government of ghana/ministry of education ghana...

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Government of Ghana/Ministry of Education

Ghana Accountability for Learning Outcomes

Project, P165557

ENVIRONMENTAL and SOCIAL

COMMITMENT PLAN (ESCP)

April, 2019

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Government of Ghana/Ministry of Education

Ghana Accountability for Learning Outcomes Project, P165557

ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN

1. Government of Ghana is planning to implement the Ghana Accountability for Learning Outcomes Project (the Project). The Ministry of Education (MOE) and the Ghana Education Service (GES) are the main implementing agency with the involvement of the National Council for Curriculum and Assessment (NaCCA), National Inspectorate Board (NIB) and National Teaching Council (NTC). The Association has agreed to provide financing for the Project.

2. Government of Ghana will implement material measures and actions so that the Project is implemented in accordance with the World Bank Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out a summary of the material measures and actions.

3. Where the ESCP refers to specific plans or other documents, whether they have already been prepared or are to be developed, the ESCP requires compliance with all provisions of such plans or other documents. In particular, the ESCP requires compliance with the provisions set out in Environmental and Social Management Framework, Stakeholder Engagement Plan and Resettlement Policy Framework that that have been developed for the Project.

4. The table below summarizes the material measures and actions that are required as well as the timing of the material measures and actions. Government of Ghana through the MOE and the GES 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 Bank by the Government of Ghana through the MOE and the GES as required by the ESCP and the conditions of the legal agreement, and the Bank will monitor and assess progress and completion of the material measures and actions throughout implementation of the Project.

6. As agreed by the Bank and Government of Ghana through the MOE and the GES, 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 Ghana through the MOE and the GES will agree to the changes with the Bank 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 Bank and the Ministry of Finance of the Government of Ghana. The Government of Ghana through the MOE and the GES will promptly disclose the updated ESCP. Depending on the project, the ESCP may also specify the funding necessary for completion of a measure or action.

7. Where Project changes, unforeseen circumstances, or Project performance result in changes to the risks and impacts during Project implementation, the Government of Ghana shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts, which may include environmental, health, and safety impacts, labor influx, gender-based violence.

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Ghana Accountability for Learning Outcomes Project (GALOP) (P165557) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN DATE: March 25, 2019

Summary of the Material Measures and Actions to Mitigate the Project’s Potential Environmental and Social Risks and Impacts

Timeframe

Responsibility / Authority and Resources/Funding Committed

Date of Completion

ESCP Monitoring and Reporting REGULAR REPORTING:

The Project will submit regular reports in form and substance acceptable to the Bank, providing details of: (i) status of implementation of the ESCP; (ii) conditions, if any, which interfere or threaten to interfere with the implementation of the ESCP; and (iii) corrective and preventive measures taken or required to be taken to address such conditions.

Six-monthly throughout Project implementation.

MOE/GES Project Management unit, funding from project budget

Throughout the Project life time.

INCIDENTS AND ACCIDENTS NOTIFICATION: The Project will promptly notify any incident or accident related or having an impact on the Project which has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers including situations of fatalities or serious bodily harm and incidents of Gender Based Violence. Project will ensure that contractors and subcontractors report on any occurrence of death by accident or injuries from moving parts of equipment, tractors, grinders, and moving heavy materials.

Promptly after taking notice of the incident or accident. This would be done 48 to 72 hours of the Project Management Unit becoming aware of the incident/accident.

MOE/GES Project Management unit, Contractors funding from project budget

Throughout the Project life time

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Timeframe


Date of Completion

SUMMARY ASSESSMENT

ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS 1.1 ORGANIZATIONAL STRUCTURE:

Since 2017, the MOE engaged two Environment and Social Safeguards officers as Safeguard Team (i) The Environmental Officer is seconded from the Environmental Protection Agency (EPA) and (ii) the Social Safeguard Officer is under an extended term consultancy service. These officers currently work on all education projects including the GALOP. The project will add focal persons for the MOE special education unit to handle the other social issues including GBV and disability inclusion. The safeguards team forms part of the project management team/unit reporting directly to the Chief Director of the MOE. The project will maintain the environmental and social officers as necessary throughout Project implementation.

Safeguards Team already in place prior to appraisal.


Prior to commencing of the Projects activities

1.2 ENVIRONMENTAL AND SOCIAL ASSESSMENT The project has developed Environmental and Social assessments (i.e., ESMF, RPF and Social Assessment). The ESMF and RPF have identified the environmental and social risks and impacts of the Project and were disclosed prior to appraisal.

