The World Bank Expanding Opportunities for Learning (P166059) Environmental and Social Review Summary Appraisal Stage (ESRS Appraisal Stage) Public Disclosure Date Prepared/Updated: 05/07/2019 | Report No: ESRSA00136 May 07, 2019 Page 1 of 12 The World Bank Expanding Opportunities for Learning (P166059) BASIC INFORMATION A. Basic Project Data Country Region Project ID Parent Project ID (if any) Djibouti MIDDLE EAST AND NORTH P166059 AFRICA Project Name Expanding Opportunities for Learning Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date Education Investment Project Financing Borrower(s) Implementing Agency(ies) Ministry of Education and Vocational Training (Ministere de l'Education Nationale et de la Formation Public Disclosure Proposed Development Objective(s) The project development objective is to increase equitable access to basic education, improve teaching practices, and strengthen MENFOP's management capacity. Financing (in USD Million) Amount Total Project Cost 27.80 B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] The project aims to address the following key sectoral challenges: (a) Early childhood education (ECE) provision is limited and, where available, at a nascent stage of development. It is constrained by a lack of classroom space and dedicated or qualified preschool teachers. Therefore, the project proposes to support the regulatory and quality aspects of ECE provision, teacher professional development and materials provision and establishment of dedicated pre-school classrooms (through construction or repurposing of existing spaces); (b) access and retention: the shortage May 07, 2019 Page 2 of 12 The World Bank Expanding Opportunities for Learning (P166059) of infrastructure in urban areas results in the curtailing of enrollments at the beginning of each school year, large class sizes and double shifting. Out-of-school rates are much higher in rural areas than in Djibouti-ville due in part to insufficient numbers of schools. Distance from school, poverty, and opportunity costs deter young children from attending, especially for girls wanting to attend lower secondary education. As a result, the project proposes to construct new or expand existing schools in strategic locations and explore innovative ways to provide educational services to rural areas, with a particular focus on girls’ access to education opportunities; (c) learning and assessing: The quality of education is a central concern as shortages of key quality inputs (learning materials, teacher guides, and development opportunities) impede education quality and teachers need to develop more appropriate pedagogical practices but also receive sufficient professional in-school support. Also, the introduction of Information and Communication Technologies (ICT) into the classroom requires guidance. Another challenge is the lack of data especially related to student performance and teacher pedagogical and content knowledge skills that would allow providing targeted corrective measures. The project aims to improve teacher professional development and build on the government’s current system of centralized training to a decentralized and continued support/mentoring approach. It will also explore ways to strengthen the existing assessments (year 2 and 5 national exams – OTI) and provide capacity building for ministry staff from central to school levels to be able to interpret data and act on it. D. Environmental and Social Overview D.1. Project location(s) and salient characteristics relevant to the ES assessment [geographic, environmental, social] The project development objective is to increase equitable access to basic education, improve teaching practices, and strengthen MENFOP management capacity. Project investments will cover both urban and rural settlements of the entire country, including high income and low income neighborhoods. At least 200 classrooms will be built all over the Public Disclosure country, through the construction of new schools, extensions to schools, and/or through the rehabilitation of existing classrooms. School canteens will also be added to rural schools to encourage attendance. The new facilities will be located within the compounds of existing schools or on public land; at national, regional and local level. The project development objective is to increase equitable access to basic education, improve teaching practices, and strengthen MENFOP management capacity. Project investments will cover both urban and rural settlements of the entire country, including high income and low income neighborhoods. Sub-Components 1.3 and 2.1 may present risks/impacts on Occupational and Community health and safety especially on schoolchildren and school employees. These components are likely to induce also land acquisition for rehabilitation or construction of new school facilities, including canteens, latrines and water points and involve labor in the civil works. Djibouti is characterized by a desert climate with sporadic rainfall. The dry season, very hot where temperatures are generally above 40 ° C in the day weighs heavily on the degradation of the environment and on water resources. The scarcity of water resources and their poor quality particularly in Djibouti city is a severe constraint for the population and its health. The project by funding the