Document of The World Bank FOR OFFICIAL USE ONLY Report No: PAD3536 INTERNATIONAL DEVELOPMENT ASSOCIATION PROJECT PAPER ON A PROPOSED ADDITIONAL GRANT IN THE AMOUNT OF SDR 13.1 MILLION (US$18 MILLION EQUIVALENT) TO THE UNION OF COMOROS FOR THE ADDITIONAL FINANCING FOR THE SOCIAL SAFETY NET PROJECT December 5, 2019 Social Protection and Jobs Global Practice Africa Region This document has a restricted distribution and may be used by recipients only in the performance of their official duties. Its contents may not otherwise be disclosed without World Bank authorization. CURRENCY EQUIVALENTS Exchange Rate Effective October 31, 2019 Currency Unit = Comorian Franc (KMF) US$1.00 = KMF 441.0289108 US$1.00 = SDR 0.72495813 GOUVERNMENT FISCAL YEAR January 1 – December 31 Regional Vice President: Hafez M. H. Ghanem Country Director: Mark Lundell Regional Director: Dena Ringold Practice Manager: Robert Chase Task Team Leaders: Julia Rachel Ravelosoa, Andrea Vermehren ABBREVIATIONS AND ACRONYMS AF Additional Financing ANACEP Agence Nationale de Conception et d’Exécution des Projets (National Agency for Design and Implementation of Projects) CDD Community-driven Development CERC Contingent Emergency Response Component COMPASS Comprehensive Approach to Health Systems Strengthening CPF Country Partnership Framework CPKRRP Comoros Post-Kenneth Recovery and Resilience Project CRW Crisis Response Window DA Designated Account DGSC Direction Générale de la Sécurité Civile (Directorate General for Civil Security) DoSSP Directorate of Solidarity and Social Protection DP Development Partner DRM Disaster Risk Management ESMF Environmental and Social Management Framework ESMP Environmental and Social Management Plan FM Financial Management GBV Gender-based Violence GDP Gross Development Product GoC Government of Comoros GRM Grievance Redress Mechanism GRS Grievance Redress Service IFR Interim Financial Report INSEED National Institute of Statistics, Economic, and Demographic Studies IPF Investment Project Financing IRR Internal Rate of Return ISR Implementation Status and Results Report KMF Comorian franc M&E Monitoring and Evaluation MFI Microfinance Institution MIS Management Information System MoHSSP Ministry of Health, Solidarity, Social Protection and Gender Promotion NGO Nongovernmental Organization NPV Net Present Value PDO Project Development Objective PEFA Public Expenditure and Financial Accountability PFM Public Financial Management PIU Project Implementation Unit RPF Resettlement Policy Framework SDR Special Drawing Rights SEA Sexual Exploitation and Abuse SSN Social Safety Net SSNP Social Safety Net Project TA Technical Assistance ToR Terms of Reference UNICEF United Nations Children's Fund Union of Comoros Additional Financing for the Social Safety Net Project TABLE OF CONTENTS I. BACKGROUND AND RATIONALE FOR ADDITIONAL FINANCING ........................................ 7 A. Introduction...................................................................................................................... 7 B. Country Context ............................................................................................................... 8 C. Performance of Original Project ...................................................................................... 9 D. Rationale for Additional Financing ................................................................................. 11 II. DESCRIPTION OF ADDITIONAL FINANCING .................................................................... 16 A. Summary of Changes...................................................................................................... 16 B. Changes to Components and Costs................................................................................ 17 C. Other Changes ................................................................................................................ 24 D. Gender ............................................................................................................................ 25 E. Climate Change .............................................................................................................. 25 F. Monitoring and Evaluation............................................................................................. 26 III. KEY RISKS ..................................................................................................................... 26 IV. APPRAISAL SUMMARY .................................................................................................. 28 V. WORLD BANK GRIEVANCE REDRESS .............................................................................. 36 VI SUMMARY TABLE OF CHANGES ..................................................................................... 37 VII DETAILED CHANGE(S) .................................................................................................... 37 VIII. RESULTS FRAMEWORK AND MONITORING ................................................................... 42 ANNEX 1: IMPLEMENTATION ARRANGEMENTS AND SUPPORT PLAN ................................... 51 ANNEX 2: FINANCIAL MANAGEMENT ASSESSMENT REPORT ................................................ 53 ANNEX 3: IMPACT OF CYCLONE KENNETH ............................................................................ 59 The World Bank Additional Financign for the Social Safety Net Project (P171633) BASIC INFORMATION – PARENT (Comoros Social Safety Net Project - P150754) Country Product Line Team Leader(s) Comoros IBRD/IDA Julia Rachel Ravelosoa Project ID Financing Instrument Resp CC Req CC Practice Area (Lead) P150754 Investment Project HAFS1 (9340) AFCS2 (5547) Social Protection & Jobs Financing Implementing Agency: ANACEP ADD_FIN_TBL1 Is this a regionally tagged project? Bank/IFC Collaboration No Expected Original Environmental Approval Date Closing Date Guarantee Current EA Category Assessment Category Expiration Date 19-Mar-2015 31-Dec-2019 Partial Assessment (B) Partial Assessment (B) Financing & Implementation Modalities Parent [ ] Multiphase Programmatic Approach [MPA] [ ] Contingent Emergency Response Component (CERC) [ ] Series of Projects (SOP) [ ] Fragile State(s) [ ] Disbursement-Linked Indicators (DLIs) [✓] Small State(s) [ ] Financial Intermediaries (FI) [✓] Fragile within a Non-fragile Country [ ] Project-Based Guarantee [ ] Conflict [ ] Deferred Drawdown [✓] Responding to Natural or Man-made disaster [ ] Alternate Procurement Arrangements (APA) Page 1 of 59 The World Bank Additional Financign for the Social Safety Net Project (P171633) Development Objective(s) The Project Development Objective is to increase poor communities’ access to safety net and nutrition services. Ratings (from Parent ISR) RATING_DRAFT_ NO Implementation Latest ISR 12-Jun-2017 30-Jun-2017 21-Dec-2017 25-Jun-2018 11-Feb-2019 19-Sep-2019 Progress towards achievement of S MU MS MS MS S PDO Overall Implementation S MS MS MS MS S Progress (IP) Overall Safeguards MU MS MS MS S Rating Overall Risk S S S S S S BASIC INFORMATION – ADDITIONAL FINANCING (ADDITIONAL FINANCING FOR THE SOCIAL SAFETY NET PROJECT - P171633) ADDFIN_TABLE Urgent Need or Capacity Project ID Project Name Additional Financing Type Constraints P171633 ADDITIONAL FINANCING Restructuring, Scale Up Yes FOR THE SOCIAL SAFETY NET PROJECT Financing instrument Product line Approval Date Investment Project IBRD/IDA 18-Dec-2019 Financing Projected Date of Full Bank/IFC Collaboration Disbursement 30-Apr-2023 No Is this a regionally tagged project? Page 2 of 59 The World Bank Additional Financign for the Social Safety Net Project (P171633) No Financing & Implementation Modalities Child [ ] Series of Projects (SOP) [✓] Fragile State(s) [ ] Disbursement-Linked Indicators (DLIs) [✓] Small State(s) [ ] Financial Intermediaries (FI) [ ] Fragile within a Non-fragile Country [ ] Project-Based Guarantee [ ] Conflict [ ] Deferred Drawdown [✓] Responding to Natural or Man-made disaster [ ] Alternate Procurement Arrangements (APA) [✓] Contingent Emergency Response Component (CERC) Disbursement Summary (from Parent ISR) Net Source of Funds Total Disbursed Remaining Balance Disbursed Commitments IBRD % IDA 6.00 5.82 0.06 99 % Grants % PROJECT FINANCING DATA – ADDITIONAL FINANCING (ADDITIONAL FINANCING FOR THE SOCIAL SAFETY NET PROJECT - P171633) PROJECT FINANCING DATA (US$, Millions) SUMMARY -NewFi n1 SUMMARY (Total Financing) Proposed Additional Total Proposed Current Financing Financing Financing Total Project Cost 6.00 18.00 24.00 Total Financing 6.00 18.00 24.00 of which IBRD/IDA 6.00 18.00 24.00 Financing Gap 0.00 0.00 0.00 Page 3 of 59 The World Bank Additional Financign for the Social Safety Net Project (P171633) DETAILS - Additional Financing NewFinEnh1 World Bank Group Financing International Development Association (IDA) 18.00 IDA Grant 18.00 IDA Resources (in US$, Millions) Credit Amount Grant Amount Guarantee Amount Total Amount Comoros 0.00 18.00 0.00 18.00 Crisis Response Window 0.00 18.00 0.00 18.00 (CRW) Total 0.00 18.00 0.00 18.00 COMPLIANCE Policy Does the project depart from the CPF in content or in other significant respects? [ ] Yes [ ✔ ] No Does the project require any other Policy waiver(s)? [ ] Yes [ ✔ ] No INSTITUTIONAL DATA Practice Area (Lead) Social Protection & Jobs Contributing Practice Areas Climate Change and Disaster Screening This operation has been screened for short and long-term climate change and disaster risks Page 4 of 59 The World Bank Additional Financign for the Social Safety Net Project (P171633) Gender Tag Does the project plan to undertake any of the following? a. Analysis to identify Project-relevant gaps between males and females, especially in light of country gaps identified through SCD and CPF Yes b. Specific action(s) to address the gender gaps identified in (a) and/or to improve women or men's empowerment Yes c. Include Indicators in results framework to monitor outcomes from actions identified in (b) Yes PROJECT TEAM Bank Staff Name Role Specialization Unit Team Leader (ADM Senior Social Protection Julia Rachel Ravelosoa HAFS1 Responsible) Economist Lead Social Protection Andrea Vermehren Team Leader HAFS1 Specialist Sylvain Auguste Procurement Specialist (ADM Procurement Specialist EA1RU Rambeloson Responsible) Maharavo Harimandimby Financial Management Financial Management EA1G2 Ramarotahiantsoa Specialist (ADM Responsible) Specialist Andrianjaka Rado Social Specialist (ADM Social Development Specialist SAFS1 Razafimandimby Responsible) Environmental Specialist (ADM Erik Reed Environmental Specialist SAFE3 Responsible) Aissatou Diallo Team Member Finance Officer WFACS Emre Ozaltin Team Member Program Leader HAFD1 Faly Diallo Team Member Finance Officer WFACS Hajalalaina Consuella Rabearivony Team Member Primary Program Assistant HAFS2 Andrianjakanava Hasina Tantelinirina Social Specialist Social Development Specialist SAFS1 Ramarson Ep Rafalimanana Ines Melissa Emma Attoua Team Member Finance Officer WFACS Etty Page 5 of 59 The World Bank Additional Financign for the Social Safety Net Project (P171633) Khurshid Banu Noorwalla Team Member Operations Analyst HAFS3 Margaux Laurence Vinez Team Member Young Professional HAFS1 Marouan Maalouf Counsel Legal LEGAM Sheila Braka Musiime Team Member Legal LEGAM Siv Elin Tokle Team Member Operations Officer HSPJB Todimalala Volasoa Team Member Team Assistant AFMMG Razafiarimbola Extended Team Name Title Organization Location Page 6 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) I. BACKGROUND AND RATIONALE FOR ADDITIONAL FINANCING A. Introduction 1. This project paper seeks the approval of the Executive Directors of the World Bank Group to provide a first Additional Financing (AF) for the Social Safety Net Project (P150754 - the ‘Project’ or ‘SSNP’) in the form of an additional IDA Grant in the amount of SDR 13.1 million (US$18 million equivalent) to the Union of Comoros. The parent project, Social Safety Net Project (P150754), is financed through an IDA Grant (IDA-D0320) in the amount of SDR 4.2 million (US$6 million equivalent), approved in March 2015 and effective in July 2015. The proposed AF scales up a disaster response subcomponent which includes a provision for recovery grants, cash for work and rehabilitation of community-based infrastructure. Cyclone Kenneth hit the Comoros on April 24–25, 2019, causing large human and physical losses. The Government swiftly requested a social protection response to address early recovery and rehabilitation needs of the most vulnerable population through the disaster response subcomponent of the SSNP. 2. The proposed AF would finance the costs associated with scaling up activities of the SSNP in cyclone-affected areas to respond to the population’s recovery needs. The proposed AF will finance (a) recovery grants and an integrated support package including livelihood support services and adult learning sessions (social empowerment and financial inclusion) to support the recovery of households, including the promotion of income-generating activities of poor households in disaster affected communities; (b) the rehabilitation of selected small community-based infrastructure damaged by the cyclone; and (c) project management, coordination, and monitoring and evaluation (M&E). 3. The Project Development Objective (PDO) will be slightly amended to reflect the rehabilitation of the community infrastructure. The PDO of the current SSNP is to ‘increase poor communities’ access to safety net and nutrition services’. To reflect the additional activities in response to the cyclone, particularly the rehabilitation of community infrastructure, the PDO will be amended to ‘increase poor communities’ access to safety net, nutrition, and community services’. Furthermore, the proposed scale- up of the project will also lead to increased targets in selected PDO- and intermediary indicators as described in Section VIII. Finally, the proposed AF will provide an opportunity for further consolidation of the social protection system and strengthen the existing capacity of the Government to support the poor and vulnerable on time, especially in the early recovery after an emergency. 4. The proposed AF is fully compliant with the World Bank Policy of Investment Project Financing (IPF) and the accompanying World Bank Directive. This a well-performing project. In the recent Implementation Status and Results Report (ISR, September 2019) ratings for implementation progress and development objectives consistently are rated moderately satisfactory or above over the last 12 months and the project showing full compliance with key loan covenants. There are no outstanding audits. 5. The AF is directly linked to the development priorities of the Government of Comoros (GoC). The proposed activities will also support the Government’s Cyclone Kenneth recovery plan and ‘’Stratégie de Croissance Accélérée et de Développement Durable’’ or Accelerated Growth and Sustainable Development Strategy (SCA2D, 2018) of the Comoros. The AF will contribute to promote human development and economic inclusion of the Comoros through the recovery grants that will support Page 7 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) families to rebuild their lives and enable access to health, nutrition, and education services. It will also support the supply side of human development through the rehabilitation of social infrastructure that will provide communities with better access to essential community services in the affected areas. Finally, the recovery grant will be complemented by livelihood support services which will increase technical and business skills among the poor and vulnerable and enhance their financial literacy. This AF complies with IDA18 priorities by focusing on the poorest and vulnerable areas for their inclusion and resilience and by improving women’s empowerment and gender equality through adult learning sessions. 6. The AF is fully aligned with the Country Partnership Framework (CPF) objectives for FY14–FY19 1. The project will contribute to support increased resilience (Pillar 1) by supporting the recovery of cyclone- affected households and promoting livelihood diversification, economic inclusion, and enhanced resilience at the household and community level. 7. Closing dates. This project paper proposes AF and a restructuring of the SSNP that includes the extension of the project by 36 months, until December 31, 2022, to complete all additional activities. Based on past disbursement capacity and expected effectiveness of the AF in mid-February 2020, the project is expected to be fully disbursed by the revised closing date. 8. Urgent need or capacity constraints. This AF has received approval to apply Condensed Procedures as allowed under Paragraph 12 of section III of World Bank Policy, IPF: Projects in Situations of Urgent Need of Assistance or Capacity Constraints. B. Country Context 9. Despite political uncertainty and governance challenges, the Comoros became a lower-middle- income country in July 2019. The Comoros is a small nation characterized by geographical isolation, limited domestic markets, and a high dependency on food imports and remittances. In addition, the Comoros has experienced recurrent political crises and conflicts between the islands after independence in 1974. Despite this, the Comoros has shown economic stability due, in large part, to remittances; economic growth has remained steady at 2.8 percent in 2018. However, a part of the population has not benefited from this situation, especially the poorest, who have no access to remittances. 