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THE REPUBLIC OF TUNISIA
SUPPORT TO SMALL AND MEDIUM ENTERPRISES FOR ECONOMIC RECOVERY (P178380)
ENVIRONMENTAL and SOCIAL COMMITMENT PLAN (ESCP)
December 15, 2022
SUPPORT TO SMALL AND MEDIUM ENTERPRISES FOR ECONOMIC RECOVERY (P178380) ENVIRONMENTAL AND SOCIAL COMMITMENT PLAN
- 1. The Republic of Tunisia (hereinafter the Borrower) will implement the proposed Support to Small and Medium Enterprises for Economic Recovery Project (the Project) with the involvement of the Central Bank of Tunisia (CBT), as set out in the Loan Agreement. The International Bank for Reconstruction and Development (hereinafter the Bank) has agreed to provide financing for the Project, as set out in the referred agreement.
- 2. The Borrower shall ensure that the Activities are carried out in accordance with the Environmental and Social Standards (ESSs) and this Environmental and Social Commitment Plan (ESCP), in a manner acceptable to the Bank. The ESCP is a part of the Loan Agreement. Unless otherwise defined in this ESCP, capitalized terms used in this ESCP have the meanings ascribed to them in the referred agreements.
- 3. Without limitation to the foregoing, this ESCP sets out material measures and actions that the Borrower shall carry out or cause to be carried out, including, as applicable, the timeframes of the actions and measures, institutional, staffing, training, monitoring and reporting arrangements, and grievance management. The ESCP also sets out the environmental and social (E&S) instruments that shall be adopted under the Project, all of which shall be subject to prior consultation and disclosure, consistent with the ESS, and in form and substance, and in a manner acceptable to the Bank. Once adopted, said E&S instruments may be revised from time to time with prior written agreement by the Bank.
- 4. As agreed by the Bank and the Borrower, this ESCP will be revised from time to time if necessary, during the implementation of the Project, to reflect adaptive management of changes and unforeseen circumstances related to the Project or in response to assessment of performance of the Project. In such circumstances, the Borrower through the CBT and the Bank agree to update the ESCP to reflect these changes through an exchange of letters signed between the Bank and the Borrower. The Borrower shall ensure that the CBT promptly disclose the updated ESCP.
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
|---|---|---|---|
| MONITORING AND REPORTING | |||
| A | REGULAR REPORTING : Prepare and submit regular monitoring reports to the Bank on environmental, social, health and safety (ESHS) performance of the Project and sub-projects, including but not limited to the preparation of the E&S documents required under the ESCP, stakeholder engagement activities, and functioning of the grievance mechanism, including but not limited to grievance logs from workers and SMEs. | Submit twice a year reports to the Bank throughout the Project implementation, commencing after the Effective Date. Submit each report to the Bank no later than 15 days after the end of each reporting period. | CBT through Project Coordination Unit (PCU). |
| FINANCIAL INTERMEDIARIES REPORTS Prepare and submit reports on ESHS performance of subprojects supported under Components 1 and 2 of the Project, including the operation of their respective ESMS, according to the format set forth in the Project Operational Manual (POM). | The Participating Financial Institutions (PFIs) shall be required to furnish to CBT each progress report not later than 30 days after each quarter starting from the Effective Date. These reports shall be provided to the Bank, at the request of the Bank. | CBT through PCU, and PFIs. | |
| B | INCIDENTS AND ACCIDENTS NOTIFICATION : 1- Promptly notify the Bank of any incident or accident related the Project and sub-projects which has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public or workers including but not limited to: • Occupational Health and Safety Issues | 1-Report any incident or accident to the Bank within 48 hours after becoming aware of the occurrence of the incident or accident. 2-Provide the Bank with a summary report that includes a description and analysis of the root causes of the incident or accident and immediate mitigation or prevention measures not later than 10 days after notification of the incident. 3-Submit a detailed incident report within 30 days or agreed time frame 4- PFIs to report any incident or accident to CBT within 48 hours after becoming aware of the occurrence of the incident or accident. Notification/reporting requirements shall be in place throughout the Project implementation. | CBT through PCU and PFIs. |
ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
|---|---|---|---|
| 1.1 | ORGANIZATIONAL STRUCTURE : Maintain, throughout the Project implementation, an organizational structure (PCU) including an environmental and social risks and impacts management function with qualified staff and adequate resources to support management of environmental, social, health and safety (ESHS) risks and impacts of the Project, all with composition, mandate, and resources, and terms of reference satisfactory to the Bank. Require that each Participating FI designate a senior representative to assume overall responsibility for coordinating the management of the environmental and social aspects of the subprojects supported under the Project, and an environmental and social specialist responsible for the day-to-day implementation of the ESMS. | This organizational structure shall include an E&S Specialist. In the interim, the CBT shall nominate an E&S focal point no later than 30 days after the effective date. An E&S focal point shall be designated by CBT during the hiring process of the E&S specialist and prior to carrying out Project activities and maintained throughout the Project implementation. The E&S specialist shall be hired within 90 days of the Effective Date and shall be maintained throughout Project implementation. An organizational structure has already been established at the CBT. Prior to the commencement of any project activities and maintain throughout project implementation. | CBT through the PCU |
