Comoros Financial Sector Development Project (P166193) – Environmental and Social Commitment Plan: VERSION 02 – March 2020 Government of Comoros / Central Bank of Comoros (CBC) Comoros Financial Sector Development Project (P166193) Draft ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP) March 2020 2 | Page Comoros Financial Sector Development Project (P166193) – Environmental and Social Commitment Plan: VERSION 02 – March 2020 ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN 1. The Government of Comoros will implement the Financial Sector Development Project (the Project), with the involvement of the following: Project Implementation Unit (PIU) at the Central Bank of Comoros (CBC). The International Development Association (hereafter the Association) has agreed to provide financing for the Project. 2. The Government of Comoros will implement material measures and actions so that the Project is implemented in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these. 3. The Government of Comoros will also comply with the provisions of any other E&S documents required under the ESF and referred to in this ESCP, such as Environmental and Social Management Plans (ESMP), and Stakeholder Engagement Plans (SEP), and the timelines specified in those E&S documents. 4. The Government of Comoros is responsible for compliance with all requirements of the ESCP even when implementation of specific measures and actions is conducted by the Ministry, agency or unit referenced in 1. above. 5. Implementation of the material measures and actions set out in this ESCP will be monitored and reported to the Association by Government of Comoros as required by the ESCP and the conditions of the legal agreement, and the Association will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project. 6. As agreed by the Association and Government of Comoros, this ESCP may be revised from time to time during Project implementation, to reflect adaptive management of Project changes and unforeseen circumstances or in response to assessment of Project performance conducted under the ESCP itself. In such circumstances, Government of Comoros will agree to the changes with the Association and will update the ESCP to reflect such changes. Agreement on changes to the ESCP will be documented through the exchange of letters signed between the Association and the Government of Comoros. The Government of Comoros will promptly disclose the updated ESCP. 7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the Government of Comoros shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts. 2 | Page Financial Sector Development Support Project (P166193) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MARCH 2020 Summary of the concrete measures and actions to be implemented to mitigate the potential environmental and social risks and effects of the Timeframe Responsible Entity/authority project MONITORING AND REPORTING PREPARATION A REGULAR REPORTING: Responsible Entity: Project Prepare and submit to the Association regular monitoring reports on the Bi-annual report starting Project effectiveness Management Unit (PMU) implementation of (i) ESCP, (ii) environmental, social, health and security date and maintained throughout project Responsible: PMU Coordinator in (ESHS) performance of the project, (iii) status of preparation and implementation collaboration with Environmental and implementation of SEP, (iv) implementation of LMP, and (vi) functioning of Social Manager of the PMU the grievance mechanism(s) Funding: Project Funds B INCIDENTS AND ACCIDENTS NOTIFICATION: Responsible Entity: PMU Promptly notify the Association of any incident or accident related to the Inform the Association within 48 hours after Responsible: PMU Coordinator project or which has, or is likely to have an impact on it, and that has or becoming aware of the incident or accident, in Funding: Project Funds could have a significant adverse effect on the affected communities, the accordance with the Association's tool for public, or the workers included, but without any limit, any allegations of responding to environmental and social gender-based violence, work-related accidents or deaths related to the incidents (World Bank Environment and Social project, labor strikes and social unrest. Incidence Response Toolkit (ESIRT)). Provide enough detail regarding the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, Any incident report should be notified in a and any information provided by any contractor and supervising entity, as time acceptable for the Association, as appropriate while ensuring confidentiality especially for GBV/SEAH related requested. incidents. Subsequently, as per the Association request, prepare a report on the incident or accident and propose any measures to prevent its recurrence. SUMMARY OF ASSESSMENT ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE: Responsible Entity: PMU Establish and maintain an organizational structure made up