ESMF, RPF and Social Assessment,) have been carried out and disclosed prior to appraisal.


Disclosed prior to appraisal and E&S screening and assessment completed prior to Subprojects activities. The project will develop and implement specific ESMPs and RAPs

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Timeframe


Date of Completion

The ESMF includes a screening tool that will help in identifying potential environmental and social risks & impacts of subproject activities. The project will develop and implement specific ESMPs and RAPs as required when sub-project locations are known.

for the sub-projects prior to civil works.

1.3 MANAGEMENT TOOLS AND INSTRUMENTS: Environmental and Social Assessment process for subprojects will be done during Subprojects screening. Using the E&S screening tool the project will identify the potential risks of subprojects and determine which environmental assessment instrument such as Environmental and Social Management Plans (ESMPs), Resettlement Action Plan that may be required.

Prior to civil works Throughout project implementation

Project safeguard Team

Prepared and disclosed prior to Subprojects activities

1.4 MANAGEMENT OF CONTRACTORS: The project has developed an ESMF which includes a general ESMP to guide project implementation. The procedure for managing contractors and shall include the following as appropriate:

Prior to the preparation of procurement documents.

MOE/GES Project Management unit, Safeguards Team


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Timeframe


Date of Completion

• environmental and social requirements will be included in the procurement and contracting process including bidding documents, for potential civil works.

• relevant requirements are included in contracts and subcontracts (reflecting ESSs and ESCP); contractors will be required to implement site specific ESMP

• codes of conduct are required of contractors and subcontractors and their workers;

• promptly notifying incidents and accidents; • providing grievance redress mechanisms for

contractor and subcontractor, communities and other stakeholders

The project will ensure regular reporting from contractors provide details on contractor’s oversight on environmental, social, health and safety (ESHS) performance.

Maintain procedures throughout Project implementation.

funding from project budget

1.5 PERMIT, CONSENTS AND AUTHORIZATIONS: The Project will seek and obtain the necessary approvals, permits and authorizations from the Environmental Protection Agency, District Assemblies and from other relevant national authorities as applicable.

Prior to initiating activities that require permits, consents and authorizations.

MOE/GES Project Management unit, Safeguards Team funding from project budget


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Timeframe


Date of Completion

The project will Comply or cause to comply, as appropriate, with the conditions established in these permits, consents and authorizations throughout Project implementation.

1.6 THIRD PARTY MONITORING: The Project will engage an independent consultant who will be required to undertake an environmental and social audit (ESA) to verify the monitoring of the environmental and social impacts of the project at mid-term and end of the project.

Mid-term and end of the project



1.7 Add other measures and actions that have been agreed, as per the specific risks and impacts of the Project

None

ESS 2: LABOR AND WORKING CONDITIONS 2.1 LABOR MANAGEMENT PROCEDURES:

The project ESMPs will determine whether a specific labor management plan is required. In the case of significant impacts, an LMP will be developed by the contractor and submitted to the Project Implementation Unit for review and the World Bank for clearance before implementation. With Low risk, the contractor ESMP will include labor related clauses, Codes of Conduct as well

Labor Management Procedures will be developed when the project becomes effective and prior to civil works.


When project becomes effective and Prior to civil works.

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Timeframe


Date of Completion

as specific language referencing the prioritization of the hiring of unskilled local labor.

2.2 GRIEVANCE MECHANISM FOR PROJECT WORKERS: The contractor shall develop and implement a GRM for their staff, to address worker grievance and this shall be approved by the Project Management Unit of MOE and the Bank.

Functional Contractor’s Grievance mechanism for workers will be developed prior to civil works and will be maintained and updated throughout the Project implementation.

MOE/GES Project Management unit, Contractors funding from project budget,


2.3 OHS MEASURES: The project contractor will prepare OHS measures as part of the labor management procedures (LMP). The OHS measures will be designed and implemented to address: (a) identification of potential hazards to project workers, particularly those that may be life-threatening; (b) provision of preventive and protective measures, including modification, substitution, or elimination of hazardous conditions or substances;

OHS measures will be part of the Labor Management Procedures, which will be developed when the project becomes effective and prior to civil works.



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Timeframe


Date of Completion

(c) training of project workers and maintenance of training records; (d) documentation and reporting of occupational accidents, diseases and incidents; (e) emergency prevention and preparedness and response arrangements to emergency situations; and (f) remedies for adverse impacts such as occupational injuries, deaths, disability and disease.