construction/rehabilitation of these school facilities (water points, latrines, canteens) aims to mitigate some of these climatic constraints faced particularly by the stakeholders in education sector. The climate change and disaster screening instrument reveals that the country is also susceptible to flooding and extreme weather events. All these activities may cause risks/impacts and are relevant to the ESSs. D. 2. Borrower’s Institutional Capacity The Ministry of Education, at the national level, has the overall project preparation and implementation responsibilities. Within the ministry, an established and dedicated office, the Bureau d’exécution des projets (Project Implementation office), will carry out the planning, preparation and execution of the various project activities. At provincial and local levels, school districts and schools, will be the implementing agencies. The Project implementing Office has a good experience in implementing Bank funded projects. However, a lack of capacity in managing May 07, 2019 Page 3 of 12 The World Bank Expanding Opportunities for Learning (P166059) specifically E&S risks is noted at national level as well as at at provincial level. The Project implementation office has no trained and dedicated focal point to ensure E&S compliance. An E&S focal point, with qualifications acceptable to the World Bank, will be assigned in the Project implementation Office to monitor the implementation of environmental and social risks management plans, to ensure compliance with the E&S requirements, including reporting. Provincial E & S focal points will also be designated to closely monitor the implementation of these E&S aspects with various stakeholders, including future contracted companies, as well as periodic reporting to the central E&S focal point. The ESCP will support Project implementation Office Capacity building. II. SUMMARY OF ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS A. Environmental and Social Risk Classification (ESRC) Moderate Environmental Risk Rating Moderate The Environmental and social risks of the project are deemed moderate. Project activities will be confined to small civil works interventions (rehabilitation of school classes and construction of school buildings) within the facilities of existing schools or on confined public land. Other Risks/impacts are linked to operational phase of canteens, water points and latrines funded by the project. The project is classified as Moderate Risk as the potential adverse risks and impacts on human populations and/or the environment are not likely to be significant and can be easily mitigated in a predictable manner. Social Risk Rating Moderate Public Disclosure The project development objective is to increase equitable access to basic education, improve teaching practices, and strengthen MENFOP management capacity. Project social risks are deemed moderate, although there is a contextual risk, given that the PIU has yet to have a dedicated and trained focal point to ensure E&S compliance. “At least 200 classrooms will be built through the construction of new schools, extensions to schools, and/or through the rehabilitation of existing classrooms. School canteens will also be added to rural schools to encourage attendance.” The targeted school facilities will be located within the compounds of existing schools or on public land, as has been the practice for the last seven years, at least. Thus, the rehabilitation or construction of new school facilities, will require public land acquisition within existing facilities, thus those operations are highly unlikely to induce involuntary resettlement, causing physical or economic displacement. However, since specific construction sites have yet to be selected and screened, an ESMF and an RPF have been prepared to address potential environmental and social risks. During implementation, the WB will conduct its due diligence to ensure project compliance with the various standards applied. Labor influx is not expected, as the project will procure civil works services from local contractors, given the small size and simplicity of the works. A stakeholder engagement plan has been prepared to strengthen project ownership and prevent potential conflicts between beneficiaries, it includes a grievance redress mechanism. Additionally, project activities to be implemented have already been carried out in previous Bank financed projects, without inducing adverse social impacts, and contextually, the overall political economy framework is still the same. The new project will build on the experience of a Bank financed project which closed June 30, 2018. B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered B.1. General Assessment May 07, 2019 Page 4 of 12 The World Bank Expanding Opportunities for Learning (P166059) ESS1 Assessment and Management of Environmental and Social Risks and Impacts Overview of the relevance of the Standard for the Project: Rational for ESS1: Project investments have a country wide coverage and will include, urban and rural settlements, high and low income neighborhoods. Operations will involve civil works, contractors, labor, and land acquisition for building of new school facilities. “At least 200 classrooms will be built through the construction of new schools, extensions to schools, and/or through