of qualified The environmental and social expert will be Responsible: PMU Coordinator staff(s) in environment, social, and communication aspects in order to hired before effectiveness. The organizational Funding: Project Funds support the management of social risks. The environmental and social structure will be maintained throughout specialist will also ensure the engagement and mobilization of stakeholders. Project implementation. The Union of the Comoros will mobilize the additional staff required for short- Additional staff or an environmental and social or long-term assignments in accordance with the assessment or with specialist will be hired twice a year before 8 | Page Financial Sector Development Support Project (P166193) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MARCH 2020 Summary of the concrete measures and actions to be implemented to mitigate the potential environmental and social risks and effects of the Timeframe Responsible Entity/authority project institutional needs, including specialists on the following topics: gender- launch of the activities which will be managed based violence and sexual exploitation and abuse (GBV / SEA), working by the staff to be recruited and twice a year conditions (safety and health), and social inclusion. throughout project implementation. 1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT An ESMP check list was developed prior to Responsible Entity: Central Bank of CBC will maintain an E&S due diligence and supervision on the rehabilitation Appraisal. Prior to finalize civil works technical Comoros (CBC) of IT room and generator site in their premises under the Project, which will study to conduct ESMP check list assessment. Responsible: PMU Coordinator include at a minimum the following elements: Funding: Project Funds a. Applicable E&S requirements following the results of ESMP checklist Prior to the preparation of the procurement and included E&S clauses in the bidding document before launching. documents. Supervise b. Incorporate the relevant aspects of the ESMP mitigation measures contractors/subcontractors throughout and the Labor Management Procedures and the ESHS specifications project implementation. of the procurement documents with contractors. Thereafter, it will ensure that contractors comply with the ESHS specifications of their respective contracts. 1.3 NATIONAL PAYMENT COMMITTEE: Responsible Entity: Central Bank of Set up the system after promulgation by the Presidency of the Union of the 30 - 60 days at the latest after project Comoros (CBC) Comoros of the decree appointing members, including representatives of effectiveness date. Responsible: PMU Coordinator local groups of women, of women entrepreneurs as well as civil society Funding: Project Funds organizations from the 2 (two) islands to ensure that women and the entire Operational throughout project population benefiting from the service are significantly represented in the implementation. consultation and implementation of the payment system. 1.4 MANAGEMENT TOOLS AND INSTRUMENTS: ESCP, Draft SEP, Draft LMP and ESST Responsible Entity: PMU Update, adopt, and implement the Environmental and Social risk submitted to the Bank for approval prior to Responsible: PMU Coordinator management tools: project appraisal Funding: Project Funds - Environmental and Social Commitment Plan (ESCP); - Stakeholder Engagement Plan (SEP); Final SEP and LMP to be submitted to the Bank - Labor Management Plan (LMP); prior to project effectiveness. Once approved, - Code of conduct for workers, as part of LMP; the instruments are carried out throughout - Project and worker Grievance Mechanism, as part of LMP; Project implementation. - Environmental and social screening tools (ESST) for the minor rehabilitation of the premises of the Central Bank of Comoros (CBC) to house IT equipment and materials. 8 | Page Financial Sector Development Support Project (P166193) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MARCH 2020 Summary of the concrete measures and actions to be implemented to mitigate the potential environmental and social risks and effects of the Timeframe Responsible Entity/authority project 1.5 MANAGEMENT OF SUPPLIERS AND SERVICE PROVIDERS: Responsible Entity: PMU Incorporate relevant aspects of the SEP, including relevant documents and / During the preparation of bidding documents. Responsible: Procurement team and or pertinent environmental and social screening tools for the minor Environmental and social team of the rehabilitation of the premises of the Central Bank of Comoros (CBC) to house Supervise the firm throughout the PMU IT equipment and materials and worker management procedures, codes of implementation of the project. Funding: Project Funds conduct, into the environmental, social, health, and safety (ESHS) specifications of procurement documents with contractors. Ensure that contractors comply with the ESHS specifications of their respective contracts in a manner