10. The Comoros has shown progress in reducing poverty, but economic vulnerability remains significant. The latest report on consumption and poverty showed that between 2003 and 2014, the Comoros has made strides in reducing monetary poverty. Nearly 40 percent of the population was poor in 2004 and currently 25 percent of its estimated 760,000 population are living below the poverty line. However, economic vulnerability (chronically poor and non-poor with high probability of falling into poverty in the event of a shock) has stagnated and remains high; around 48 percent of households in 2003 and 45 percent in 2013.2 11. Despite the progress in poverty reduction, the human capital index for the Comoros remains low at 0.41. The Human Capital index score implies that a child born today in Comoros will achieve on average 21 percent of his/her potential by age 18. According to the last household survey, 2013–2014, 60 1 Report No. 82054-KM. 2 World Bank, 2018. Etude sur la vulnérabilité àla pauvreté des ménages aux Comores. Etude basée sur l’enquête 123. 2013/2014. Study on households’ vulnerability to poverty in Comoros. Study based on the survey 123. 2013/2014. Page 8 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) percent of Comorian households' consumption is spent on food, reflecting economic vulnerability, limiting investments in human and productive capital, and thereby sustaining the intergenerational transmission of poverty. Children’s outcomes are especially poor; the Comoros has a high rate of malnutrition—30 percent of the children are stunted, and while there has been progress in school enrollment, around 25 percent of children ages 6–17 are out of school due mainly to financial constraints. According to the Multiple Indicator Cluster Survey in 2012, only 12 percent of the population has access to safe drinking water and 37 percent to sanitation facilities. 12. In addition to economic vulnerability, the Comorian population is also vulnerable to natural disasters (hurricanes, volcanic eruptions, floods, and so on) which have become more frequent in recent years. Around 54 percent of the population and 59 percent of the land are highly exposed to natural disasters (cyclones, floods, and drought), all of which have shown an increase in intensity in recent years and are partially linked to climate change. Apart from bringing hardship to people during the event, the disasters are also affecting the national economy and the livelihoods and living conditions of the population: after each natural disaster’s occurrence, affected households suffer a loss of income by losing all or part of their crops and/or assets and a loss of human capital by disrupted education and restricted access to and provision of health and nutrition services. 13. Given this high level of vulnerability, the GoC has started to progressively establish the political, legal, and institutional foundations of a social safety net (SSN) system. The country created the Directorate of Solidarity and Social Protection (DoSSP) in the Ministry of Health, Solidarity, Social Protection and Gender Promotion (MoHSSP) to lead social protection activities in 2011 and adopted its first National Social Protection Policy in 2016. It lays out the country’s vision for a comprehensive and inclusive social protection system that ensures every citizen can permanently satisfy their basic needs. It involves improving access to basic social services and establishing SSNs for reaching the most vulnerable. While this institutional framework provides the basis for an SSN, it is not well coordinated. The DoSPP has recently launched the establishment of a simplified national registry in an effort to improve coordination. 14. Despite the progress, coverage of existing SSN programs is still insufficient to cover the needs. The country, with support from the World Bank and United Nations Children’s Fund (UNICEF), has begun to establish SSN programs for the vulnerable and poorest groups. Covering only 44 percent of the extreme poor, these SSN programs are not yet able to meet the needs of the country. Other existing initiatives are fragmented despite the Government’s coordination effort under the leadership of the DoSSP in the MoHSSP. Due to the limited capacity of the social protection system, the Comoros is not able to cope with economic and climatic hazards. This situation has especially affected the poorest and the most vulnerable households after Cyclone Kenneth hit the Comoros on April 24–25, 2019. C. Performance of Original Project 15. The ongoing SSNP (P150754) has completed all activities in a satisfactory way. The PDO of the current SSNP is to ‘increase poor communities’ access to safety net and nutrition services’ and has not changed throughout implementation. Approved in March 2015 and effective since July 2015, the SSNP is funded by a US$6 million IDA Grant which has been used to establish a Productive Safety Net Program based on cash-for-work activities combined with community-based nutrition activities in the poorest communities of the three Comorian islands. The project is currently implemented by the National Agency for Design and Implementation of Projects (Agence Nationale de Conception et Execution des Projets, Page 9 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) ANACEP) and has achieved or exceeded all targets of the PDO indicators. The project has been rated at or above moderately satisfactory in the last 12 months for progress toward achievement of the PDO. Overall implementation progress, procurement, and M&E have been rated at or above moderately satisfactory since the beginning of the project. Of the total budget of US$6 million, 99 percent has been disbursed and it is expected to be 100 percent disbursed by December 2019. 16. The project includes three components. • Component 1: Establishing a Productive and Disaster Responsive Safety Net o Subcomponent 1.1: Establishing a Productive Safety Net o Subcomponent 1.2: Ensuring an Early Recovery Response to Natural Disasters • Component 2: Improving the Nutrition of Young Children and Mothers from Poor Communities • Component 3: Strengthening Safety Net Management, Coordination, and Monitoring and Evaluation. 17. Component 1. Establishing a Productive and Disaster Responsive Safety Net. The aim of this component is to provide income support to poor households through two subcomponents (a) Subcomponent 1.1: Establishing a Productive Safety Net. The productive safety net program provided regular cash to 4,217 targeted poor families in exchange for their participation in productive cash-for-work activities in the poorest 69 villages of the Comoros over a three-year period. The gender and social impacts have been high, with 59 percent of cash transfer direct recipients being women. Over 685,000 person days of employment were created, through works in reforestation, water management, terracing, and so on. The subcomponent exceeded the target coverage PDO indicator of 4,000 beneficiary households and 60 poor communities getting access to safety net and nutrition services. Furthermore, six small community infrastructure subprojects were selected and implemented in consultation with communities. The infrastructures have been built to increase communities’ productive assets. (b) Subcomponent 1.2: Ensuring an Early Recovery Response to Natural Disasters. This subcomponent aimed to finance activities to support communities and households in the immediate aftermath of natural disasters. This subcomponent was designed to finance post- disaster cash transfers and the rehabilitation and reconstruction of small village infrastructure damaged by natural disasters. In the absence of a disaster during the first two years of the project period and following the request of the GoC, the budget of this subcomponent was reallocated in 2019 to Component 2 to enhance nutrition services. 18. Component 2: Improving the Nutrition of Young Children and Mothers from poor Communities. Complementary to the safety net activities, this component has provided preventive nutrition services in the same 69 villages where the productive safety net activities were implemented. It has focused on delivering a minimum package of nutrition-specific interventions for children under five years of age, with Page 10 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) a focus on the ‘first thousand days’ window of opportunity (from conception to two years of age) and promoting better nutrition and reproductive health for mothers. With technical support from UNICEF, the MoHSSP has completed the implementation of this component. It has exceeded the target PDO indicator of 9,600 beneficiaries with 2,571 pregnant women, 12,287 mothers, and 13,081 children under five years of age receiving basic nutrition services, or a total coverage of 27,885 beneficiaries. In addition, the nutrition program covered 6,254 children under the age of 24 months who benefited from improved infant and young child feeding practices, also exceeding the target indicators of 2,800 children. 19. Component 3. Strengthening Safety Net Management, Coordination, and Monitoring and Evaluation. This component has supported the development of a management information system (MIS) which has been transferred to the MoHSSP, under the DoSSP. Regarding financial management (FM), the project has been rated moderately unsatisfactory since 2018 because of non-reimbursement of ineligible expenditures. The GoC proposed a payback plan in May 2019, which was considered acceptable by the World Bank. As of October 31, 2019, the KMF 16.7 million has been fully reimbursed. Considering this, the FM rating has been upgraded from moderately unsatisfactory to moderately satisfactory. Procurement activities have been rated satisfactory. There are no overdue financial audits. 20. Compliance with environmental and social safeguards is rated Satisfactory . The project is currently rated satisfactory regarding the implementation of environmental safeguards policies based on the successful implementation of safeguards instruments. The Project Implementation Unit (PIU) recruited an environmental and social safeguards specialist with adequate capacity at the beginning of the project. Productive cash-for-work activities are implemented with adequate measures to mitigate and/or manage the limited negative environmental impacts. Proposed AF activities could produce some adverse impacts, such as minor accidents, loss of livelihoods and/or land, water pollution, social conflicts and gender-based violence (GBV), and security issues (mainly related to the economic recovery grant). The current Environmental and Social Management Framework (ESMF) and Resettlement Policy Framework (RPF) for the parent project have been revised and publicly disclosed3 to manage the risks and potential impacts under the proposed AF. D. Rationale for Additional Financing 21. The proposed AF will cover the financing for activities under Subcomponent 1.2 for the early recovery response to natural disasters through the implementation of the following activities : (a) recovery grants, livelihood support services, and adult learning sessions to assist poor households in localities affected by the cyclone; (b) rehabilitation/reconstruction of small infrastructures in affected communities; and (c) administration and monitoring of these two activities. 22. Shortly after Cyclone Kenneth hit the Comoros, the Government carried out an assessment of the impact of the cyclone and developed a Recovery and Reconstruction Plan in June 2019. With support from the development partners (DPs), including the World Bank, the Directorate General of Civil Security (Direction Générale de la Sécurité Civile, DGSC) started a first rapid evaluation in the days following the disaster and produced an assessment of the damages and losses as well as a National Recovery Plan. The report highlighted recovery and reconstruction needs in multiple sectors (housing, agriculture, livestock and fishery, infrastructure, health and nutrition, education and social protection, energy, water and 3 On November 5, 2019. Page 11 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) sanitation, environment, and private sector). The assessment classified the affected areas based on three levels of priority (Figure 1, see also Annex 3): Category 1: severely affected area requiring multisectoral assistance, Category 2: moderately affected area, and Category 3: weakly affected area. The recovery plan estimates damages and losses at US$185 million and calculated that US$277 million would be required over five years to recover livelihoods, rebuild the most affected sectors, and mitigate risks of future disasters. 23. Cyclone Kenneth caused extensive damage to the livelihoods of the affected population, hitting 241 villages in 45 communes and affecting 345,000 people or more than 40 percent of the population. According to the DGSC, 231 of the affected villages (in 28 communes) are in Grandes Comores, 10 villages (in 6 communes) in Mohéli, and 18 villages (in 11 communes) in Anjouan4 (see Annex 3 for more details). Overlapping the poverty map and affected areas reveals that poor communities were most affected by the cyclone, even if all parts of the income distribution were hit (as illustrated in Figure 1). The cyclone resulted in an official death toll of 6 people, more than 153 people injured, and at least 11,000 displaced people. A total of 4,854 houses were destroyed and 7,013 damaged. Figure 1. Number of Affected Villages - by Poverty and Priority Zones – As of June 2019 Source: DGSC; National Institute of Statistics, Economic, and Demographic Studies (INSEED); and author’s calculation. Note: Based on poverty map, 2003, calculated by INSEED. 24. Cyclone Kenneth also caused extensive damage to infrastructures. In the education sector, 38 percent of the Comoros’ classrooms (465 classrooms) were destroyed affecting more than 44,000 pupils. A total of 147 water tanks, serving more than 130,000 people, were damaged. In addition, nine health facilities were also damaged. The cyclone affected 60 percent of the standing food crops, 30 percent of cash crops, and 30 percent of trees in the affected areas and resulted in the loss of hundreds of cattle, goats, and chicken. 4 However, the DGSC acknowledges that due to lack of time for the assessment, some affected villages could not be identified. DPs such as Food and Agriculture Organization of the United Nations or UNICEF have been able to identify other affected villages in Mohéli and Anjouan. Page 12 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) 25. In a fragile small island economy with limited response capacity from the formal institutions and governance structures, the consequences of Cyclone Kenneth are affecting people’s lives and livelihoods and the inequality gap is likely to widen. Preliminary gross domestic product (GDP) growth estimates in 2019 were revised down from 3.1 percent to 1.3 percent because of the cyclone. The impact from the cyclone is likely to contribute to a further widening of the inequality gap, which is mainly driven by differences in education and employment, as well as socioeconomic conditions in local communities and access to diaspora remittances.5 Individuals whose consumption level is just above the poverty line are vulnerable to falling back into poverty because of the devastations of the cyclone. In general, consumption levels among the poorest are likely to decrease which will also contribute to increasing poverty. In addition to losing their homes and fearing for the next rainy/cyclone season, many households were temporarily relocated and to date are still hosted by family members or neighbors, often split up and far from their regular sources of revenue and school system, with additional expenses imposed on their households and host families. 26. Given the limited capacity of the country, the GoC has asked for support from technical and financial partners to implement the recovery plan of the Comoros. A state of emergency was officially declared by the Government shortly after the cyclone, and the Government requested the World Bank’s assistance on May 23, 2019. The effect of Cyclone Kenneth has exacerbated socioeconomic vulnerabilities in affected areas, underscoring the need to support the most affected households who are at risk of food insecurity—a priority beneficiary group in the SSNP. 5 Comoros Poverty Assessment, April 2017. Page 13 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Figure 2. Impact of Cyclone Kenneth Source : General Directorate of Civil Security (Direction Générale de la Sécurité Civile), 2019. 27. The AF to the SSNP is an efficient way to respond to the recovery needs of cyclone-affected households. The SSNP already includes a subcomponent designed to respond to natural disasters, which has been tested in previous incidents related to cyclones and landslides. By building on the existing experience and systems, the activities of the AF will provide a way to support the economic and social recovery of households and communities whose livelihoods and service facilities have been damaged by the cyclone, in line with the objectives of the parent operation. 28. The AF provides an opportunity to connect the emergency, humanitarian response with a more resilience-oriented approach. The project will follow a flexible and phased approach to support recovery and development of livelihoods, as well as rehabilitation of essential community infrastructure. The recovery grant will be paid in three instalments to ensure that both immediate needs are met and that households can invest in productive assets over time. Selected beneficiaries will be supported over several months by local organizations to follow through on those recovery activities. This combined approach is expected to allow beneficiaries to meet pressing needs while also strengthening their income-generating activities and resilience in the longer term. In addition, the rehabilitation of essential community infrastructure such as schools, water tanks, and health facilities will allow communities to access again much-needed human and economic development services. 