the rehabilitation of existing classrooms. School canteens will also be added to rural schools to encourage attendance.” The targeted school facilities will be located within the compounds of existing schools or on public land, as has been the practice for the last seven years, at least. Thus, the rehabilitation or construction of new school facilities, will require public land acquisition, but those operations are highly unlikely to induce involuntary resettlement, causing physical or economic displacement. However, since specific construction sites have yet to be selected and screened, an ESMF and an RPF have been prepared to address potential environmental and social risks. During implementation, the WB will conduct its due diligence to ensure project compliance with the various ESF standards applied. Project design, particularly component 1. (Establishing foundations for quality preschool education, and component 2 (Expanding access to and improving retention in basic education), and component component 3. (Building capacity to support teaching and learning) involve multiple stakeholders, at international, national, regional and local level. Key stakeholders include but are not limited to: i) international donors; ii) the ministry of education; iii) school administrations at national, regional and local level; iii) the teachers as a collective and as individuals; parents as a collective and individuals; students as a collective and individuals (vulnerable groups, girls and refugees); civil society; and potential project affected persons (by land acquisition or economic displacement) should there be any, as both land acquisition and economic displacement are highly unlikely to be induced by the project. The majority of stakeholders are constituted of various beneficiaries and Public Disclosure other interested parties (OIPs). The client has prepared a Stakeholder Engagement Plan (SEP) prior to Appraisal. The SEP includes both other interested parties (OIPs), various beneficiaries and directly impacted project affected persons (PAPs), including disadvantaged and vulnerable groups. Components 1 and 2, (1. Establishing foundations for quality preschool education, and component 2 (2. Expanding access to and improving retention in basic education), will involve civil works and acquisition of public land reserved for the facilities, thus, those operations (rehabilitation or construction of new school facilities) are highly unlikely to induce involuntary resettlement, causing physical or economic displacement. Components 1 and 2, (1. Establishing foundations for quality preschool education, and component 2 (2. Expanding access to and improving retention in basic education), will involve civil works and acquisition of public land reserved for the facilities, thus, those operations (rehabilitation or construction of new school facilities) are highly unlikely to induce involuntary resettlement, causing physical or economic displacement. Impacts/risks under Sub-components 1.3 and 2.1: Increasing access to preschool and increasing access to schooling will include construction of new/ repurposing of existing classrooms and equipping them with necessary inputs (furniture and learning materials) and construction of canteens, water points and latrines, may generate Risks/impacts that are mainly linked to construction phase and may include Occupational Health and Safety hazards, Community Health and Safety risks especially related to school children and some Environmental risks due to solid waste generation, noise and vibration, wastewater discharges and dust. Other Risks/impacts during operational phase are linked to Community Health and safety especially to school children and school employees using canteens, water points and latrines. The risk is Moderate. The ESMF will include a negative list of subprojects that will not be eligible for financing, which are the ones with a potential substantial/high risk (e.g. in critical habitats or ecosystems) given that the overall project risk is moderate. The ESMF will also contain provisions to ensure labor aspects, including child labor and labor influx, are properly addressed in the documents prepared during project implementation, including construction phase ESMPs, bidding documents, and civil works contracts. The ESMF will May 07, 2019 Page 5 of 12 The World Bank Expanding Opportunities for Learning (P166059) include a negative list of subprojects that will not be eligible for financing, which are the ones with a potential substantial/high risk (e.g. in critical habitats or ecosystems) given that the overall project risk is moderate. The ESMF will contain provisions to ensure labor aspects, including child labor and labor influx, are properly addressed in the documents prepared during project implementation, including construction ESMPs, bidding documents, and civil works contracts. The ESMF will ensure proper consultation with project beneficiaries. The ESMF will contain Guidelines to comply with international norms and standards regarding hygiene and health of school children and other users in canteens and use of water points and latrines. The implementing agency will prepare construction ESMPs during project implementation. The implementing agency will prepare detailed Guides for management of Environmental Health and Safety