acceptable to the World Bank. 1.6 PERMITS, APPROVALS AND AUTHORIZATIONS: Before starting any activity requiring Responsible Entity: PMU environmental and social filtration. Responsible: Environmental and Develop and ensure validation by the Comorian authorities and by the World Bank of the environmental and social screening tools for the minor Social specialist of the PMU Before recruiting firms. rehabilitation of the premises of the Central Bank of Comoros (CBC) to house Funding: Project Funds IT equipment and materials ESS 2: LABOR AND WORKING CONDITION 2.1 LABOR MANAGEMENT PROCEDURES: Responsible Entity: PMU (i) A first draft of the LMP (which include Code of conduct) has been (i) LMP to be finalized prior to project Responsible: Human Resources prepared and submitted to the Association for approval prior to project effectiveness. Once approved, it will be Manager of the project in appraisal. Finalize, adopt, and implement the Labor Management maintained throughout Project collaboration with the Environmental Procedures (LMP). implementation. and Social Manager of the PMU (ii) Codes of Conduct including clauses and sanctions against the use of (ii) Prior to engaging Project workers and Funding: Project Funds GBV/SEAH will be required for all workers, contractors and subcontractors contractors and maintained throughout and their workers. All staff will be required to attend information and Project implementation. awareness sessions on GBV/SEAH throughout project implementation. Induction sessions will be organized for temporary workers before they start work. 2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: Responsible Entity: PMU Establish, maintain and operationalize a grievance mechanism for Project Operational mechanism to be established Responsible: Environmental and workers, as described in the LMP and in accordance with ESS2. before recruiting project workers and to be social manager of the PMU in implemented throughout project implementation 8 | Page Financial Sector Development Support Project (P166193) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MARCH 2020 Summary of the concrete measures and actions to be implemented to mitigate the potential environmental and social risks and effects of the Timeframe Responsible Entity/authority project collaboration with Communication Manager of the PMU Funding: Project Funds 2.3 OCCUPATIONAL HEALTH AND SAFETY (OHS) MEASURES Responsible Entity: Environmental Develop and implement occupational health and safety measures (OHS), Prior to engaging related activities and and social team of the PMU when needed. thereafter implemented throughout Project Responsible: Environmental and implementation. social manager of the PMU Funding: Project Funds 2.4 PREPARATION AND RESPONSE TO EMERGENCY SITUATION: Responsible Entity: Environmental As part of the OHS measures specified in section 2.3, include emergency Prior to engaging related activities and and social team of the PMU preparedness and response systems. Ensure that workers and contractors thereafter implemented throughout Project Responsible: Environmental and are trained, and the plan is implemented. implementation. social manager of the PMU Funding: Project Funds ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT: Measures for the rational use of resources and pollution prevention and Responsible Entity: Environmental management will be set out in the EMP check list. BCB will take appropriate Prior to engaging related activities and and social team of the PMU mitigation measures to minimize the impact of the project on the thereafter implemented throughout Project Responsible: Environmental and environment and the natural resources, in accordance with ESS 3. Solid Waste implementation. social manager of the PMU Management Plan from civil works will be implemented by the enterprise. Funding: Project Funds Six months at the latest after project Conduct an energy audit and prepare an energy efficiency plan to address effectiveness date. Action plans adopted resource efficiency related to the operation of the data center. throughout project implementation. ESS 4: POPULATION HEALTH AND SAFETY 8 | Page Financial Sector Development Support Project (P166193) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MARCH 2020 Summary of the concrete measures and actions to be implemented to mitigate the potential environmental and social risks and effects of the Timeframe Responsible Entity/authority project 4.1 RISKS OF GENDER-BASED VIOLENCE, EXPLOITATION AND SEXUAL ABUSE: Submit the GBV sensitization Plan to the Responsible Entity: Environmental The project will prepare, adopt and implement G BV sensitization activities. Association for approval during the first year and social team of the PMU The project will ensure that the code of conduct is included into all bidding of the project, and once approved, Responsible: Environmental and documents and all worker’s contracts. The project will ensure that