and contractors on project related environmental, social and health and safety risks, and requirements, site safety requirements, hazard identification and risk assessment, incident investigation, road traffic safety including a driver training program, code of conduct, emergency preparedness and response and climate adaptation. MONITORING AND REPORTING C REGULAR REPORTING Submit quarterly reports to the EEC Bank throughout Project Prepare and submit to the Bank regular monitoring reports on the environmental, social, health and implementation. safety (ESHS) performance of the Project. The reports shall include: Submit each report to the Bank no ▪ Status of preparation/ updating and implementation of E&S documents required under the later than 5 working days after the ESCP. end of each reporting period. ▪ Summary of stakeholder engagement activities carried out as per the Stakeholder Engagement Plan. ▪ Complaints submitted to the grievance mechanism(s), the grievance log, and progress made in resolving them. ▪ ESHS performance of contractors and subcontractors as reported through monthly contractors’ and supervision firms’ reports. ▪ Findings on ESHS compliance inspections and audits including status of corrective actions relevant to contractor compliance with requirements in ESMP ▪ Number and status of resolution of incidents and accidents reported under action E below. D CONTRACTORS’ MONTHLY REPORTS Submit the monthly reports as EEC annexes to the reports to be submitted under action C above. 3 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY Require contractors and supervising firms to provide monthly monitoring reports on E&S performance in accordance with the metrics specified in the respective project E&S documents as stipulated in the bidding documents and contracts and submit such reports to the Bank. E INCIDENTS AND ACCIDENTS Notify the Bank no later than 48 EEC hours after learning of the incident Notify the Bank of any incident or accident relating to the project which has, or is likely to have, a or accident. Provide available significant adverse effect on the environment, the affected communities, the public or workers, details upon request. including those resulting in death or significant injury to workers or the public; project related road traffic incidents, acts of violence, discrimination or protest; unforeseen impacts to cultural heritage Provide review report and or biodiversity resources; pollution of the environment; forced or child labor; displacement without Corrective Action Plan to the Bank due process (forced eviction); allegations of sexual exploitation or abuse (SEA), or sexual no later than 10 days following the harassment (SH); or disease outbreaks. Provide available details of the incident or accident to the submission of the initial notice, Bank upon request. unless a different timeframe is agreed to in writing by the Bank. Arrange for an appropriate review of the incident or accident to establish its immediate, underlying and root causes. Prepare, agree with the Bank, and implement a Corrective Action Plan that sets out the measures and actions to be taken to address the incident or accident and prevent its recurrence. ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ENVIRONMENTAL AND SOCIAL ASSESSMENTS AND/OR PLANS EEC 1.Maintain,implement, review and update the EEC Environmental Management System (EMS) 1.For the duration of the project consistent with ISO 14001 and an OHS Management System (OHSMS) consistent with ISO 45001. implementation. 2. Update Project Operational Manual (POM) prepared under NRAP to include the screening of sub- 2. Update the POM within 6 project activities and E&S implementation arrangements in line with the requirements set out in the months of project approval and Environmental and Social Management Framework (ESMF) prepared and disclosed on January 5, thereafter implement throughout 2022, under the NRAP (P166170). Project implementation. 3. Update the ESMP prepared for the distribution network under NRAP and disclosed on January 5, 2022, to address the environmental, social and health and safety risks associated with the activities 3. Update ESMP prior to under this Project. commencing with preparation of the bidding documents and thereafter implement throughout Project implementation. 4 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 4. Develop and implement an Initial Environmental Evaluation and Comprehensive Mitigation Plan 4.Prior to commencing with and provide copies to the World Bank. preparation of bidding documents and thereafter implement throughout Project implementation. 