29. This AF is part of a comprehensive World Bank response to address impacts from Cyclone Kenneth. It complements other government operations and programs by focusing on a sector where there is no or limited donor support and where the World Bank has added value. Given the extraordinary level Page 14 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) of impact of the cyclone, the World Bank’s response combines the strategic use of IDA resources of US$73 million as detailed below: (a) Using up to US$18 million of the uncommitted IDA18 performance-based allocations through (i) the emergency component of the SSNP (P150754) to channel the AF to support recovery grants and livelihood support services for poor households in disaster-affected communities, as well as the rehabilitation of selected small community-based infrastructure; and (ii) activating the Contingent Emergency Response Component (CERC) of the Comprehensive Approach to Health Systems Strengthening (COMPASS) Project (P166013) which was approved on July 2, 2019, and has a functioning PIU; (b) Using up to US$10 million from active operations of the portfolio within their respective envelopes, especially the two investment projects supporting the agriculture and fishery sectors: the Integrated Development and Competitiveness Project [PIDC, P164584] and the AFR RI-South West Indian Ocean Fisheries Governance and Shared Growth Project [SWIOFish 1, P132123]; and (c) A Crisis Response Window (CRW) allocation of US$45 million to support recovery and increase resilience of select public and private infrastructure in areas affected by Cyclone Kenneth through the Comoros Post-Kenneth Recovery and Resilience Project (CPKRRP) (P171361, hereafter ‘Emergency Project’). 30. A disaster recovery context requires gender-sensitive approaches. While the parent project has achieved a high degree of participation of women, these outcomes could be more difficult to achieve in a disaster recovery context. Global evidence shows that natural disasters disproportionately have an impact on women and that inequalities that prevailed in the pre-disaster context are likely to be exacerbated. 6 While Comorian society is matrilineal and gender equality is embedded in the Constitution, high inequalities prevail that translate into inequal access to economic opportunities; there is a large education gap, women’s participation in the labor force is half that of men, their access to public service jobs is limited, and social and customary norms translate into low influence over household decision making and low control of assets.7 Despite being disproportionately affected by disasters, evidence shows that women have a critical role to play in reconstruction and recovery efforts to ensure the sustainability to those efforts.8 This project will incorporate these findings to enhance female participation, encourage women 6 In countries where women’s socioeconomic status is low, women’s mortality rates can be higher than men’s (for instance, in Bangladesh during the 1991 cyclone, women were 14 times more likely to die than men), and women are subject to indirect impacts that occur in the aftermath of a disaster and compound their impact (deterioration in access to social services, unequal access to social assistance, GBV, early and forced marriages, loss of livelihood and access to education, increases in workload, and so on). UNDP (United Nations Development Program). 2010. Gender and Disasters. Bureau for Crisis Prevention and Recovery. https://www.undp.org/content/dam/undp/library/crisis%20prevention/disaster/7Disaster%20Risk%20Reduction%20- %20Gender.pdf. World Bank. Gender Equality and Women’s Empowerment in Disaster Recovery. Disaster Recovery Guidance Series .GFDRR. https://www.gfdrr.org/sites/default/files/publication/gender-equality-disaster-recovery.PDF . 7 World Bank. 2019. Towards a More Prosperous and United Union of Comoros, Systematic Country Diagnostic . World Bank. 2019. CPF for the Union of Comoros. 8 World Bank. 2019. Towards a More Prosperous and United Union of Comoros, Systematic Country Diagnostic . World Bank. 2019. CPF for the Union of Comoros. Page 15 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) to participate in the trainings and to develop livelihood activities, and ensure that women are not excluded from receipt of the grant, thereby promoting women’s economic inclusion and empowerment. II. DESCRIPTION OF ADDITIONAL FINANCING A. Summary of Changes 31. The proposed AF would (a) scale up SSNP activities in the cyclone-affected areas through Subcomponent 1.2 ensuring an early recovery response to natural disasters; (b) expand Component 3 for additional project management, supervision, and operating costs; and (c) extend the project closing date by three years from December 31, 2019, to December 31, 2022, to implement the additional activities. (a) PDO. The PDO of the parent project does not fully reflect the activities undertaken under this AF, in particular the rehabilitation and reconstruction of community infrastructures. Hence the PDO will be amended to ‘Increase poor communities’ access to safety net, nutrition and community services.’ (b) Results Framework. The Results Framework of the project will be adjusted to reflect the new scope and scale-up of project activities. This includes introducing indicators that reflect the increased coverage of the population affected by Cyclone Kenneth benefiting from the livelihood recovery grants, as well as updating some end targets. (c) Institutional arrangements. Currently, the SSNP is implemented under ANACEP whose objective is to prepare, coordinate, and monitor all investment and development projects in the country. Based on a request from the Government and to ensure quick implementation, the implementation of the project will be transferred to the DoSSP under the MoHSSP. The World Bank carried out an institutional assessment of the arrangements, with a focus on operational, fiduciary, and safeguard capacities, and found that they are adequate given that the entire staff from the SSNP has been moved to the MoHSSP and that they will continue to work on the project. The project’s legal agreement will be adjusted to reflect these institutional arrangements. (d) Social and environmental safeguards, rated as Category B, remain unchanged. There are no potential large-scale, significant, and/or irreversible environmental and social impacts expected to arise from this project or its AF. The environmental and social safeguard policies triggered by this operation are the same as those under the parent project: OP/BP 4.01 (Environmental Assessment) and OP/BP 4.12 (Involuntary Resettlement). An Environmental and Social Management Framework (ESMF) and Resettlement Policy Framework (RPF) were updated to reflect to the additional financing. The documents were disclosed in country and on the World Bank website on November 5, 2019. They were disclosed through the parent project. For the AF the safeguard risk rating and policies triggered were unchanged from the parent project, but in order to provide an update in the PID/ISDS it was necessary to select this option. Page 16 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) (e) Extension of the closing date. The project closing date would be extended by three years from December 31, 2019, to December 31, 2022, to implement the additional activities. This extension of three years is necessary given the magnitude of the disaster, the quantity of rehabilitation of infrastructure, and the limited capacity of the country. B. Changes to Components and Costs 32. The AF will scale up Subcomponents 1.2 and Component 3 of the SSNP over a three-year period. 33. Component 1: Establishing a Productive and Disaster Responsive Safety Net. (Original US$4 million; revised US$3.43 million; additional US$15 million). Under Subcomponent 1.2, the AF will finance two distinct activities as detailed in the following paragraphs. 34. Activity (a): Support the early recovery of selected, cyclone-affected households (US$10 million). This activity will be implemented through the provision of recovery grants and access to an integrated support package comprising adult training sessions and livelihood support services for 10,000 selected poor households in villages affected by the cyclone. 35. This activity will build on international experience and finance studies to develop and implement a sequenced and flexible approach to livelihoods strengthening that includes (a) recovery grants for all beneficiaries; (b) a set of options for livelihood support services to accompany the grant that will accommodate different settings and socioeconomic conditions; and (c) adult learning sessions. This integrated package will tackle key constraints to the recovery and creation of income-generating activities and focus on restoring productive assets, increasing productivity in agriculture, diversifying livelihoods, and increasing resilience to future disasters. The set of options offered to beneficiaries for technical livelihood support services will be determined based on the economic potential and constraints of each region and the support will be flexible to adjust to the heterogeneity of needs and capacities of beneficiary households. The envisioned sequenced support is illustrated in Table 1. Table 1. Sequenced Approach to Livelihoods Strengthening Month 9–End Months 1–2 Months 2–8 Months 8–10 of Project 1.  First  Second  Third installment: Recovery installment: 10 installment: 70 A final payment of grants percent of the percent will be 20 percent will be grant upon paid upon paid after an registration in validation of a assessment of the the program. simple recovery progress made. plan and participation in the trainings. 2.  Income-  Validation of  Follow-up  Follow-up Livelihood generating recovery plan coaching and coaching support activities  Follow-up mentoring and services orientation and technical support mentorin (specific to profiling g Page 17 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Month 9–End Months 1–2 Months 2–8 Months 8–10 of Project the choice  Support to  Coaching and of recovery plan mentoring technical development support  Technical package) training  Coaching and mentoring 3. Adult  Formation of  Continued sessions  Continued sessions  Continued learning groups based on based on curriculum sessions sessions  Selection of curriculum based on group leaders curriculum  Monthly sessions on key human development and economic inclusion topics 36. Recovery grants will be paid to beneficiary households through third-party institutions (microfinance, bank, mobile banking, and so on) in three instalments as described in Table 1. The first disbursement will be paid upon registration in the program and is expected to enable beneficiary households to cover their short-term consumption needs. The second installment will be paid upon validation of a simple and realistic ‘recovery plan’ that will lay out how the household proposes to use the money, and the third installment will be paid after a simple assessment of the progress made in implementing the plan without applying rigid criteria. While beneficiaries will be encouraged to use part of the second and third payments to rebuild or develop economic activities and productive assets, flexibility will be built in to ensure that the recovery plans are realistic, and the scale is adjusted to the conditions of the households. It is therefore expected that most registered households will receive the three instalments. This subcomponent will finance the direct cost of the grant as well as the cost of transfer through third-party providers. The amount of the grant (US$700 to US$750), corresponds to around 63 percent of average annual per capita consumption.9 (a) Livelihood support services will provide beneficiaries with the necessary skills and support to develop their choice of income-generating activities as they receive the recovery grant. It will be based on previous analytical work carried out by the World Bank on promising value chains and include livelihood orientation, goal setting, training in technical skills for livelihood development, coaching and mentoring, and follow-up support to beneficiaries to sustain their economic inclusion activities. Beneficiaries will be grouped for the livelihood support trainings based on their choice of livelihoods. Women will be particularly encouraged to diversify their income-generating activities and consider occupations that are 9This is slightly below other government-led programs in the Sahel region fostering productive inclusion and in non-emergency settings (Burkina Faso, Chad, Mali, Mauritania, Niger, and Senegal). In those countries, the transfer is between US$140 and US$275, which represents around 70 percent of average annual per capita consumption. Page 18 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) traditionally taken by men. (b) In parallel, the beneficiaries will be supported through adult learning sessions related to human development and economic inclusion to strengthen their resilience. This will include a package of core trainings on early child development and parenting, nutrition, health and sanitation, family planning, women empowerment, and financial literacy and planning. The parts of the package of training related to human development (early child development, health, education, family planning, parenting, and reproductive health) and women empowerment will be coordinated with the COMPASS Project (P166013), given the latter’s plans to implement similar measures in pilot zones. Methodology as well as tools and materials will be developed jointly. The coordination, collaboration, and communication during preparation and implementation will be facilitated by the fact that both the health project and the AF are under the same ministry (MoHSSP). Health, Nutrition, and Population and Social Protection and Jobs teams have jointly hired a specialist to help the PIUs of the two projects prepare those activities. Financial literacy will be promoted through the opening of bank accounts by each participant in microfinance institutions (MFIs) of their choice. The sessions will draw on behavioral approaches and focus particularly on boosting women’s empowerment and participation in household decision making and budget management. The project will draw on lessons from other countries with behavioral interventions, such as Madagascar and Kenya, for the design and implementation of these adult learning sessions. Beneficiaries will be grouped for the delivery of the trainings under the leadership of ‘group leaders’, preferably women, and in safe spaces. Those leaders will be supported by the social protection committees, nongovernmental organizations (NGOs), and project staff to deliver the trainings. The project will elaborate materials and tools for mother/father leaders. The capacity building of the mother/father leaders and the well- being sessions will adopt a participatory, iterative, and playful pedagogy using examples and experiences relevant to the beneficiaries to facilitate assimilation and appropriation of key messages. 37. The enrollment step will help determine which household members will collect the transfer and participate in the livelihood support services and adult training sessions. By default, the female head of the household or the spouse of the household head will be the primary recipient of the grant. Households will be offered the option to request that the transfer be made to a bank account owned jointly by the head of the household and his spouse or to an alternative recipient in case the household head and/or his spouse are unavailable. The enrollment step will also determine which household members will participate in the different training sessions, depending on the household’s livelihood strategies and the skills and capacities of the different household members. A lot of flexibility will be allowed to adjust to the specific conditions of beneficiary households and maximize the impact of both the grant and the support services. 38. Geographic targeting. Based on the Memorandum of Understanding signed in 2015, the PIU coordinates with the DGSC on targeting. To effectively and quickly respond to emergencies, the project had to coordinate action and efforts with the DGSC, which is the government agency in charge of Disaster Risk Management (DRM). The working group which also includes the MoHSSP and ANACEP decided on geographic targeting using the data collected by the DGSC to objectively identify the most affected areas. The two criteria used to identify the villages most in need of assistance following the cyclone were (a) high Page 19 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) impacts of Cyclone Kenneth in the community (villages identified as priority 1 or 2 in the recovery plan) and (b) high poverty rate: (villages where more than 69 percent of the population lives below the poverty rate).10 All 118 villages that met those two criteria were selected to benefit from the project activities: 83 in Grandes Comores, 22 in Anjouan, and 13 in Mohéli. Among those villages, 35 are priority one villages and 83 are priority two villages. No priority three village was selected as the impacts of Cyclone Kenneth were smaller and poverty rates in those villages ranged from 26 percent to 60 percent. Table 2. Priority Villages Based on Extent of Impact of Cyclone Kenneth Islands Priority Based on the Extent of Grandes Mohéli Anjouan Total the Impacts of Cyclone Kenneth Comores Priority 1 — — 35 35 Priority 2 13 22 48 83 Total 13 22 83 118 39. Distribution of beneficiary households on the three islands. In all identified villages, 30 percent of households will be selected among the poorest and most vulnerable to benefit from the recovery grant and the associated package of support services. In total, 10,000 households or about 50,000 persons representing 15 percent of the affected population will benefit from the project. To facilitate the implementation, a minimum of 30 and a maximum of 400 beneficiary households per village were set. Based on the latest population estimates available,11 the beneficiary households will therefore be distributed as follows on the three islands: 55 percent in Grandes Comores, 32 percent in Anjouan, and 13 percent in Mohéli. Table 3: Population of the Identified Villages on the Three Islands Islands Number of Communes Number of Villages Population Number of Households Grandes Comores 22 83 104,604 18,620 Anjouan 10 22 61,538 10,989 Mohéli 5 13 23,616 4,217 Total 37 118 189,758 33,826 40. Selection of beneficiary households. Beneficiary households will be identified in cyclone-affected villages based on a combination of community selection and categorical criteria considering gender aspects. The development of the targeting system and guidelines will be financed under Component 3, and the implementation will be financed under this subcomponent. The following criteria will be considered: (a) education of the household head; (b) number of children below five years living in the household; (c) household’s assets; and (d) gender of the household head. 41. Guidelines will be developed as part of the emergency response manual to prioritize households based on these criteria. The selection of households will follow the following steps: 10 Measured using the 2003 poverty maps elaborated by INSEED. 