in Canteens, water points and Latrines. The ESMF will be part of the Project Operations Manual (OM). The ESMF will provide Guidance to prepare specific Guide concerning the management during operational phase for canteens, water points and latrines The ESMF will ensure proper consultation with project beneficiaries. Implementing agency will prepare construction ESMPs during project implementation. The ESMF will be part of the Project Operations Manual (OM). The RPF will address potential land acquisition issues, compensation for lost assets or access to livelihood resources, social inclusion and exclusion issues, stakeholder engagement and grievance redress mechanisms. ESS10 Stakeholder Engagement and Information Disclosure Rational for ESS10 : Project design, particularly component 1. (Establishing foundations for quality preschool education, and component 2 (Expanding access to and improving retention in basic education), and component component 3. (Building capacity to support teaching and learning) involve multiple stakeholders, at international, Public Disclosure national, regional and local level. Key stakeholders include but are not limited to: i) international donors; ii) the ministry of education; iii) school administrations at national, regional and local level; iii) the teachers as a collective and as individuals; parents as a collective and individuals; students as a collective and individuals (vulnerable groups, girls and refugees); civil society; and potential project affected persons (by land acquisition or economic displacement) should there be any, as both land acquisition and economic displacement are highly unlikely to be induced by the project. The majority of stakeholders are constituted of various beneficiaries and other interested parties (OIPs). The client has prepared a Stakeholder Engagement Plan (SEP) prior to Appraisal. The SEP includes both other interested parties (OIPs), various beneficiaries and directly impacted project affected persons (PAPs), including disadvantaged and vulnerable groups. The PMU will put in place, as part of the ESMF, procedures for external communications on environmental and social matters proportionate to the risks and impacts of project activities consistent with the requirements of ESS10. The ESMF will also include a project-level grievance mechanism to respond to public enquiries and concerns. B.2. Specific Risks and Impacts A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions Environmental and social risks/impacts related to OHS are expected to be low, for the following reasons. Labor influx, is not expected. The project is likely to use local contractors, and local labor, for the rehabilitation/construction of school facilities. The type of labor will include: manual labor, masons, electricians, painters and plumbers. Direct workers in the project management unit (PMU) will be civil servants, others will include contractors with their manual May 07, 2019 Page 6 of 12 The World Bank Expanding Opportunities for Learning (P166059) labor. A rough estimate suggests that about 4,000 contracted workers (direct worker and primary supply workers) could be hired over the four years of project implementation given that, at least 200 classrooms will be built through the construction of new schools, extensions to schools, and/or through the rehabilitation of existing classrooms. School canteens will also be added to rural schools to encourage attendance. Risks related to OHS could be induced by minor civil works. OHS measures will address, identify potential hazards to workers, develop preventive and protective measures, and propose training program. The PMU of the Ministry of Education, will prepare a labor management procedure and contractors will prepare labor management plans. These procedures will set out the way project workers will be managed in accordance with the requirements of national laws and ESS2. The procedures will include requirements for: working conditions and terms of employment; nondiscrimination and equal opportunity; worker’s organizations; child labor and minimum age; forced labor; grievance mechanisms; maintenance of training records and documentation and reporting of occupational accidents, diseases and incidents, emergency prevention and remedies for injuries, disability and disease. The Ministry of Education will incorporate the requirements of ESS2 into contractual agreements with contractors together with appropriate noncompliance remedies. The ESMF will assess related OHS risks/impacts and will identify all mitigation measures to be incorporated into labor management procedure and contractors labor management plans. ESS3 Resource Efficiency and Pollution Prevention and Management The project may presents risks/impacts linked to the management of construction wastes generated, dust emission, noise and vibrations. Construction ESMPs will be prepared before construction and will be part of bidding documents. Other Risks/impacts during operational phase linked to the management of solid wastes and water discharge Public Disclosure pollution from canteens and latrines. Specific Guides will be prepared during project implementation regarding hygiene and health of school children and other users in canteens and latrines concerning to comply with international norms and standards. The