2.4 EMERGENCY PREPAREDNESS AND RESPONSE: The project will incorporate an Emergency Preparedness and Response measures in OHS measures.

When the project becomes effective and prior to civil works. Maintained throughout Project implementation.



2.5 PROJECT WORKERS TRAINING: Implement training of Project Workers designed to heighten awareness of risks and to mitigate impacts on local communities. The project will ensure that contractors and subcontractors and their works are trained and are aware of risks and to mitigate impacts on local communities.

Prior to initiating civil works, with regular refresher training.

Prior to civil works.

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Timeframe


Date of Completion


None

ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT 3.1 MANAGEMENT OF WASTE AND HAZARDOUS MATERIALS:

The Project will ensure that contractors and subcontractors have waste management plans. The project will ensure that contractors and subcontractors use waste minimization techniques such as buying in bulk. Allocating responsibilities for waste management and identifying all sources of wastes, and ensuring wastes are handled by personnel licensed to do so. Making available suitable facilities for the collection, segregation and safe disposal of the wastes. Creating waste collection areas with clearly marked facilities such as color-coded bins and providing equipment for handling the wastes. The bins should be coded for plastics, rubber, organics, glass, timber, metals etc.

Prior to civil works. Maintained throughout Project implementation.




None

ESS 4: COMMUNITY HEALTH AND SAFETY 4.1 TRAFFIC AND ROAD SAFETY:

The Project will ensure that all contractors as part of their ESMP have traffic and road safety measures.


MOE/GES Project Management unit, contractors and subcontractors

Prior to civil works. Continuous.

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Timeframe


Date of Completion


4.2 COMMUNITY HEALTH AND SAFETY: The Project will conduct training for potential contractors, sub-contractors, headteachers and School Management Committees (SMCs), community members, children and pupils to ensure orientation in community health and safety. Other safety measures required of contractors will be to cordon off construction sites.


MOE/GES Project Management unit, contractors and subcontractors funding from project budget

Continuous

4.3 GBV AND SEA RISKS: The ESMF considered a number of GBV prevention and mitigation

measures. The Project will assess site specific GBV risk as part of

ESMP and develop and implement a GBV and SEA risks mitigation

plan. The project will ensure that contractors and subcontractors

bidding documents provide requires for GBV and SEA risks

mitigation. The project will identify non-governmental

organizations with the necessary expertise to support ways to

prevent and address GBV issues.

GBV and SEA risks mitigation plan will be developed when the project becomes effective and prior to civil works. Maintained throughout Project implementation.


Continuous

4.4 GBV AND SEA RISKS DURING PROJECT IMPLEMENTATION: Monitoring incidents throughout the

MOE/GES Project Management unit,

Continuous

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Timeframe


Date of Completion

The project will make additional funding available for GBV and SEA risk mitigation when needed and this will be costed under the implementation of the ESMP.

implementation period of the project


4.5 EMERGENCY RESPONSE MEASURES: Emergency Preparedness and Response measures incorporated in OHS measures

Emergency preparedness and response measures as part of the OHS measures will be developed when the project becomes effective and prior to civil works. Maintained throughout Project implementation.



4.6 SECURITY PERSONNEL: Not relevant for the implementation of this Project. However, during project implementation when this becomes relevant, the Project will ensure that contractors and subcontractors put in place appropriate security measures in collaboration with the Ghana Police Service.

Not relevant for this project

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Timeframe


Date of Completion

4.7 TRAINING FOR THE COMMUNITY: The Project will conduct training for communities and project affected stakeholders to create awareness of risks and to mitigate impacts. The training will aim at building the capacity and commitment of communities to support programmes targeted at promoting child rights, gender-based violence prevention, HIV-AIDS/STI awareness and prevention, community grievance redress mechanism etc.

Prior to project implementation

Safeguard Team Continuous


None

ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT 5.1 LAND ACQUISITION AND RESETTLEMENT:

The Project has prepared Resettlement Policy Framework (RPF) which will be disclosed prior to appraisal. The RAP will be prepared as required when subproject locations are identified.

Prior initiating activities that involve involuntary resettlement.


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Timeframe


Date of Completion

5.2 RESETTLEMENT PLANS: The Project will prepare RAPs when subproject locations are identified, and it is determined that activities will involve involuntary resettlement.

RAPS will be implemented prior initiating activities that involve involuntary resettlement.


5.3 MONITORING AND REPORTING: The Project will ensure monitoring and reporting on land acquisition and resettlement activities throughout Project implementation as part of regular reporting.