11 The DGSC used the projection made by INSEED based on the latest census. Page 20 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633)  Community assembly to present the project  Pre-registration of households interested in joining the project: several registration centers will be opened to facilitate the process. Data on the household will be collected during registration, including information on household identification, household demographic composition, variables related to the selection criteria, and damage to housing caused by the cyclone (to be used by the Emergency Project).  First community validation to ensure that the most affected households are pre-registered  Prioritization based on the criteria determined by the project  Validation by the community  Validation by the project staff to ensure that procedures complied with the guidelines 42. NGOs, consultants, or other third parties will be contracted competitively to provide support to the implementation of the recovery grant. The project will build on the lessons learned from the parent project during which overall support from NGOs was positive. However, resource availability was an issue in Mohéli, and NGOs and the payment agency had three-year contracts which reduced the administrative costs but also the leverage of the project to ensure quality. (a) Targeting. Targeting was carried out by the project team during implementation of the parent project. Given the increase in scale of the activities and the need to act quickly to respond to the emergency, the project staff will be assisted by consultants or NGOs for the targeting process of the AF, including community validation and beneficiary registration. (b) Livelihood support and adult learning sessions. NGOs will be recruited competitively to provide those services following training guidelines and emergency response manual developed by the project. They will collaborate with the local agriculture offices to ensure that existing good practices are carried forward and will train and support group leaders for the delivery of the adult training sessions. In the interest of efficiency, the project may decide to offer one-year contracts, renewable if evaluation is satisfactory, instead of three-year contracts. (c) Payment. The parent project had a contract with the Union des Meck, which used a highly centralized payment system that delayed payments to beneficiaries. This AF will try to collaborate with local agencies (MFIs, banks, and so on) and will assist beneficiaries to open bank accounts to overcome this issue. 43. A communication strategy will be developed by the implementing agency to foster transparency, to ensure that eligibility and targeting criteria are well understood, and to encourage families to focus on their human development and economic recovery. 44. Activity (b): The rehabilitation/reconstruction of damaged infrastructure (US$5 million). This activity was already included under the original Subcomponent 1.2 and will therefore not require any Page 21 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) significant change in design. This activity will be guided by the DGSC which the government agency in charge of DRM. Around 100 infrastructure subprojects are expected to be financed in poor communities in Priority 1 and 2 areas, considering the damage assessment of the Government. A participatory, community-based approach will be followed to identify priority infrastructure. Communities will be responsible for maintenance to ensure sustainability. Cash-for-work modalities will be used for minor rehabilitation works when it is technically possible and local labor and materials are available. The rehabilitation would therefore be implemented through either contractors or, where possible, through cash-for-work activities, supported and supervised by NGOs, for light repairs of damaged infrastructure, to ensure that a large part of the financing benefits the participating communities. 45. This AF was prepared in close cooperation with the Emergency Project to ensure complementarities and synergies with activities (a) and (b). The Emergency Project will focus on addressing recovery and reconstruction needs in the housing and infrastructure sectors and will therefore use different targeting criteria to select beneficiary communities and households, Emergency Project placing an emphasis on impacts on housing. However, the intervention areas of both projects are likely to overlap, because both projects focus on areas affected by the cyclone and target poor and vulnerable households. Close coordination is therefore needed through joint work with the DGSC.  Activity a. The Emergency project will finance the reconstruction of 1,000 houses on the three islands, complementing component a of this AF. Using transparent and objective selection criteria, households will be identified among the poorest whose houses have been damaged by the cyclone to receive housing support from the Emergency Project. To ensure coordination, the registry of beneficiary households to be developed under this AF will be shared with the Emergency Project and will include some variables on the housing conditions and damage from the cyclone. The Emergency Project will then use the information from the registry to complement its database for targeting. In communities targeted by both projects, it is therefore possible that some of the poorest and most vulnerable households will be selected both for the recovery grants and for housing support.  Activity b. The Emergency Project also plans to finance US$0.7 million of small community infrastructures, focusing on different types of infrastructure such as walkways, alleys, roads and associated drainage; small public spaces such as parks; small recreational infrastructures; solar powered public lamps; and other small infrastructures closely related to housing. This AF, on the other hand, will focus on community infrastructure such as schools, health centers, water storage, and so on. 46. During further preparation and implementation, coordination will be ensured through joint work with the DGSC’s and DoSSP’s representation in the Emergency Project’s Steering Committee. 47. Component 2. Improving the Nutrition of Young Children and Mothers from Poor Communities. This component will not receive any AF. This component is currently 100 percent disbursed and the newly approved COMPASS Project (P166013) will be taking over component activities, in close collaboration with the Social Protection and Jobs task team and PIU. 48. Component 3: Strengthening Safety Net Management, Coordination, and Monitoring and Evaluation will be scaled up under the AF. This component will obtain additional funding of US$3 million Page 22 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) to ensure proper management of activities under Subcomponent 1.2 and continue to support the GoC in building a social protection system. (a) The AF will support coordination and M&E of the activities. To this end, regional offices of the project will be reopened, and funding will be used for hiring of consultants, logistics, provision of equipment, training of trainers, communication, and operating costs; (b) The AF will continue to support the foundations and main elements of a safety net system (i) MIS with unique identification and key socioeconomic and demographic information on beneficiaries in the target areas; (ii) development of a targeting system and tools to identify poor and vulnerable affected households; (iii) grievance and redress systems supporting responsive management and social accountability; and (iv) efficient payment systems . These services have been designed under the parent project and are crucial for building a social protection system. The AF will try to adopt innovations with the use of digital technology to enhance these services; (c) The AF will contribute to strengthening the institutional and technical capacity of the Government. All these key elements of the SSN system will be developed in close collaboration with the DoSSP. In addition, the project will continue to assist the DoSSP in the establishment of a social registry. The project will also support the DoSSP to enable carrying out supervision of the programs as well as coordination and M&E functions which are central to the establishment of a strong SSN. 49. The costs by component for the original financing and the AF are presented in Table 4. Table 5 presents the breakdown of the budget (including administrative costs) between the socioeconomic recovery grant and the rehabilitation of infrastructures. The direct transfers to beneficiary households is estimated at around 60 percent of the total cost of the recovery grants, while livelihood support and adult training sessions are estimated to account for 10 percent to 15 percent of the total budget for this activity. The latter is essential to complement the cash transfer and foster positive behavioral change toward improved well-being and long-term improvement of the living conditions of household beneficiaries. Table 4. Social Safety Net Project Costs and Financing (US$, millions) Component Initial Cost Revised Cost Additional Revised After First Finance Cost Restructuring Component 1: Establishing a Productive and 4.00 3.43 15.00 18.43 Disaster Responsive Safety Net Subcomponent 1.1: Establishing a 3.20 3.43 0.00 3.43 Productive Safety Net Subcomponent 1.2: Ensuring an Early 0.80 0.00 15.00 15.00 Recovery Response to Natural Disasters Component 2: Improving the Nutrition of 1.00 1.17 0.00 1.17 Young Children and Mothers from Poor Communities Page 23 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Component Initial Cost Revised Cost Additional Revised After First Finance Cost Restructuring Component 3: Strengthening Safety Net 1.00 1.40 3.00 4.40 Management, Coordination, and Monitoring and Evaluation Total Project Cost 6.00 6.00 18.00 24.00 Table 5. Costs and Financing of AF by Activities (US$, millions) Rehabilitation of Component Recovery Grant Small Total Infrastructures Component 1: Establishing a Productive and Disaster Responsive Safety Net Subcomponent 1.1: Establishing a Productive 0 0 0 Safety Net Subcomponent 1.2: Ensuring an Early Recovery 10 5 15 Response to Natural Disasters Component 2: Improving the Nutrition of Young 0 0 0 Children and Mothers from Poor Communities Component 3: Strengthening Safety Net Management, Coordination, and Monitoring and 2 1 3 Evaluation Total Project Cost 12 6 18 C. Other Changes Implementation Arrangements 50. The MoHSSP will be responsible for the implementation of the project. Based on the government request and to ensure quick implementation, the PIU will be moved from ANACEP to the MoHSSP, under the DoSSP. This change was motivated by the excessive workload of ANACEP, which already oversees dozens of projects in the Comoros and had not been able to mobilize the human resources necessary to coordinate the activities under the parent project. The arrangement will be functional before project effectiveness, given that the entire project staff will be moved to the new institution and continue to be responsible for the fiduciary and day-to-day management of the project. The DoSSP will be responsible for coordinating the timely and effective implementation of the project. 51. The PIU is responsible for fiduciary aspects as well as for management and implementation of the AF. The implementation of the activities under the AF will be coordinated by this PIU, in close collaboration with the DoSSP at national and island level. The project will also have delocalized implementation units on the three islands. The project will recruit key staff with appropriate skills through a competitive process. The PIU will continue to work closely with a wide group of stakeholders from the Government, communities, the private sector (for example, microfinance and telecommunication companies), and NGOs for the implementation. The Emergency Response manual as well as the Page 24 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) administrative, financial, and procurement management manual will be adjusted to account for the new activities and implementing agency. These manuals will be reviewed by the World Bank and available before the effectiveness date. D. Gender 52. Recognizing the importance of gender-specific constraints, Subcomponent 1.2 will include interventions to boost women’s economic inclusion and social empowerment. First, the project will aim to ensure gender balance in participation through gender-sensitive sensitization campaigns and will ensure that the needs of women are addressed when developing the adult training sessions and the set of options for livelihood support services. By default, the grant will be transferred to the female head of the eligible household, unless an explicit request is made by the household to receive it on an account held jointly by both spouses or by another member of the household when relevant. The integrated support package will include specific gender-sensitive elements addressing GBV, social norms, and individual aspirations. Women beneficiaries will receive life skills training and will benefit from dedicated mentoring to address social barriers and boost self-confidence. Trainings for adult learning sessions and for livelihoods support services will partially be organized separately for women and men, when appropriate. The project will also use behavioral nudges12 to support self-affirmation. Second, evidence shows that cash transfers can help in reducing GBV-related practices (including intra-household violence and early marriage, among others).13 The project will therefore empower women and foster their economic inclusion by helping them develop their livelihood strategies and allowing them to acquire some skills while contributing to the recovery of their communities. For women particularly, the project will promote the diversification of livelihood options to encourage women to take up income-generating activities that are usually carried out by men. Finally, to reduce the risk of GBV, monitoring efforts through independent post-payment activities, will look specifically at gender issues in the distribution process to ensure that benefits are reaching the intended beneficiary, challenges for women to collect their benefits, and risky intra-household dynamics, among other key project-relevant gaps between males and females. The project’s Grievance Redress Mechanism (GRM) and citizen engagement activities will also explicitly include avenues for reporting and addressing possible GBV-related incidents. E. Climate Change 53. The Comoros is at constant risk and exposure to climate and geographical hazards, as exemplified by the passing of Cyclone Kenneth. Recent trends have indicated an uptick in cyclones and heavy rain as well as droughts that have been longer in duration in recent years. The proposed AF is seeking to build the resilience of communities by repairing/rehabilitating and strengthening small social community infrastructures that predominantly serve vulnerable populations damaged by the passage of the cyclone. The project will use the building-back-better approach, will foster wider dissemination of DRM concepts, and help ensure higher and safer standards of construction to ensure infrastructure resilience. All community infrastructure will be designed to be climate resilient, in that they are planned, designed, built, and operated in a way that anticipates, prepares for, and adapts to changing climate conditions. The project is also focusing on a ‘productive inclusion’ approach, which encompasses a phased 12 Such behavioral interventions have already been developed in the context of safety net programs in Madagascar, Tanzania, and Kenya and will be adapted to fit the Comorian context. 