GM implementation throughout the Project social manager of the PMU related to GBV is operationalized for the project implementation. Funding: Project Funds ESS 5: ACQUISITION OF LAND, RESTRICTIONS ON THE USE OF LAND AND INVOLUNTARY RESETTLEMENT NOT RELEVANT ESS 6: PRESERVATION OF THE BIODIVERSITY AND SUSTAINABLE MANAGEMENT OF BIOLOGICAL NATURAL RESOURCES NOT RELEVANT ESS 7: INDIGENOUS PEOPLE/TRADITIONAL LOCAL COMMUNITIES OF SUB-SAHARAN AFRICA HISTORICALLY DISADVANTAGED NOT RELEVANT ESS 8: CULTURAL HERITAGE NOT RELEVANT ESS 9: FINANCIAL INTERMEDIATES NOT RELEVANT ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE 8 | Page Financial Sector Development Support Project (P166193) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MARCH 2020 Summary of the concrete measures and actions to be implemented to mitigate the potential environmental and social risks and effects of the Timeframe Responsible Entity/authority project 10.1 PREPARATION AND IMPLEMENTATION OF THE STAKEHOLDER Responsible Entity: Environmental MOBILIZATION PLAN: (i) Final SEP to be submitted the Association for and social team of the PMU (i) Draft SEP has been submitted for prior review and approval of the prior review and approval prior to project Responsible: Responsible of the Association prior to project appraisal. Finalize, adopt, and implement the effectiveness. Once approved, the SEP is environmental, social and Stakeholder Engagement Plan (SEP). carried out throughout Project communication aspects of the PMU (ii) Update, adopt and implement the SEP and ensure that it is integrated into implementation. Funding: Project Funds the project management system, and that sufficient staff and budget are (ii) SEP to be updated periodically, as required, allocated to its implementation. throughout the life of project. 10.2 PROJECT GRIEVANCE MECHANISM: Responsible Entity: Environmental (i) Grievance Mechanism has been submitted for prior review and approval of (i) Finalized prior to project effectiveness. Once and social team of the PMU the Association part of the draft SEP prior to project appraisal. Finalize, adopt, approved, updated regularly throughout Responsible: Responsible of the and implement the grievance mechanism (GM) as part of the SEP. project implementation. environmental, social and (ii) Adopt, update, maintain and operate a GM, as described in the SEP. (ii) GM to be updated periodically, as required, communication aspects of the PMU throughout the life of project. Funding: Project Funds 10.3 MOBILIZATION OF STAKEHOLDERS RELATED TO THE NATIONAL PAYMENT Responsible Entity: Environmental BOARD MOBILIZATION ACTIVITIES: Before the mobilization meetings of the and social team of the PMU Hold regular consultations with women's associations and regular National Payment Board Responsible: PMU Coordinator consultations with civil societies in Anjouan and Mohéli islands. To be maintained throughout project Funding: Project Funds Initiate consultations upon request of the association. implementation CAPACITY SUPPORT (TRAINING) 8 | Page Financial Sector Development Support Project (P166193) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN (ESCP) MARCH 2020 Summary of the concrete measures and actions to be implemented to mitigate the potential environmental and social risks and effects of the Timeframe Responsible Entity/authority project CS1 Organize training for communities in order to increase awareness of Prior to commencement of relevant project Responsible Entity: Environmental environmental and social risks and impacts and mitigation measures, activities and throughout project and social team of the PMU including training on (non-exhaustive list): implementation. Responsible: Responsible of the • Stakeholder engagement environmental, social and • Social review of sub-projects communication aspects of the PMU • Environmental, Health and Safety for workers and for communities Funding: Project Funds • Emergency preparedness and response • Mitigation of risks of gender-based violence • Training on the inclusion of vulnerable and disadvantaged groups • Complaints / grievances management as described under SEP • Implementation, monitoring and reporting of compliance with workforce management procedures, etc. • Awareness and prevention of transmitted diseases: HIV / AIDS / STD • Awareness of GBV / SEA and child protection • World Bank Environmental and Social Framework CS2 Implement the training of Project workers in order to improve awareness of Before the start of project activities and / or Entity in charge: Environmental and the risks and mitigate the impacts on the local communities concerned by infrastructure construction works, and social team of the PMU the installation of ATM shelter infrastructure and merchant points, as throughout the implementation of the project. Responsible: Responsible of the defined in the GBV Action Plan. environmental, social and communication aspects of the PMU Funding: Project Funds 8 | Page