Six-monthly throughout Project implementation.

MOE/GES Project Management unit, Safeguard Team

Continuous

5.4 GRIEVANCE MECHANISM: The project will harness the existing GRM established under the Secondary Education Improvement Project (SEIP) which is being implemented by the same implementing agency (MOE) and funded by the World Bank.

Functional Grievance mechanism already in place prior to appraisal and will be maintained and updated throughout the Project implementation.


Grievance mechanism already in place prior to appraisal and will be maintained and updated throughout the Project implementation.


None

ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES

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Timeframe


Date of Completion

6.1 BIODIVERSITY RISKS AND IMPACTS: The project will screen subproject activities using the screening tool developed under the ESMF to determine potential biodiversity risks and impacts and make recommendations on specific assessments to be conducted. Work shall not be carried out in sensitive ecosystems/habitats/species, such as protected areas, forests, wetlands and IUCN listed species to avoid elaborate offsets and project delays.

Prior to commencing subproject activities.

MOE/GES Project Management unit, Safeguard Team funding from project budget



None

ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES

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Timeframe


Date of Completion

7.1 INDIGENOUS PEOPLES PRESENT OR COLLECTIVELY ATTACHED TO PROJECT AREA: Not relevant to this project since there are no recognized of known indigenous people or underserved traditional local communities within the project area and in Ghana.

Not relevant

7.2 INDIGENOUS PEOPLES PLAN: Not relevant to this project

Not relevant to this project

7.3 GRIEVANCE MECHANISM: Not relevant to this project Not relevant to this project


None

ESS 8: CULTURAL HERITAGE

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Timeframe


Date of Completion

8.1 CHANCE FINDS: The Project has developed a “Chance find” procedure as part of the ESMF disclosed prior to appraisal.

ESMF has been prepared and will be disclosed prior to appraisal


This has been developed as part of the ESMF

8.2 CULTURAL HERITAGE: The project during screening will take cognizance of tangible and intangible cultural heritage sites and items, including potential archaeological heritage within the project’s area of influence. Project shall avoid any disturbance to cultural heritage sites.

Prior to disturbance of site


Continuous


ESS 9: FINANCIAL INTERMEDIARIES

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Timeframe


Date of Completion

9.1 ESMS: Not relevant to this project since there are no FIs involved in this project. However, the project will be guided by this standard when applicable.

Not relevant

9.2 FI ORGANIZATIONAL CAPACITY: Not relevant

Not relevant

9.3 SENIOR MANAGEMENT REPRESENTATIVE: Not relevant

Not relevant


None

ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE

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Timeframe


Date of Completion

10.1 SEP PREPARATION: The Project has engaged several stakeholders at the project design, planning and will further engage stakeholders during the implementation stage through to project closure. The project has prepared a Stakeholder Engagement Plan to guide the process and will be disclosed prior to appraisal.

SEP prepared prior to appraisal to be updated regularly


The SEP prepared and disclosed prior to appraisal

10.2 SEP IMPLEMENTATION: Implement the SEP. The Project Implementation Team will have oversight over the SEP implementation. The team will monitor and document any commitments or actions agreed during consultations, including changes resulting from changes in the design of the project or the SEP. The project will use NGOs to track the SEP and other Citizen Engagement mechanisms under the project.

Throughout Project implementation


Continuous

10.3 PROJECT GRIEVANCE MECHANISM: The project will harness the existing GRM established under the Secondary Education Improvement Project (SEIP) which is being implemented by the same implementing agency (MOE) and funded by the World Bank.

Functional Grievance mechanism already in place prior to appraisal and will be maintained and updated throughout the Project implementation.


Grievance mechanism already in place prior to appraisal and will be maintained and updated throughout the Project implementation.

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Timeframe


Date of Completion


None

Capacity Support

Specify Training to be provided Specify Targeted Groups and Timeframe for Delivery

Specify Training Completed

As example, training may be required in:

• Stakeholder engagement • Subprojects Environmental and Social screening • Specific aspects of environmental and social

assessment • Emergency preparedness and response • Community health and safety • Monitoring and reporting • Child rights • Gender-based violence risk mitigation • Disability equality training

Project consultants, contractors and workers communities, SMCs, District Engineers, Planning officers, District Environmental Health officers etc. this will be done before commencement of civil works.

Continuous

Training on occupational health and safety including on emergency prevention and preparedness and response arrangements to emergency situations.

Add other capacity support and training opportunities as per the specifics of the Borrower and the Project.

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