13 Tenzin, M. 2018. “Tackling the Intervention of Gender-based Violence Prevention and Response and Cash-based Interventions.” Women’s Refugee Commission. http://www.cashlearning.org/downloads/genderandctpwrc.pdf. Page 25 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) intervention that combines a large cash grant with livelihood support services (chosen from a set of options relevant to the local context) and adult learning sessions (health, education, empowerment, and so on), with the objective to support self/wage employment and diversification of livelihoods and resilience. These SSN instruments are being used as part of an effort to be more responsive to urgent needs following disasters as a measure of climate adaptation and the approach fosters greater resilience of communities overall. A climate screening has been conducted and while it indicates high levels of exposure with moderate level of impact to project-supported infrastructure, the project will also contribute to modulate risks through capacity building to anticipate natural disasters better and target responses more effectively. F. Monitoring and Evaluation 54. The M&E of the AF activities will be financed by the project (Component 3) to measure attainment of the goals of the disaster response activities financed by the AF. Key questions for the evaluation will include, among others, any changes in households’ consumption, use of social services, household economic activities and employment gains associated with the project, and use of rehabilitation/reconstruction of damaged infrastructures. The project will use a tracer survey to examine households’ involvement in activities and investments following reception of the recovery grant. In particular, it will evaluate whether the recovery grants are used differently by the poorest households versus households close to the poverty line. III. KEY RISKS 55. The overall risk rating for the Comoros is substantial. The AF upgrades the risk ratings of the parent project for political and governance, sector strategy and fiduciary given the recent political instability and the change in overall governance in the country as well as the past experience on ineligible expenditure. High and substantial, together with proposed mitigation measures, are summarized in the following paragraphs. 56. Political and governance risk is high. The Comoros remains exposed to risks stemming from the tense relations between the GoC and governments of the islands, particularly as the country now undergoes controversial constitutional changes altering the current presidential rotation and governance practices. Beyond current constitutional challenges, recent political instability in Mayotte and Anjouan and vulnerability, particularly among disadvantaged youth, may exacerbate political and governance risks. Sudden shifts in policy priorities or even political instability could affect delivery of the new operations or disrupt implementation of ongoing operations. The presence of a World Bank resident representative stationed in Moroni as well as the technical and fiduciary team from regional country offices supporting the program facilitate more regular interaction with Comorian counterparts, through frequent, timely, and on-demand missions. 57. Macroeconomic risk remains substantial. There are four main sources of macroeconomic risk facing the Comoros: (a) its dependency on external financing, both public and private; (b) possible impact of other bilateral and multilateral partners and financial institutions on debt sustainability (for example, through either non-concessional credit or erratic grant funding leading to unrealistic expectations); (c) a business environment unfavorable to the development of the private sector, depriving the state of tax Page 26 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) revenues for public services; (d) the quasi-bankrupt state of the energy utility (MA-MWE and EDA 14), which is unable to provide regular power supply, affecting economic activity nationwide; and (e) its dependence on imports, with an export/import ratio under eight percent. The World Bank Group is mitigating these risks by working closely with the Government as well as other DPs to maximize efficiency, strengthen the regulatory environment required for private investment in sectors such as telecom, improve the commercial and financial performance of the state electricity utility, and help promote export sectors such as fisheries, as well as inform the Government and DPs on debt sustainability. 58. Sector strategies and policies risk is substantial. The GoC has approved the country’s social protection policy in 2016 which provides a comprehensive framework for the strategic development of the country’s social protection system and for coordination. Related to the proposed SSN AF, the risk is mainly related to the challenges of coordination between the safety net and the DRM agenda in the aftermath of the cyclone and the implementation of a Memorandum of Understanding between the agencies involved. The use of a single registry that is under the authority of the DoSSP would also assist in this coordination. The addition of new activities of livelihood recovery grants for self-employment or wage employment will require coordination with related sectors such as agriculture and disaster response, a practice that has already been established under the Productive Safety Net Program and which will need to be continued. Mitigation measures for ensuring proper coordination include clear guidelines in the emergency response manual for the coordination between the pertinent entities, as well as the provision of funding for collaborative management of the selection of sites and households and the joint definition of the community infrastructure projects. 59. The risk of institutional capacity for implementation remains rated substantial. Overall, the original SSNP has performed well, and the PIU would have managed to close the project as originally designed if the Government had not requested the AF in the aftermath of Cyclone Kenneth. However, several institutional risks have emerged for the SSNP, in part due to changes in the country’s overall governance structure (for example, the creation of ANACEP) and counterpart agencies/implementing units. For this AF, the experienced PIU will implement the project under the guidance, coordination, and supervision of the MoHSSP’s DoSSP. While the MoHSSP has limited experience in managing World Bank- financed operations, the PIU brings ample experience with up to 20 years of carrying out community- based projects and four years of providing cash grants for productive purposes under the productive safety net Subcomponent 1.1) of the SSNP. Furthermore, the MoHSSP is currently implementing the COMPASS Project (P166013) and several projects financed by UNICEF and other partners which will together contribute to strengthen its capacity to guide and oversee project implementation and with which this AF is closely coordinating. The SSN’s PIU will be overseen by the DoSSP, which already has experience in managing projects in collaboration with UNICEF. To further enhance the ministry’s and PIU’s capacity, the AF will make provisions for training of technical and project management staff. The World Bank will continue to support the implementing agency with technical assistance and capacity building on economic inclusion, including collaboration and study tours to Madagascar, support for evaluation design, and technical assistance to improve manuals on reconstruction activities. 60. The fiduciary risk is substantial. There were incidents of ineligible expenditures under the parent project, causing it to be rated moderately unsatisfactory for FM at times during implementation. These expenditures are being paid back and the World Bank will continue to track the repayment of ineligible 14 Electricité d’Anjouan. Page 27 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) expenditures. Furthermore, the World Bank will supervise the fiduciary aspects of the project intensively including through audits, technical assistance (TA), and frequent supervision. The AF benefits from the satisfactory implementation of procurement under the parent project and will continue applying the mitigation measures already used for the parent project. It will also benefit from the experience of the PIU which has been located within the DoSSP. Continued attention to building fiduciary capacity in implementation units will also help address this risk. IV. APPRAISAL SUMMARY A. Economic and Financial (if applicable) Analysis 61. The proposed AF is expected to impact beneficiaries outcomes by (a) providing them with economic recovery grants for income-generating activities and consumption smoothing in the aftermath of the cyclone; (b) strengthening their resilience to future shocks; (c) building their human capital and productive skills and promoting their empowerment through training, coaching, and mentoring; and (d) enhancing their access to basic social services through the rehabilitation of selected community-based infrastructure. 62. For this analysis, the benefits are defined as the average increase in the annual earnings because of the recovery grant, although these activities could reasonably be expected to generate other monetary benefits in the longer term (accumulation of assets and shift from casual wage labor to self-employment), human capital benefits, and socioeconomic benefits (such as women’s empowerment). While some of these benefits will be discussed in the narrative, only expected increases in earnings will be included explicitly in the cost-benefit analysis. A detailed or comprehensive economic and financial analysis cannot be carried out for the project because of the short time frame for preparation (emergency operation), the lack of available data, and the uncertainty about the type of activities that beneficiaries will invest in. 63. To address poverty and acute food insecurity, many countries in Sub-Saharan Africa have instituted cash transfer programs as a form of consumption support (Bastagali et al. 2016 and Beegle et al. 2018). Cash transfers can also allow consumption smoothing in post-disaster settings. For instance, Mansur et al. (2018)15 demonstrated that households who received the transfer have a quicker recovery after Cyclone Winston in Fiji, about 28.5 percent of the post-disaster cash transfers were used on food consumption while 21 percent were used on materials for dwelling repairs. Beegle et al. (2018) also show that safety nets in fragile and conflict-affected areas increased productive assets by 34 percent on average while limiting negative coping strategies such as child labor. In addition to short run welfare gains, post- disaster social assistance can also have a strong impact on long-term growth through nutritional and productivity pathways (Dercon 200416 and Hill et al. 201917). However, cash is only one of the constraints that households living in extreme poverty face and that limits their ability to generate income and to cope with shocks such as droughts, climatic shocks, or conflicts. Approaches have therefore been developed 15 Mansur, A., Doyle, J., Ivaschenko, O., 2018. Cash Transfers for Disaster Response: Lessons from Tropical Cyclone Winston (SSRN Scholarly Paper No. ID 3143459). Social Science Research Network, Rochester, NY. 16 Dercon, S., 2004. Growth and shocks: evidence from rural Ethiopia. Journal of Development Economics 74, 309–329. https://doi.org/10.1016/j.jdeveco.2004.01.001. 17 Hill, R., Skoufias, E., Maher, B., 2019. The Chronology of a Disaster: A review and Assessment of the Value of Acting Early on Household Welfare. The World Bank Group, Washington, D. C. Page 28 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) and tested to address those constraints more comprehensively to include a cash plus package of training and business support. 64. International evidence suggests that integrated packages of livelihood interventions, in combination with standard cash transfer programs, can promote income-generating activities, and have a range of productive and sustainable impacts (Bandiera et al. 201718 and Banerjee et al. 2016).19 In addition, they can potentially contribute to building resilience (Macours et al. 2012).20 For instance, Banerjee et al. (2016) were able to track the beneficiaries of such an integrated package of interventions in West Bengal, India over seven years. Their results show significant improvement in consumption, income, food security, household assets, and financial positions (See Figure 3). Bandiera et al. (2017) find that in Bangladesh, with the supply of livestock, the reallocation of labor across work activities by the ultra-poor leads their earnings to be 21 percent higher than their counterparts in control villages after four years. Similar results are also found from a pool of countries (Bangladesh, Ethiopia, Ghana, India, and Pakistan) where the combination of increased assets and labor translated into 42 percent more revenue from livestock after two years and 33 percent after three years relative to the comparison group. In addition, households also invest in livestock business and land acquisition. The same facts have also been observed in Madagascar with the South social safety net program (named FIAVOTA), which provided cash and training to beneficiaries (Rakotomanana et al. 2019).21 Fiavota’s impact evaluation showed that the proportion of households starting family production units is 12 percent higher in the treatment group (leading to an increase in income more important by 11 percentage points) compared to the control group, only after one year of implementation. Evidence also shows that such programs are generally cost effective (with benefit/cost ratios ranging from 133 percent in Ghana to 410 percent in India), (for example, Banerjee et al.2015).22 18 Oriana Bandiera & Robin Burgess & Narayan Das & Selim Gulesci & Imran Rasul & Munshi Sulaiman, 2017. "Labor Markets and Poverty in Village Economies," The Quarterly Journal of Economics, Oxford University Press, vol. 132(2), pages 811-870. https://doi.org/10.1093/qje/qjx003. 19 Banerjee, Abhijit, Esther Duflo, Raghabendra Chattopadhyay and Jeremy Shapiro. 2016. “The Long-term Impacts of a “Graduation” Program: Evidence from West Bengal”. MIT Cambridge USA. https://economics.mit.edu/files/16588. 20 Macours, Karen, Patrick Premand, and Renos Vakis. 2012. Transfers, Diversification and Household Risk Strategies: Experimental Evidence with Lessons for Climate Change Adaptation. Policy Research Working Papers 6053. The World Bank. https://doi.org/10.1596/1813-9450-6053. 21 Rakotomanana Faly, Zo Tahiana Randrianatoandro, Julia Rachel Ravelosoa. 2019. Résultats de l’Evaluation À Mi-Parcours du Programme Fiavota. World Bank. 22 Banerjee, Abhijit, Esther Duflo, Raghabendra Chattopadhyay and Jeremy Shapiro. 2016. “The Long-term Impacts of a “Graduation” Program: Evidence from West Bengal”. MIT Cambridge USA. https://economics.mit.edu/files/16588. Page 29 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Figure 3. Economic Impact by Years Since Asset Inset 1.00 2 years 3 years 7 years 1.09 1.00 0.96 0.80 0.93 0.89 0.88 0.83 0.83 0.78 0.60 0.40 0.45 0.43 0.00 0.33 0.25 0.36 0.25 0.00 0.00 0.30 0.20 0.19 0.18 0.00 Asset Index Productive Asset Household Asset Total per capita Food Security Financial Inclusion Income and Index Index consumption, Index Index Revenue Index standardized Source: Banerjee et al. 2016. The Long-term Impacts of a “Graduation” Program: Evidence from West Bengal. 65. In the post-disaster context in Comoros, the project design is based on best practices and evidence from other productive inclusion or graduation projects and the literature. Affected households will receive a recovery grant in three installments which will be complemented by a comprehensive package of training, coaching, and mentoring. The first disbursement of KMF 32,500 (US$73.69) will be delivered to households after registration in the program and is larger than the monthly poverty line of KMF 25,431 (US$57.66) per capita (World Bank 2019).23 It will enable beneficiary households to cover their short-term consumption needs.24 The amount of the grant (US$700 to US$750), corresponds to around 63 percent of average annual per capita consumption, slightly below other government-led programs in the Sahel region (Burkina Faso, Chad, Mali, Mauritania, Niger, and Senegal). In those countries, the transfer is between US$140 and US$275, which represents around 70 percent of average annual per capita consumption. 66. From the literature, the impact on earnings of productive grants in other countries is not constant over time and ranged from 12 percent before two years to eight percent after two years (Banerjee et al. 2015, Bandiera et al. 2017, and Rakotomanana et al. 2019). Given data limitations, simple assumptions on the evolution of actual household earnings have been made. Data on average household income are drawn from the survey of employment, the informal sector, and household consumption in the Comoros in 2014 (EESIC 2014).25 The baseline considered is the average income in the informal sector given the high level of informality and unemployment in the Comoros. As the latest available data on actual earnings is for 2014, beneficiary income has been projected until 2019 by using national GDP per capita growth rate (earnings and growth are in real term) between 2015 and 2019. This projection assumes that the real income of beneficiaries grew at a similar rate as the country’s GDP per capita. According to the latest technical note on discount rates to be used for economic analysis of World Bank projects, a discount rate of six percent is used. A sensitivity analysis is conducted using a discount rate of 15 percent and for income gains of five percent, ten percent, and 15 percent, or 12 percent per year during 23 World Bank, 2019. Comoros - Towards a More United and Prosperous Union of Comoros : Systematic Country Diagnostic (No. 137110). The World Bank. 24 Behavioral research suggests that poor people make suboptimal economic decisions unless their immediate consumption needs are met, see Scarcity: Sendhil Mullainathan et al. 2013 “Why Having Too Little Means So Much”. 