ESMF will assessed all these risks/impacts and mitigate them though ESMPs and specific Guides to be prepared during project implementation. ESS4 Community Health and Safety Communities health and safety issues are associated to typical risks/impacts of construction sites as, dust, noise and vibrations, wastes and labor influx. The project is funding rehabilitation/construction of classrooms that will be accessed by school children, school employees and some times other persons. Some risks/impacts are identified concerning public potential exposure to operational accidents or natural hazards, including extreme weather events. Construction ESMPs will be prepared before construction and will be part of bidding documents. The project is funding construction of canteens, water point and latrines. Risks/ impacts are identified concerning Community Health and Safety during operation phase . Specific Guides will be prepared during project implementation regarding hygiene and health of school children and other users in Canteens (quality of food and beverage), Water points (quality of drinkable water) and latrines (cleanliness) to comply with international norms and standards. The project will also apply the concept of universal access to the design and construction of such new classrooms where technically and financially feasible to take in account the needs of handicapped or limited mobility people accessing the schools and other facilities The ESMF will assess all these risks/impacts and mitigate them through ESMPs and specific Guides to be prepared during project implementation. May 07, 2019 Page 7 of 12 The World Bank Expanding Opportunities for Learning (P166059) ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement Rational for ESS5 : Components 1 and 2, (1. Establishing foundations for quality preschool education, and component 2 (2. Expanding access to and improving retention in basic education), "At least 200 classrooms will be built through the construction of new schools, extensions to schools, and/or through the rehabilitation of existing classrooms. School canteens will also be added to rural schools to encourage attendance." These investments will involve civil works and acquisition of public land reserved for the facilities, as has been the practice for the last seven years, at least. Thus, the rehabilitation or construction of new school facilities, are highly unlikely to induce involuntary resettlement, causing physical or economic displacement. However, since specific construction sites have yet to be selected and screened, an RPF have been prepared to address potential social risks. During implementation, the WB will conduct its due diligence to ensure project compliance with the various ESF standards applied. Subsequent RAP or RAPs will be prepared during project implementation, as need be. The Bank will carry out its due diligence to ensure Project ESF compliance. Estimates of potential quantity of land to be potentially affected, and likewise number of project affected persons (PAPs), seem unrealistic, will be a fiction, given the unlikely acquisition of land. In fact, to avoid land acquisition is the client's strategy in building schools. ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources This ESS is not expected to be relevant to this project. Project is not allowing interventions in natural critical habitats or ecosystems. Public Disclosure ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities There are no communities in Djibouti that fulfill ESS definition of indigenous people. ESS8 Cultural Heritage Although project activities will invest in human capital and physical assets, those operations will be carried out within the framework of existing school premises and will be limited in space and time. The physical activities will be confined to small civil works interventions (rehabilitation of school classes and construction of school buildings) within the physical space of existing schools or on confined public land. They are unlikely to affect built heritage, intangible heritage, or natural heritage. Nevertheless, through the ESMF, the PIU of the Ministry of Education, will determine the potential risks and impacts of the proposed activities of the project on cultural heritage and will screen out subprojects with risks/impacts on Cultural Heritage. The ESMF will develop a chance find procedure to be followed during project implementation. ESS9 Financial Intermediaries This ESS is not expected to be relevant to this project. The project is unlikely to procure any services of through financial intermediaries. C. Legal Operational Policies that Apply OP 7.50 Projects on International Waterways No May 07, 2019 Page 8 of 12 The World Bank Expanding Opportunities for Learning (P166059) OP 7.60 Projects in Disputed Areas No III. BORROWER’S ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) DELIVERABLES against MEASURES AND ACTIONs IDENTIFIED TIMELINE ESS 1 Assessment and Management of Environmental and Social Risks and Impacts MENFOP will Prepare ESMF and RPF to identify environmental and social risks and impacts of the Project 04/2019 and appropriate mitigation measures. MENFOP will Develop and implement site specific Environmental and Social Management Plans (ESMPs) 11/2019 and Resettlement Action Plans (RAPs) MENFOP will