5.Obtain and maintain an Environmental Compliance certificate or an Environmental Authorization 5. Prior to commencing with letter, as needed, and provide evidence to the World Bank. preparation of bidding documents 1.2 MANAGEMENT OF CONTRACTORS As part of the preparation of EEC Incorporate the relevant aspects of the ESCP, including, inter alia, ESMPs, the Labor Management procurement documents and Procedures, and code of conduct, into the E&S specifications of the procurement documents and respective contracts. contracts with contractors and supervising firms. Thereafter ensure that the contractors and Supervise contractors throughout supervising firms comply and that they require their subcontractors to comply with the E&S Project implementation. Copies of specifications of their respective contracts. Provide copies of the relevant contracts with relevant contracts provided to the contractors/subcontractors and supervision firms to the Bank. Bank upon request. 1.3 USE OF BORROWER ENVIRONMENTAL AND SOCIAL FRAMEWORK EEC 1.Partial use of Borrower Environmental and Social Framework 1.Throughout the Project Action: Ensure that the E&S risks and impact of the Project, are managed in accordance with this Implementation ESCP and the Borrower E&S Framework regards to implementation of the requirements set forth in the issuance of the Environmental Compliance certificate and authorization letter in addition to the existing E&S instruments prepared under NRAP (P166170). 2. Partial use of Borrower Labor Framework 2.Throughout the Project Action: Ensure that the labor management and working conditions of Project workers are consistent Implementation with this ESCP and with the Borrower labor framework, where consistent with ESS2 objectives. Where inconsistencies exist the requirements in the LMP prepared and disclosed on December 24, 2021, under NRAP (P166170) will apply. 3. Promptly notify the Bank of any changes to the Borrower’s E&S Framework that may materially 3. Notify the Bank immediately adversely affect the Borrower’s ability to manage the E&S risks and impacts of the Project in line after taking notice of the change to with the ESSs and the immediate measures taken or that are planned to be taken to address said the Borrower’s E&S Framework. changes and the ensuing potential risks and impacts of the Project. If, in the opinion of the Bank, Subsequent actions, if requested by such changes adversely affect relevant ESHS risk management aspects of the Project, the Borrower the Bank, shall reflected in an shall agree to implement measures and actions to address them in a manner acceptable to the updated ESCP as indicated in Bank. The ESCP shall be updated to reflect such agreed actions paragraph 4 of the Initial Section of this ESCP. 5 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES Update the LMP prior to EEC commencing with bidding process Update the Labor Management Procedures (LMP), disclosed on December 24, 2021, prepared and thereafter implement the LMP under the NRAP to address finding and recommendations provided in the Eswatini ESS2 overview throughout Project assessment commissioned by the World Bank and implement said LMP for the purposes of the implementation. Project. 2.2 OCCUPATIONAL HEALTH AND SAFETY MANAGEMENT PLAN 1.Update the OHS Management EEC 1.Update and implement the OHS Management Plan prepared for NRAP to assess and manage the Plan prior to commencing with the OHS risks and hazards under this Project, considering the General Environmental, Health and Safety bidding documents, and thereafter Guidelines (EHSGs), the industry-specific EHSGs and other Good International Industry Practice implement the plan throughout (GIIP), as relevant. Project implementation. 2.Require contractors and subcontractors to prepare and implement OHS Management Measures 2.Prior to commencing with civil in accordance with the Project OHS Management Plan prior to commencing with physical works. works. 2.3 GRIEVANCE MECHANISM FOR PROJECT WORKERS Maintain a grievance mechanism EEC prior engaging Project workers and Maintain and operate a grievance mechanism for Project workers established under the NRAP as operate it throughout Project described in the LMP and consistent with ESS2. implementation. ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 WASTE MANAGEMENT PLAN Update the WMP prior to EEC Update the Waste Management Procedure (WMP) prepared under NRAP to make provision for commencing with construction and electronic waste associate with solar, battery and electrical installations, to manage hazardous thereafter implement the WHDP wastes associated with this Project consistent with ESS3. throughout Project implementation. 