25 Enquête sur l'Emploi, le Secteur Informel et la Consommation auc Comores / Survey of employment, the informal sector and household consumption in the Comoros in 2014 (EESIC). Page 30 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) the first two years and eight percent per year after that. The inflation rate is assumed to be two percent based on the country’s last macroeconomic outlook. The analysis led to the results as in Table 7. Table 6. Summary of Projected Costs and Benefits for a Discount Rate of 6 percent Incremental income 12 percent per 5 percent 10 percent 15 percent gains from year ≤2 years; 8 participation percent per year >two years Baseline earnings in 1,055 1,055 1,055 1,055 US$ (2019) Net present value 105,037 4,922,604 2,154,792 9,232,188 (NPV) (US$) Discount rate (%) 6 6 6 6 Benefit-to-cost ratio 0.31 0.18 0.37 0.55 Internal rate of return 8.2 2.1 10.1 16.4 (IRR) (%) Table 7. Summary of Projected Costs and Benefits for a Discount Rate of 15 percent Incremental income 12 percent per year 5 percent 10 percent 15 percent gains from ≤2 years; 8 percent participation per year >2 years Baseline earnings in 1,055 1,055 1,055 1,055 US$ (2019) NPV (US$) (5,404,710) (8,310,713) (4,621,426) (932,139) Discount rate (%) 15 15 15 15 Benefit-to-cost ratio 0.31 0.18 0.37 0.55 IRR (%) 8.2 2.1 10.1 16.4 Source : EESIC 2014, Banerjee et al 2015, Bandiera et al 2017, Rakotomanana et al. 2019, and author’s calculation. 67. The analysis suggests that the incremental benefits expected in the ‘with-project’ situation compared to the ‘without-project’ situation justify the project costs although not all incremental benefits can be expressed in monetary terms. The estimated NPV of the project is US$105,037 at a discount rate of six percent and with increases in earnings of 12 percent during the first two years and eight percent after two years, which makes the project profitable. The IRR is estimated to be 8.2 percent. 68. A sensitivity analysis was conducted to test various scenarios, for different discount rates and incremental income gains from the project. With a discount rate of six percent, the NPV is negative (negative US$4,922 million dollars) if earnings increase by five percent only, and the IRR is 2.1 percent. For all scenarios where earnings increase by more than five percent, the NPV is positive and the IRR ranges from ten percent to 16.4 percent. With a discount rate of 15 percent, the NPV is always negative and the IRR ranges from 2.1 percent if earnings increase by five percent to 16.4 percent if earnings increase by 15 percent. The results from the impact evaluation of the Fiavota project in Madagascar provide reassurance that such a project can increase income by around ten percent. 69. The project is also expected to generate longer-term benefits in terms of human development and psychological outcomes such as physical health, mental health, political involvement, or women’s empowerment. Banerjee et al 2016 show that graduation can have a positive effect on mental health Page 31 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) driven by self-reported happiness and lack of stress, and political involvement driven by greater interactions with community leaders, improved attendance in community meetings and membership in political parties. For instance, one year after the program ended, 55 percent of treatment group households reported voting in the last election and 49 percent reported voicing concerns with their village leaders in the past year, compared respectively to 48 percent and 44 percent in the comparison group. A meta-analysis by Bastagli et al. (2016)26 also provides evidence of improvement in women’s decision making power and lower physical and non-physical abuse by male partner with cash transfers. Notwithstanding, there is a potential risk of increase of intimate/gender-based violence but in general these behaviors tend to decrease with cash transfers programs (Buller et al. 2018).27 These are significant findings as it shows that beyond improving economic outcomes, the program could improve perceptions of ‘status’ in the community which could in turn improve longer-term economic outcomes, as beneficiaries start exerting their ‘voice’ for example, for negotiating better outcomes with respect to provision of basic public services such as health, water and education. In terms of human capital, Bandiera et al (forthcoming)28 study the inter-generational impact of the graduation approach based on a long term follow up of treated and controlled households 11 years after treatment. They find that among children aged zero to five years at the start of program, prevalence of stunting, wasting and underweight fell by six percentage points. A similar effect was observed only for wasting among children aged six to eleven years. Likewise, overall primary and secondary school completion rates increased by seven percentage points and five percentage points respectively. Likewise, Bedoya et al (2019)29 also find that graduation leads to 6 percentage point increase in school enrollment and 5 percentage point decrease in absenteeism in Afghanistan 70. Access to community infrastructure and services will also be improved through the rehabilitation and reconstruction of selected community infrastructure with which the project already has many years of experience.30 Private companies will be contracted to conduct the work. Concerning the rehabilitation of community infrastructure, lessons learned from previous post emergencies programs in India (Orissa Rural Livelihoods Project, P093478); Indonesia (Community Recovery in Earthquake Affected Areas through UPP, P096647); and Haiti (Housing Reconstruction - Urban Community Driven Development AF, P121833) highlight the importance of community-driven reconstruction efforts which produce the most effective and sustainable results as well as higher beneficiary satisfaction. For instance, ‘A Post Construction Economic Impact Analysis Study for community-driven development (CDD) programs in Indonesia’ found that the average construction cost of community-driven development projects was 40 percent lower than those done by contractors of local governments. Moreover, the project did not only support much-needed investments, but also contributed to the psychological recovery of the victims by involving them in the decision-making processes. 26 Bastagli, F., J. Hagen-Zanker, L. Harman, V. Barca, G. Sturge, and T. Schmidt. 2016. Cash transfers: What does the evidence say? A rigorous review of program impact and the role of design and implementation features. London: Overseas Development Institute. 27 Ana Maria Buller, Amber Peterman, Meghna Ranganathan, Alexandra Bleile, Melissa Hidrobo and Lori Heise . 2018 “A Mixed- Method Review of Cash Transfers and Intimate Partner Violence in Low- and Middle-Income Countries” World Bank Research Observer 2018 33:2, 218-258. 28 These findings are based on discussions with the authors, the paper is not yet available online. 29 Bedoya, Guadalupe, Aidan Coville, Johannes Haushofer, Mohammad Isaqzadeh, and Jeremy Shapiro. 2019. “ No Household Left Behind: Afghanistan Targeting the Ultra Poor Impact Evaluation”. World Bank Policy Research Working Paper 8877. 30 See, for example, Service Support Credit (P084315) and Comoros - Emergency Crises Response Project (P120631). Page 32 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) 71. Rationale for public financing of the emergency productive grant. The recovery grant and livelihood services provided under the project are typically not provided by the private sector and thus justify the provision of these services by public financing. Safety net services are meant to provide the poorest population with some income support to stabilize their living conditions, which is especially important in a post-disaster context. This is expected to help them gradually become productive members of the society as they are able to accumulate assets which they can then use over time to improve their incomes. The World Bank is supporting similar programs worldwide and is thus able to provide a value added to the implementation of safety net and nutrition services based on international experience and global knowledge. 72. Rationale for public financing of the rehabilitation/reconstruction of damaged community infrastructures. The rehabilitation/reconstruction services will be financed by the Government because the poor, affected populations cannot afford to rebuild. It will be implemented through the private sector which will ensure second-round economic benefits for communities. The project will use the building- back-better of construction to ensure infrastructure resilience. The Bank is supporting similar programs worldwide and is thus able to provide added value to the implementation of resilient infrastructure based on international experience and knowledge in DRM. B. Financial Management 73. The FM assessment of the MoHSSP was carried out in accordance with the Directives and Policy for IPF and the World Bank Guidance on FM in World Bank IPF Operations issued on February 28, 2017. The conclusion of the assessment is that the MoHSSP FM arrangements will meet the World Bank’s minimum requirements once the mitigation measures are implemented. The mitigation measures will be implemented within three months after the AF agreement signature and include (a) the update of the administrative, financial, and procurement management manual (including FM procedures) to consider the change in institutional arrangements; (b) the contract renewal of the qualified FM staff involved in the implementation of the parent project; (c) the purchase of adequate accounting software; (d) the recruitment of one internal auditor; and (e) recruitment of qualified payment agent for transfers. 74. The overall risk rating is substantial due mainly to the risk related to the funds flow given the decentralization and the nature of activities to be financed. Once implemented, the mitigation measures shall bring the residual risk to moderate. C. Procurement 75. The procurement part of the project will be implemented by a PIU under the MoHSSP. The MoHSSP has started working with World Bank through the new health project (P166013) recently approved in July 2019. The PIU is staffed with qualified experts moving from ANACEP and working with the parent project. A procurement assessment was undertaken on the MoHSSP and in conclusion, the risk is rated as substantial, mainly due to the requirements of the Procurement Regulations for IPF Borrowers which applies for the AF when the parent project was under the Procurement Guidelines. The risk will be mitigated through regular reporting on the progress and implementation of fiduciary activities by the PIU, World Bank supervision, World Bank procurement team hands-on support when required, and further capacity building. Procurement under the proposed operation will be guided by the following documents: (a) the ‘World Bank Procurement Regulations for IPF Borrowers’ dated July 1, 2016, revised in November Page 33 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) 2017 and August 2018 (Procurement Regulations) and (b) the World Bank’s Anticorruption Guidelines ‘Guidelines on Preventing and Combatting Fraud and Corruption’, revised July 1, 2016. The administrative, financial, and procurement management manual have been drafted in accordance with these documents and detailed procedures for administration and handling of procurement-related complaints. As required by the procurement regulations, the Project Procurement Strategy for Development has been developed by the Recipient with a Procurement Plan covering the first 18 months of implementation and have been finalized before negotiations. 76. The project will use the World Bank’s online procurement planning and tracking tools to carry out all procurement transactions. The Systematic Tracking of Exchanges in Procurement will be used for submission, clearance, and update of the Procurement Plan. (a) All goods and non-consulting services will be procured in accordance with the requirements set forth or referred to in Section VI of the Procurement Regulations. (b) Approved selection methods. Consulting services will be procured in accordance with the requirements set forth or referred to in Section VII of the Procurement Regulations. 77. The Comoros has a procurement regulatory framework, but the national procurement procedures are not widely used for most of the ministries and the client has proposed the use of the World Bank’s procedures and documents for this project. The proposed project has complex procurement that will challenge the Recipient capacity. Procurement activities will be closely followed up by the World Bank team and dedicated consultants. D. Social (including Safeguards) 78. Social assessment and project category. Most of the activities financed under the AF (Component 1. Establishing a Productive and Disaster Responsive Safety Net and Subcomponent 1.2: Early Recovery Response to Natural Disasters) are expected to have limited social impacts as they consist of transfers of economic recovery grants, capacity building and training, and the provision of TA, materials, equipment, and operational costs. 79. Moreover, under Component 1, the AF activities are expected to have site specific environmental and social safeguard impacts as they focus on rehabilitating and reconstructing damaged small infrastructures in the affected communities to respond to the cyclone’s destruction. Thus, project activities could produce some impacts, such as minor accidents, loss of land, social conflicts (some social tensions may nevertheless arise from those who are not among beneficiaries, due to frustration, jealousy, discontent, and so on), GBV, and security issues (mainly related to the economic recovery grant). Social risks related to the staff management should also be considered, such as cases of harassment or abuse of authority. Overall, the potential adverse social risks and impacts of both the original project and the proposed AF are expected to be small in scale and site specific, typical of Category B projects. There is no potential large-scale, significant, and/or irreversible impacts associated with the original project or with the activities proposed for the additional credit. The proposed AF remains Category B, same as the parent project. The same two safeguard policies of the original project are maintained triggered for the AF: OP 4.01 (Environmental Assessment) and OP 4.12 (Involuntary Resettlement). Though no involuntary resettlement occurred to date in the parent project, it is prudent to trigger OP 4.12 to prevent and take Page 34 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) care of rare but possible cases of land acquisition, economic displacement, loss of income, or restriction on land use during rehabilitation/reconstruction of damaged infrastructures. The current ESMF and RPF for the parent project have been revised and disclosed to manage the risks and potential impacts under the proposed AF. 80. Working conditions, community worker mobilization and safety, and gender violence prevention. The project has experience in ensuring community worker safety mainly when implementing labor-intensive public works. The project is continuing efforts to ensure the security of workers. However, the project should continue to reinforce sensitization regarding the importance of work safety and the implementation of safeguard measures during the implementation of the project. Even if no case has been registered to date, the project will also make sure to avoid child labor, and to pay attention to GBV. The rehabilitation of infrastructure or civil works related to Component 1 could be subject to the mobilization of external contractors, however based on the relatively small scale of the planned interventions, it is not expected that a large mobilization of workers will be necessary. Nevertheless, the ESMF of the project was developed to cover worker mobilization issues and health security and safety measures for workers. 81. GBV prevention. The GBV risk for the project was assessed as low. However, the project will pay attention to prevent and address possible GBV or cases of sexual exploitation and abuse (SEA) because of mobilization of short-term workers close to local communities mainly during infrastructure rehabilitation. Measures developed in the ESMF to address these challenges include (a) a continuous assessment of labor influx risks; (b) a requirement that the Recipient includes clauses on workers’ conditions and management, child protection, and GBV prevention in all contracts; (c) provision of TA and training to the Recipient and awareness raising on GBV among all contractors, workers, and local residents; and (d) the setup of an accessible and accountable GRM to ensure that any incident related to workers and GBV will be addressed in an effective manner with sufficient social sensibility. The Emergency Response Manual will be updated to cover worker GBV/SEA issues. 82. Citizen engagement. The project will continue its support to citizen engagement and ensure that related mechanisms in place are inclusive: (a) the project will have two citizen engagement indicators, one related to GRM performance and one related to beneficiaries satisfaction; (b) third-party monitoring will be continued in combination with beneficiary feedback consultations, which will be conducted periodically to inform activities; and (c) the AF will reinforce and implement the GRM to strengthen project governance. 