Establish an organizational structure with qualified staff to support the management of E&S risks, including an E&S focal point responsible for the day-to-day implementation of the ESMF and 11/2019 RPF. MENFOP will develop and implement procedures for managing contractors and subcontractors.incorporate the obligation of preparing an Environmental Health and Safety (EHS) plan Public Disclosure into the contractual agreements with contractors and subcontractors together with appropriate 11/2019 noncompliance remedies Environmental and Social clauses will be included in all bidding documents, with an obligation to prepare a construction phase ESMP including an Environmental Health and Safety (EHS) plan into contractual a • Obtain or assist in obtaining the permits, consents and authorizations that are applicable to the Project from relevant national authorities • Comply or cause to comply, as appropriate, with the conditions established in these permits, consents and authorizations throughout Project implementation. • Comply 11/2019 with the conditions established in these permits, consents and authorizations throughout Project implementation. . MENFOP will Develop and prepare an Environmental and Social Capacity building Plan that includes a 11/2019 clear timeline and budget for MENFOP and other stakeholders MENFOP will submit semiannual E&S performance reports to the World Bank on ESMF/RPF 03/2020 implementation, and subsequent ESMPs and RAPs, if any. ESS 10 Stakeholder Engagement and Information Disclosure Prepare and disclose a Stakeholder Engagement Plan (SEP). 04/2019 ESS 2 Labor and Working Conditions May 07, 2019 Page 9 of 12 The World Bank Expanding Opportunities for Learning (P166059) MENFOP will prepare and implement a labor management procedure (LMP) including Occupational 04/2019 Health and Safety (OHS) measures and grievance mechanisms for its own workforce. Contractors will prepare and implement Labor Management plans including OHS measures, project workers training to heighten awareness of risks and to mitigate impacts on local communities and 11/2019 internal grievance mechanism for their own workforce As part of the OHS measures specified in 2.2, include measures on emergency preparedness and 11/2019 response, ESS 3 Resource Efficiency and Pollution Prevention and Management The contractor will develop and implement measures and actions in EHS plan to manage waste and 11/2020 hazardous materials. ESS 4 Community Health and Safety The contractor will Develop and implement measures and actions in EHS plan to manage risks related to Community Health and Safety including traffic and road safety, Labor influx, GBV, SEA and risks 11/2020 related to the use of security personnel 1. Preparation of a Guide for Hygiene / Health / Environment risk management in canteens 2. Preparation of a Guide for the proper use and maintenance of water points 3. Preparation of a Guide 11/2019 Public Disclosure for the proper use and maintenance of Latrines Conduct training for the community designed to heighten awareness of risks and to mitigate impacts 11/2019 specified in this section. This will be conducted as part of the Stakeholder Engagement Plan ESS 5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement Assess the nature and degree of expected land acquisition and involuntary resettlement under the 04/2019 Project including the preparation of the RPF Develop and implement resettlement plans (RPs) consistent with the requirements of the RPF and ESS5. 11/2019 Ensure that monitoring and reporting on land acquisition and resettlement activities are conducted 11/2019 separately or as part of regular reporting. ESS 6 Biodiversity Conservation and Sustainable Management of Living Natural Resources ESS 7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities ESS 8 Cultural Heritage May 07, 2019 Page 10 of 12 The World Bank Expanding Opportunities for Learning (P166059) Chance find procedures will be incorporated into the bidding documents for contractors and sub- 11/2019 contractors. ESS 9 Financial Intermediaries B.3. Reliance on Borrower’s policy, legal and institutional framework, relevant to the Project risks and impacts Is this project being prepared for use of Borrower Framework? In Part Areas where “Use of Borrower Framework” is being considered: 1. Traditional grievance redress mechanisms at local community level, as recognized by Djibouti legal framework. 2. Land tenure laws. 3. Labor laws. IV. CONTACT POINTS World Bank Contact: Mohamed Adnene Bezzaouia Title: Environmental Specialist Public Disclosure Telephone No: 5714+3047 Email: mbezzaouia@worldbank.org Contact: Eloise Sophie Fluet Title: Senior Social Development Specialist Telephone No: 5220+32061 / Email: efluet@worldbank.org Contact: Antoine V. Lema Title: Senior Social Development Specialist Telephone No: 473-5797 Email: alema@worldbank.org Borrower/Client/Recipient Implementing Agency(ies) Ministry of Education and Vocational Training (Ministere de l'Education Nationale et de la Implementing Agency: Formation V. FOR MORE INFORMATION CONTACT May 07, 2019 Page 11 of 12 The World Bank Expanding Opportunities for Learning (P166059) The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects VI. APPROVAL Task Team Leader(s): Simon Thacker, Samira Halabi Public Disclosure May 07, 2019 Page 12 of 12