3.2 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT Prior to commencing with the EEC Adopt the resource efficiency and pollution prevention and management measures in ESMP construction and thereafter prepared for the distribution network under NRAP for this Project consistent with ESS3. implement throughout the Project implementation. ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY As part of the contractors EEC Prepare procedures for vehicle safety inspections and implement a driver training program as measures to manage traffic and road safety incidents. 4.2 COMMUNITY HEALTH AND SAFETY Update and adopt the OCHSP prior EEC Review, update and adopt the Occupational and Community Health and Safety plan (OCHSP) to commencing with preparation of prepared under NRAP for this Project. the bidding document and thereafter implement throughout Project implementation. 6 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY 4.3 EMERGENCY PREPAREDNESS AND RESPONSE 1.Adopt and implement the EPRP EEC 1.Adopt the Emergency Preparedness and Response Plan (EPRP) prepared under NRAP. throughout Project implementation. 2.Require contractors to include emergency preparedness and response procedures as part of the 2.Prior to commencing with civil contractors OHS plans. works. 4.4 SEA AND SH RISKS Update the SEA/SH Action Plan EEC prior to commencement of civil As needed, update the SEA/SH Action Plan prepared under NRAP (P166170) and disclosed on works and thereafter implement January 2, 2022, and implement for the purpose of the Project. the SEA/SH Action Plan throughout Project implementation. ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 RESETTLEMENT PLANS Adopt and implement the EEC respective RAP, prior to: (i) taking Adopt and implement site-specific Resettlement Action Plan(s) (RAP), consistent with ESS5. possession of the land, and (ii) commencement of any civil works. ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES 6.1 BIODIVERSITY RISKS AND IMPACTS Update ESMP and thereafter EEC implement throughout Project If required, adopt or update mitigation measures to minimize impacts on biodiversity as part of the implementation. ESMP prepared and disclosed on January 5, 2022, under NRAP, for this Project, consistent with ESS6. ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES N/A ESS 8: CULTURAL HERITAGE 8.2 CHANCE FINDS Adopt and implement the EEC Adopt and implement the chance find procedure prepared under NRAP and disclosed as part of the procedures throughout Project ESMF on January 5, 2022, as part of this Project. implementation. ESS 9: FINANCIAL INTERMEDIARIES N/A ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 10.1 STAKEHOLDER ENGAGEMENT PLAN Update the SEP by Appraisal and EEC thereafter implement the SEP As needed, update the Stakeholder Engagement Plan prepared under NRAP and disclosed April 30, throughout Project 2019, and implement it for the purposes of the Project, consistent with ESS10, which shall include implementation. measures to, inter alia, provide stakeholders with timely, relevant, understandable and accessible 7 MATERIAL MEASURES AND ACTIONS TIMEFRAME RESPONSIBLE ENTITY information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. 10.2 PROJECT GRIEVANCE MECHANISM Maintain the grievance mechanism EEC Publicize, maintain, and operate an accessible grievance mechanism, to receive and facilitate established under NRAP and resolution of concerns and grievances in relation to the Project, promptly and effectively, in a operate said mechanism transparent manner that is culturally appropriate and readily accessible to all Project-affected throughout Project parties, at no cost and without retribution, including concerns and grievances filed anonymously, in implementation. a manner consistent with ESS10. The grievance mechanism shall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. INDICATORS FOR IMPLEMENTATION READINESS The following actions are indicators for implementation readiness: ▪ Update Project Operational Manual prepared under NRAP to include the screening of sub-project activities and implementation arrangements for E&S in line with the requirements set out in the Environmental and Social Management Framework prepared and disclosed on January 5, 2022, under the NRAP. ▪ Update and implement the ESMP prepared for the distribution network under NRAP and disclosed on January 5, 2022. ▪ Develop and implement an Initial Environmental Evaluation and Comprehensive Mitigation Plan and provide copies to the World Bank. ▪ Obtain and maintain an Environmental Compliance certificate and provide evidence to the World Bank. ▪ Update the Labor Management Procedures, disclosed on December 24, 2021, prepared under the NRAP. ▪ Update the Stakeholder Engagement Plan prepared under NRAP and disclosed April 30, 2019. ▪ Implement site-specific resettlement action plan(s) for activities. 8