83. Public consultation and information disclosure. The AF will develop a communication strategy to share information related to the project by informing the public about the project’s objectives, activities, expected impacts, and results. The strategy and tools will be tailored according to the targeted audiences (project beneficiaries, civil society organizations, private sector, academia, parliament, and government institutions involved in the social issues). The affected people and communities and other relevant stakeholders were consulted during the update of safeguards document (ESMF/ Environmental and Social Management Plan [ESMP] and RPF/Resettlement Action Plan). The feedback from the consultations were incorporated into the project design and the final draft of these documents. Likewise, during AF implementation, the implementing agency is expected to consult project-affected groups, local governmental organizations, and NGOs on all environmental and social aspects of the project and take their views into account accordingly. Public consultations will be carried out as early as possible and all Page 35 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) the relevant materials in the form and language(s) needed to be understandable and accessible to the groups being consulted will be provided on time before the consultation. The draft updated ESMF and RPF were received by the World Bank in October 2019. The final version of these documents were disclosed both in-country and at the World Bank’s external web site on November 5, 2019. 84. All safeguard policies. A satisfactory timetable, sufficient budget, and clear institutional responsibilities have been secured for the implementation of measures related to safeguard policies. Costs related to safeguard policy measures are included in the project cost. E. Environment (including Safeguards) 85. Environmental assessment and project category. The majority of activities financed under the AF (Component 1. Establishing a Productive and Disaster Responsive Safety Net and Subcomponent 1.2: Early Recovery Response to Natural Disasters are expected to have limited environmental impacts. There could be negative environmental impacts arising from rehabilitation/reconstruction of small infrastructure financed under the AF, however these are expected to be limited in scope and impact as they will focus on damaged small infrastructure in affected communities as a response to Cyclone Kenneth. The site- specific nature of the works will be manageable with good practices and the risk rating of the AF is consistent with the parent project. There are no potential large-scale, significant, and/or irreversible impacts associated with the original project or with the activities proposed for the AF. The proposed AF remains Category B, same as the parent project. According to the screening process outlined in the ESMF, the ESMP will be developed for site-specific works. 86. The capacity to implement safeguards policies has been strengthened during the implementation of the parent project, an environmental and social specialist has been hired, and safeguards implementation was rated satisfactory. V. WORLD BANK GRIEVANCE REDRESS 87. Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to existing project-level grievance redress mechanisms or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns. Project affected communities and individuals may submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank's attention, and Bank Management has been given an opportunity to respond. For information on how to submit complaints to the World Bank’s corporate Grievance Redress Service (GRS), please visit http://www.worldbank.org/en/projects-operations/products-and-services/grievance-redress-service . For information on how to submit complaints to the World Bank Inspection Panel, please visit www.inspectionpanel.org Page 36 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) VI SUMMARY TABLE OF CHANGES Changed Not Changed Implementing Agency ✔ Project's Development Objectives ✔ Results Framework ✔ Components and Cost ✔ Loan Closing Date(s) ✔ Disbursements Arrangements ✔ Safeguard Policies Triggered ✔ EA category ✔ Cancellations Proposed ✔ Reallocation between Disbursement Categories ✔ Legal Covenants ✔ Financial Management ✔ Procurement ✔ Other Change(s) ✔ VII DETAILED CHANGE(S) IMPLEMENTING AGENCY Implementing Agency Name Type Action ANACEP Parastatal/Indepen Marked for Deletion dent Government Institute Ministry of Health, Solidarity and Social Line New Protection Ministry/Ministerial Department Page 37 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) PROJECT DEVELOPMENT OBJECTIVE Current PDO The Project Development Objective is to increase poor communities’ access to safety net and nutrition services. Proposed New PDO Increase poor communities’ access to safety net, nutrition, and community services. COMPONENTS Current Component Name Current Cost Action Proposed Component Proposed Cost (US$, (US$, millions) Name millions) Component 1: Establishing a 3.43 Revised Component 1: 18.43 Productive and Disaster Establishing a Responsive Safety Net Productive and Disaster Responsive Safety Net Component 2: Improving 1.17 No Change Component 2: 1.17 the Nutrition of Young Improving the Nutrition Children and Mothers from of Young Children and Poor Communities Mothers from Poor Communities Component 3: 1.40 Revised Component 3: 4.40 Strengthening Safety Net Strengthening Safety Management, Coordination, Net Management, and Monitoring and Coordination, and Evaluation Monitoring and Evaluation TOTAL 6.00 24.00 LOAN CLOSING DATE(S) Ln/Cr/Tf Status Original Closing Current Proposed Proposed Deadline Closing(s) Closing for Withdrawal Applications IDA-D0320 Effective 30-Jun-2019 31-Dec-2019 31-Dec-2022 30-Apr-2023 DISBURSEMENT ARRANGEMENTS Change in Disbursement Arrangements Yes Page 38 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Expected Disbursements (in US$) DISBURSTBL Fiscal Year Annual Cumulative 2015 44,820.00 44,820.00 2016 554,814.00 599,634.00 2017 889,614.00 1,489,248.00 2018 1,026,846.00 2,516,094.00 2019 1,621,566.00 4,137,660.00 2020 5,500,000.00 9,637,660.00 2021 9,000,000.00 18,637,660.00 2022 3,600,000.00 22,237,660.00 2023 1,762,340.00 24,000,000.00 SYSTEMATIC OPERATIONS RISK-RATING TOOL (SORT) Risk Category Latest ISR Rating Current Rating Political and Governance  High  High Macroeconomic  Substantial  Substantial Sector Strategies and Policies  Substantial  Substantial Technical Design of Project or Program  Moderate  Moderate Institutional Capacity for Implementation and  Substantial  Substantial Sustainability Fiduciary  Substantial  Substantial Environment and Social  Moderate  Moderate Stakeholders  Moderate  Moderate Other  Moderate Overall  Substantial  Substantial Safguard_Table COMPLIANCE Change in Safeguard Policies Triggered Yes Page 39 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Safeguard Policies Triggered Current Proposed Environmental Assessment OP/BP Yes Yes 4.01 Performance Standards for Private No No Sector Activities OP/BP 4.03 Natural Habitats OP/BP 4.04 No No Forests OP/BP 4.36 No No Pest Management OP 4.09 No No Physical Cultural Resources OP/BP No No 4.11 Indigenous Peoples OP/BP 4.10 No No Involuntary Resettlement OP/BP 4.12 Yes Yes Safety of Dams OP/BP 4.37 No No Projects on International Waterways No No OP/BP 7.50 Projects in Disputed Areas OP/BP 7.60 No No Environmental Assessment (EA) Category Change of EA Category Original EA Category Yes Partial Assessment (B) Current EA Category Proposed EA Category Partial Assessment (B) Partial Assessment (B) LEGAL COVENANTS2 LEGAL COVENANTS – ADDITIONAL FINANCING FOR THE SOCIAL SAFETY NET PROJECT (P171633) Sections and Description The Recipient not later than 30 days after effectiveness date, shall cause the Ministry of Health, Solidarity, Social Cohesion and Gender Promotion to create and thereafter maintain during Project implementation, a Project Implementation Unit (PIU) within the Directorate of Solidarity and Social Protection, to be responsible for the Page 40 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) management, coordination, supervision, and monitoring of Project activities. No later than 45 days after the Effectiveness Date or such later date as agreed in writing by the Bank, cause the PIU to appoint and hire at the national and regional level, and thereafter maintain, throughout Project implementation key staff i.e.: (i) a Project coordinator; (ii) a safeguard and environmental specialist; (iii) a recovery grant specialist; (iv) an accompanying measures specialist; (v) a financial management specialist; (vi) an accountant; (vii) a procurement specialist; (viiii) an M&E specialist; and (ix) an infrastructure specialist and thereafter maintain, until completion of the Project, a structure, responsibilities, and such key staff with functions, experience, responsibilities and qualifications acceptable to the Association. No later than three (3) months after the Effectiveness Date, or such later date as agreed by the Bank, the Recipient cause the PIU to appoint and hire an internal auditor, and thereafter maintain an internal auditor for the Project, throughout Project implementation. The Recipient shall take all action required on its behalf to establish, not later than six (6) months after the Effective Date, and thereafter maintain and operate, a functional grievance redress mechanism for the Project, with adequate staffing and processes for registering grievances and acceptable to the Association, thereby ensuring the ongoing improvement on service delivery under the Project. Conditions Type Description Effectiveness Article IV, 4.01 (a) the Recipient has updated the Project Financial and Administrative Manual in a manner satisfactory to the Association; Type Description Effectiveness (b) the Recipient has updated the Emergency Response Manual in a manner satisfactory to the Association. Page 41 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) VIII. RESULTS FRAMEWORK AND MONITORING Results Framework COUNTRY: Comoros RESULT_NO_PDO ADDITIONAL FINANCING FOR THE SOCIAL SAFETY NET PROJECT Project Development Objective(s) Increase poor communities’ access to safety net, nutrition, and community services. Project Development Objective Indicators by Objectives/ Outcomes RESULT_FRAME_T BL_ PD O Indicator Name DLI Baseline Intermediate Targets End Target 1 2 3 4 5 6 Beneficiaries of Safety nets Programs Beneficiaries of Safety Nets programs (number) 0.00 2,000.00 4,500.00 5,000.00 4,000.00 4,000.00 4,000.00 4,000.00 (CRI, Number) Action: This indicator has been Revised Beneficiaries of Safety Nets programs - 0.00 1,000.00 2,250.00 2,500.00 2,000.00 2,000.00 Female (number) (Number) Action: This indicator has been Revised Beneficiaries of Safety Nets programs - Cash- for-work, food-for- 0.00 2,000.00 4,500.00 5,000.00 4,000.00 4,000.00 work and public works (number) (Number) Page 42 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) RESULT_FRAME_T BL_ PD O Indicator Name DLI Baseline Intermediate Targets End Target 1 2 3 4 5 6 Action: This indicator has been Revised Number of poor communities that have access to safety net and 0.00 20.00 60.00 60.00 60.00 60.00 nutrition services. (Number) Action: This indicator has been Revised Pregnant/lactating women, adolescent girls and/or children under 0.00 2,000.00 9,600.00 9,600.00 9,600.00 9,600.00 age five-reached by basic nutrition services (number) (Number) Action: This indicator has been Revised Children under the age of 24 months benefiting from improved infant and 0.00 560.00 2,800.00 2,800.00 2,800.00 2,800.00 young child feeding (IYCF) practices (number) (Number) Action: This indicator has been Revised Beneficiary households receiving recovery grants 0.00 0.00 0.00 0.00 8,000.00 10,000.00 10,000.00 (Number) (Number) Action: This indicator is New Page 43 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) PDO Table SPACE Intermediate Results Indicators by Components RESULT_FRAME_T BL_ IO Indicator Name DLI Baseline Intermediate Targets End Target 1 2 3 4 5 6 Establishing a Productive and Disaster Responsive Safety Net (Action: This Component has been Revised) Number of rehabilitated, reconstructed and constructed 0.00 0.00 0.00 0.00 5.00 36.00 80.00 100.00 infrastructure sub- projects (Number) Action: This indicator has been Revised Number of person/days of employment created 0.00 90,000.00 330,000.00 570,000.00 600,000.00 600,000.00 (Number) Action: This indicator has been Revised Number of households benefiting from post- 0.00 0.00 500.00 1,000.00 1,000.00 0.00 disaster activities (Number) Action: This indicator has been Revised Beneficiaries with recovery plan for their recovery grant for 0.00 0.00 0.00 0.00 0.00 5,000.00 7,500.00 8,000.00 income-generating activities (Number) Action: This indicator is New Page 44 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) RESULT_FRAME_T BL_ IO Indicator Name DLI Baseline Intermediate Targets End Target 1 2 3 4 5 6 Beneficiaries having launched income- generating activities with 0.00 0.00 0.00 0.00 0.00 3,000.00 6,000.00 8,000.00 their recovery grant (Number) Action: This indicator is New Female beneficiaries of socio economic recovery 0.00 0.00 0.00 0.00 0.00 50.00 55.00 60.00 grant (Percentage) Action: This indicator is New Improving the Nutrition of Young Children and Mothers from Poor Number of children under five years enrolled in the growth monitoring 0.00 2,000.00 9,200.00 9,200.00 9,200.00 9,200.00 program (Number) Action: This indicator has been Revised Number of Community Health Workers trained 0.00 50.00 100.00 100.00 100.00 105.00 to provide IYCF services (Number) Action: This indicator has been Revised Strengthening Safety Net Management, Coordination, and Monitoring and Operational costs of the project (Percentage) 20.00 20.00 20.00 20.00 20.00 18.00 Page 45 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) RESULT_FRAME_T BL_ IO Indicator Name DLI Baseline Intermediate Targets End Target 1 2 3 4 5 6 Action: This indicator has been Revised Number of Operational Audits implemented 0.00 1.00 1.00 1.00 2.00 3.00 (Number) Action: This indicator has been Revised Percentage of beneficiary households of the Productive Safety Net 0.00 50.00 70.00 80.00 90.00 90.00 activities registered in the PIU's MIS (Percentage) Action: This indicator has been Revised Beneficiaries' feedback related to the project 0.00 0.00 0.00 0.00 0.00 1.00 2.00 3.00 (Citizen engagement Indicator) (Number) Action: This indicator is New Periodic report on the Grievance Redress Mechanism (Citizen 0.00 0.00 0.00 0.00 0.00 2.00 2.00 4.00 Engagement Indicator) (Number) Action: This indicator is New IO Table SPACE Page 46 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Monitoring & Evaluation Plan: PDO Indicators Mapped Methodology for Data Responsibility for Data Indicator Name Definition/Description Frequency Datasource Collection Collection This indicator measures the number of individual beneficiaries covered by safety nets programs supported by the Bank. Safety nets programs Beneficiaries of Safety Nets programs Semesterly PIU MIS Data Collection PIU intend to provide social (number) assistance (kind or cash) to poor and vulnerable individuals or families, including those to help cope with consequences of economic or other shock. Beneficiaries of Safety Nets programs Semesterly PIU Data collection PIU - Female (number) Beneficiaries of Safety Nets programs Semesterly PIU Data collection PIU - Cash-for-work, food-for-work and public works (number) Number of poor communities that have Semesterly PIU MIS Data collection PIU access to safety net and nutrition services. Pregnant/lactating women, adolescent girls and/or children under age five- Bi-annually Data collection UNICEF UNICEF reached by basic nutrition services (number) Children under the age of 24 months benefiting from improved infant and Bi-annually Data collection UNICEF UNICEF young child feeding (IYCF) practices (number) Page 47 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Beneficiary households receiving recovery Semestrialy MIS PIU Data collection PIU RSE grants (Number) ME PDO Table SPACE Monitoring & Evaluation Plan: Intermediate Results Indicators Mapped Methodology for Data Responsibility for Data Indicator Name Definition/Description Frequency Datasource Collection Collection Information Number of rehabilitated, reconstructed SEMESTERL Management Data collection PIU and constructed infrastructure sub- Y System and projects project report Information Number of person/days of employment Bi-annually Management Data collection PIU created System and project report Fortunately, Comoros has not faced any disasters in recent years, so the indicator remains at 0. this also influences the number Information Number of households benefiting from of hours worked (see Bi-annually Management Data collection PIU post-disaster activities indicator above) which now System and captures the regular safety project report net beneficiaries, not the disaster response beneficiaries. Beneficiaries with recovery plan for their Semesterly PIU MIS Data collection PIU recovery grant for income-generating activities Page 48 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Beneficiaries having launched income- SEMESTERL PIU MIS Data collection PIU generating activities with their recovery Y grant Female beneficiaries of socio economic ANNUALY PIU MIS Data collection PIU recovery grant The actual numbers of this indicator are expected to Number of children under five years Component float as the growth Bi-annually Data collection UNICEF enrolled in the growth monitoring reports monitoring is not program UNICEF mandatory. Component Number of Community Health Workers Bi-annually Data collection UNICEF reports trained to provide IYCF services UNICEF SEMESTERL PIU MIS Progress report PIU Operational costs of the project Y Operational Number of Operational Audits Annually Audit PIU Audit report implemented (cumulative) Percentage of beneficiary households of Bi- Registration of PIU MIS PIU the Productive Safety Net activities annually beneficiaries registered in the PIU's MIS This indicator measure the satisfaction of beneficiaries related to project activities and involvment. NGO report Survey - Participatory Beneficiaries' feedback related to the Bi-annual NGO - PIU Information could be - PIU M&E monitoring tools (SECAP) project (Citizen engagement Indicator) captured by survey as well as participatory monitoring (SECAP). This is a Citizen Engagement Indicator Page 49 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) This indicator measure the ability of the project to Periodic report on the Grievance Redress PIU (M&E and manage and treat Bi-annual PIU M&E Consolidated Report Mechanism (Citizen Engagement Safeguard) grievance related to the Indicator) project. This is a Citizen Engagement Indicator ME IO Table SPACE Page 50 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) ANNEX 1: Implementation Arrangements and Support Plan Country: Comoros Project: Additional Financign for the Social Safety Net Project 1. Implementation arrangements. The Recipient shall vest responsibility for implementation of the project in the MoHSSP. Based on the organizational chart of this ministry, the DoSSP is the department in charge of social protection and thus will oversee the implementation of the activities under the AF. The PIU shall be responsible for project coordination, implementation, and monitoring and evaluation, as well as administrative, financial management, procurement, and disbursements under the project, including ensuring compliance with safeguards measures and procedures, and preparing the regular progress reports under the project. This change of institutional arrangement, moving from ANACEP to MoHSSP, has been requested by the GoC to ensure quick implementation of activities owing that ANACEP coordinates already multiple projects in Comoros. The arrangement will be functional before project effectiveness, given that the entire project staff will be moved to the new institution Figure 1.1. Organizational chart of MoHSSP Minister Commissariat of General Solidarity; of Inspectorate of Cabinet of General Secretary Social Protection Health Minister and Gender Promotion (a) General General Directorate Hospital El Directorate of Planning Studies, Marouf Health Research and Health Statistics Directorate of Directorate of solidarity and Promotion of social Gender protection (b) Health Project PIU AF-SSN- Project PIU Note: a. Decree 11-139PR of the President of the Comoros on the creation of the Commissariat National. b. Decree 11-201/PR of September 15, 2011, of the President of the Comoros on the creation of the DOSSP and on the role and charge of this directorate. Page 51 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) 2. The implementation support for the project is based on lessons learned from the implementation of the parent project (P150754), and in other countries, as well as on the project’s specific design, complexity, challenges, and risks. The project supervision team will aim to ensure the effective and timely implementation of the project components and of mitigation measures designed to address any early coordination, implementation capacity, technical, or safeguards issues, thus ensuring the achievement of the project’s development objectives. 3. The team composition. The team is aware of the challenges of the project and of the risks that might occur during implementation and is therefore planning to enhance supervision and to ensure that the project team has adequate staffing, particularly during the initial stages of project implementation. Thus, the implementation support plan will focus on building the capacity of the client. The project implementation team will consist of World Bank staff and consultants based in Comoros, Madagascar, Ethiopia and Washington, D.C. and elsewhere. The team will be composed of a task team leader based in Madagascar as well as bank staff and consultants in the areas of social protection, livelihood grant, behavior change, targeting, impact evaluation, job, procurement, safeguards, social accountability, and FM. The team members will be responsible for supporting the implementation of project-specific elements in their areas of expertise. 4. Frequency of implementation support. There will be at least two annual implementation support missions in addition to ongoing and specific technical and fiduciary support and technical assistance in areas such as social protection, economic inclusion, livelihood grant, accompanying measures. Staff and consultants will carry out regular field visits to project sites in the three islands. The implementation support will be enhanced by technical and evaluation studies carried out under the project, such as operational audits, financial audits, process as well as impact evaluations, which will draw from representative samples of project activities, thus ensuring timely and effective feedback to inform any necessary adjustments in project implementation. Based on the supervision missions, at least twice per year the task team will collaborate with clients and other stakeholders in developing a list of actions required to ensure the continued proper implementation of the project. Page 52 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) ANNEX 2: Financial Management Assessment Report Country: Comoros Additional Financing for the Social Safety Net Project Executive Summary 1. The proposed AF will support a three-year program of US$18 million that would expand and maximize the development impact of the parent project. The SSN parent project (P150754)31 of US$6 million is currently implemented by ANACEP. The AF will be managed by the MoHSSP relying on the existing staff implementing the original project within ANACEP. 2. The FM assessment of the MoHSSP was carried out in accordance with the Directives and Policy for IPF and World the Bank Guidance on FM in World Bank IPF Operations issued on February 28, 2017. 3. The conclusion of the assessment is that the MoHSSP FM arrangements will meet the World Bank’s minimum requirements once the mitigation measures are implemented. The mitigation measures will be implemented within three months after the AF agreement signature and will include (a) the update of the administrative, financial, and procurement management manual (including FM procedures) to consider the change in institutional arrangements; (b) the contract renewal of the qualified FM staff involved in the implementation of the parent project; (c) the purchase of adequate accounting software; (d) the recruitment of one internal auditor; and (e) the recruitment of a qualified payment agent for cash transfers. 4. The overall risk rating is substantial mainly due to the risk related to the funds flow given the decentralization and the nature of activities to be financed. Once implemented, the mitigation measures will bring the residual risk to moderate. Summary of the AF activities 5. The AF will mainly finance the economic recovery grants to 10,000 selected poor households (US$10 million); rehabilitation and reconstruction of damaged infrastructure (US$5 million); and strengthening safety net management, coordination, and M&E (US$3 million). 6. The project will operate in the three islands of the Comoros. Country Issues 7. The overall country fiduciary risk is high. 8. A Public Expenditure and Fiscal Management Review was finalized in October 2016 and concluded that there had been a degree of improvement in public financial management (PFM) since the previous assessment done in 2007. However, the Public Expenditure and Financial Accountability (PEFA) 31 P151785 IDA 0320, US$6 million, approved on March 2015 and disbursed at 99 percent. Page 53 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) assessment, done in 201632, also identified several critical gaps in the areas of budget credibility, completeness and transparency, execution, and control. The Government has been pursuing a program of PFM reforms since 2010 and the Ministry of Finance is committed to modernizing the PFM system through the implementation of the PFM Strategy for 2010–2019. The PFM Strategy is a comprehensive response by the authorities to address the weaknesses of their PFM system, as identified by the previous PEFA assessment and recommendations from DPs, including France, the European Union, the International Monetary Fund, and the World Bank. Financial Management Arrangements for the Project 9. The FM procedures manual will be updated by project effectiveness, to reflect the change in the institutional arrangements as well as its impact on the budgeting and planning procedures, the accounting system, and internal controls.  Internal audit. The PIU will recruit a qualified internal auditor no later than three months after project effectiveness. The internal auditor will continuously ensure the effectiveness and efficiency of governance and risk management and control over the project’s activities. A risk-based audit program will be submitted to the World Bank for review. During project implementation, the internal auditor will prepare, after each audit, a report to be submitted to the Project Steering Committee. The reports will be shared with the World Bank.  Financial reporting. The PIU will prepare quarterly unaudited interim financial reports (IFRs) for the project; the report format will be the same as for the parent project. These IFRs will be submitted to the World Bank within 45 days after the end of the quarter to which they relate. The annual financial statements will be prepared using internationally accepted accounting standards. At the end of each fiscal year, the project will prepare annual financial statements, which will be subjected to an external audit.  Staffing. The PIU will renew the contract of the FM staff involved in implementation of the parent project for the AF. For any vacant positions, the MoHSSP will recruit staff on a contractual basis with terms of reference (ToR) agreed with the World Bank.  The FM staff will include a finance manager and an accountant at the central level and one accountant for each regional office.  Flow of funds - Designated Account. The Designated Account (DA) is denominated in local currency KMF) to receive funds from the World Bank. This account will be opened at an acceptable commercial bank to enable payment of eligible expenditures.  Disbursement arrangements. Report-based disbursements will be used. An initial advance up to the ceiling of the DA and representing four months forecasted project expenditures payable through the DA will be made into the DA. Subsequent disbursements will be made 32 This assessment covered the fiscal exercise 2013, 2014 and 2015. Page 54 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) quarterly against submission of IFRs or other documents as specified in the Disbursement and Financial Report Information Letter. Table 2.1: Eligible Expenditures by Category under Additional Financing Category Amount of the Additional Grant Percentage of Expenditures to be Allocated (expressed in SDR Financed inclusive of Taxes]) (1) Goods, works, training, non- 10,900,000 100% consulting services, cash grants and consulting services for Part 1.2 (2) Goods, works, training, non- 2,200,000 100% consulting services, consulting services and operating costs for Part 3 TOTAL AMOUNT 13,100,000  External audit. The project accounts will be audited annually, and the audit report will be submitted to the World Bank no later than six months after the end of each financial year. At the time of this appraisal, there is no overdue audit report for the parent project. The project will comply with the World Bank disclosure policy on audit reports.  Supervision plan. Based on the current overall FM risk, the project will be supervised twice a year. In addition to field visits, supervision will include routine desk-based reviews and FM regular meetings, to ensure that the project’s FM arrangements operate as intended and that funds are used efficiently for the intended purposes.  FM risk assessment and mitigation. The content of these risks is described in Table 2.2. Table 2.2. FM Risk Assessment and Mitigation Risk Risk Mitigating Measures Conditions for Risk Residual Rating Incorporated into Effectiveness Risk Project Design (Y/N) Inherent risk H S Country level. H The GoC is committed to N H The MoHSSP system implement further reforms of the mirrors the central-level country’s PFMs (with support PFM system and its from the DPs). weaknesses, resulting in the risk of lack of transparency and accountability in the use of public funds. Page 55 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Risk Risk Mitigating Measures Conditions for Risk Residual Rating Incorporated into Effectiveness Risk Project Design (Y/N) Entity level. FM H The PIU will renew the contract N S requirements not met; of the well-performing FM staff weak FM capacity. involved in the implementation of the parent project. For the remaining vacant positions, MoHSSP will recruit staff who possess adequate experience and competence based on agreed ToRs. Project level. The S The PIU will comply with the N S resources of the project internal control processes as set may have been out in the FM procedure manual. distracted due to weak The internal audit unit will also control environment. continuously review the adequacy of internal controls and make improvement recommendations. Control Risk Budgeting. Weak S The FM procedures manuals will N S budgetary execution and be updated to spell out the control leading to budgeting and budgetary control budgetary overruns or arrangements to ensure inappropriate use of appropriate budgetary oversight project funds. considering the change in the institutional arrangements. The budget follow-up will be documented in the quarterly IFR. Accounting. Reliable and S The PIU will maintain suitably N S accurate information qualified and experienced FM not provided to inform staff to ensure appropriate management decision. performance of the accounting and FM functions. The financial reporting processes will be facilitated by the use of appropriate computerized accounting systems. Internal control. S The FM procedures manual will N S Business processes, be reviewed to ensure continuing roles, and adequacy over the course of the responsibilities within project life. the project are not clear, The manual will contain all the leading to ineffective key internal control processes control. pertaining to the various project Loss of assets due to low activities. control over regions. Internal control risks at the regional level will be mitigated as part of the internal audit Page 56 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Risk Risk Mitigating Measures Conditions for Risk Residual Rating Incorporated into Effectiveness Risk Project Design (Y/N) engagements. Funds flow. Risk of H The process leading to payment N S misuse and inefficient will be well described in the use of funds; financial manual and monitored inappropriate funds to mitigate the risk of the use of arrangements may lead funds for unintended purposes. to non-financing of the Internal control risks at the project activities. regional level will be mitigated as Errors or frauds in cash part of the internal audit transfers. engagements. Delay in the financial Recruit qualified payment agency reporting by the according to ToRs agreed with payment agency the World Bank. accruing undocumented debtors’ balances. Financial reporting. The S The PIU will maintain qualified N S project may not be able FM staff who possess adequate to produce the financial experience and competence. reports required on time The PIU will purchase a new as required for project computerized accounting monitoring and acquired. The system will enable management. the efficient and timely generation of financial information. Auditing. S The auditor will be recruited N S Delays in submission of early. audit reports The computerized accounting Poor quality of audit system will lead to timely report. generation of IFRs and financial statements. The Comoros does not have a professional accountancy body recognized by IFAC.a Hence, the external auditor recruitment will be opened at the international level and only qualified external auditors will be short-listed. Governance and H Robust FM arrangements and N S accountability. World Bank FM and procurement Possibility of corrupt supervisions. practices including Effective internal control bribes, abuse of arrangements. administrative and political positions, mis- procurement and misuse of funds, and so on are a critical issue. Page 57 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) Risk Risk Mitigating Measures Conditions for Risk Residual Rating Incorporated into Effectiveness Risk Project Design (Y/N) Overall FM risk H S Note: a. IFAC = International Federation of Accountants. Financial Management Action Plan 10. The FM action plan described in Table 2.3 has been developed to mitigate the overall FM risks. Table 2.3. FM Action Plan Remedial action recommended Responsible Completion date Effectiveness Entity Conditions Update the FM procedures manual (as part of the PIU Effectiveness Yes project manual of procedures) to consider the change in the institutional arrangements Renew the contract of the qualified FM staff involved PIU Effectiveness No in the implementation of the parent project Recruit any additional staff required based on the PIU No later than three No ToRs agreed with the World Bank months after effectiveness Recruit a qualified internal auditor PIU No later than three No months after the effectiveness Recruit a qualified payment agent PIU No later than six No months after the effectiveness Purchase adequate accounting software PIU No later than three No months after the effectiveness Page 58 of 59 The World Bank Additional Financing for the Social Safety Net Project (P171633) ANNEX 3: Impact of Cyclone Kenneth Country: Comoros Additional Financing for the Social Safety Net Project Table 3.1. Affected Population and Priority Zone Total Population Affected Population Priority zone 1 209,263 185,879 Priority zone 2 297,926 146,251 Priority zone 3 117,128 13,001 Total 624,316 345,131 Source: DGSC 2019. Table 3.2. Affected Population by Priority Zone and by Island Island Priority Zone 1 Priority Zone 2 Priority Zone 3 Total Anjouan — 72,140 3,071 75,210 Mohéli 6,380 13,502 4,212 24,095 Ngazidja 179,499 60,609 5,718 245,826 Total 185,879 146,251 13,001 345,131 Source: DGSC 2019, author’s calculation. Page 59 of 59