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 1.2 | ENVIRONMENTAL AND SOCIAL ASSESSMENT: Update, disclose, consult upon, adopt, and implement the Environmental and Social Management System (ESMS), consistent with the requirements of ESS1 and ESS9 and in a manner acceptable to the Bank. CBT shall ensure the implementation of the ESMS which shall be amended and updated as required during the Project implementation if unforeseen changes to risks and impacts or changes to project design take place in consultation with Project Stakeholders. | The ESMS shall be prepared and disclosed by effective date. The ESMS shall be updated when required and implemented throughout project implementation | CBT through PCU |
| 1.3 | MANAGEMENT TOOLS AND INSTRUMENTS: CBT shall ensure that PFIs incorporate the relevant aspects of the ESCP, including the relevant E&S documents and/or plans, and the Labor Management Procedures into the ESHS specifications of the procurement documents and contracts with contractors, supervising firms, through the PFIs agreements with the Participating Financial Institutions (PFIs) and through the Sub- loan Agreements with the Small and Medium Enterprises (SMEs). Thereafter ensure that the contractors, SMEs, and PFIs comply with the ESHS specifications of their respective contracts. | As required throughout project implementation | CBT through PCU, PFIs |
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 1.4 | EXCLUSION: Exclude the following types of activities as ineligible for financing under the Project: • Activities that may cause long term, permanent and/or irreversible adverse environmental impacts (e.g. loss of major natural habitat). • Activities that may have significant adverse social impacts and may give rise to significant social conflict. • Activities that may affect lands or vulnerable minorities. • Activities, including new constructions or expansions, that may involve, physical and economic displacement or adverse impacts on cultural heritage. • All the other excluded activities set out in the ESMS of the Project. | During the assessment process conducted under action 1.2. above and throughout project implementation. | CBT through PCU, PFIs. |
| ESS 2: LABOR AND WORKING CONDITIONS | |||
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 2.1 | LABOR MANAGEMENT PROCEDURES : 1. Prepare, consult, disclose adopt and implement an LMP incorporating the relevant requirements of ESS2, in a manner acceptable to the Bank, that address the terms and conditions of employment, non-discrimination and equal opportunity for employment, worker’s organizations, restrictions on child and forced labor, occupational health and safety (OHS) measures related to COVID-19 as per the national health requirements in response to the epidemy, and grievance mechanism for Project workers. 2. CBT shall require PFIs to prepare and implement an LMP, in the terms according to (1) and (2) above. 3. Maintain the existing employment arrangement of CBT staff and ensure that relevant aspects of ESS2 apply including through, inter alia, a) implementing adequate occupational health and safety measures and b) setting upgrievance mechanisms for the workers. | 1. The LMP was prepared and disclosed on December 13, 2022 on the CBT website. Implement LMP throughout Project implementation 2. The LMP is to be prepared and disclosed and adopted prior to the hiring of workers by the PFIs. 3. Throughout Project implementation | CBT through PCU, PFIs |
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 2.2 | GRIEVANCE MECHANISM FOR PROJECT WORKERS : Establish and operate a grievance mechanism for Project workers (CBT workers and contractual workers), workers of SMEs and PFIs as part of the LMP. The GMshall have the following: • Proportionate to the nature and scale of the project and its risks and impacts. • Addresses concerns promptly, using an understandable and transparent process that provides timely feedback to those concerned in a language that they understand, and without any retribution. • Operates in an independent and objective manner and implement the principles of confidentiality and anonymity as warranted (in particular when the grievance concern sexual exploitation and abuse and sexual harassment); • May utilize existing GMs given they possess the above characteristics and may be supplemented with Project specific arrangements. | The established GMat the CBT, as part of the LMP, shall be maintained throughout the project implementation The GMfor PFIs and SMEs workers shall be operational prior to the hiring of workers of the PFIs and shall be maintained throughout the project implementation | CBT through PCU and PFIs. |
| 2.3 | OHS MEASURES : Develop and implement Occupational, Health and Safety (OHS) measures in line with national legislation and ESS2 as part of the ESMS and LMP, particularly as it relates to COVID19 preventive measures and OHS risks associated with rehabilitation works. CBT shall promote safety and health in the work environment and shall require from PFIs and SMEs to do the same, in accordance with the requirements of ESS2 and in a manner acceptable to the Bank. | As part of the LMP and ESMS and implemented throughout the Project implementation | CBT through PCU, and PFIs. |
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 2.4 | EMERGENCY PREPAREDNESS AND RESPONSE : As part of the OHS measures specified in 2.3, include measures on emergency preparedness and response, and ensure coordination with measures under 4.4. | As part of the LMP and ESMS and implemented throughout the Project implementation | CBT through PCU |
| 2.5 | PROJECT WORKERS TRAINING : Implement training of Project Workers designed to heighten awareness of risks and to mitigate impacts on local communities as defined in ESMS and LMP. | As part of the LMP and the ESMS under section 1.2 of this ESCP and implemented throughout the Project implementation | CBT through PCU |
| ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT | |||
| 3.1 | MANAGEMENT OF WASTE AND HAZARDOUS MATERIALS: As part of the ESMS, develop and implement measures and procedures to manage waste and hazardous materials during construction that is in line with ESS3 and requirements of the Tunisian law, in a manner acceptable to the Bank. CBT shall ensure as per the exclusion list of the ESMS that any high polluting activities are not supported under the project. The SMEs that undertake light civil works shall be required to prepare and implement an Environmental and Social Management Plan to be eligible for funding. | Same time as for the adoption and implementation of the ESMS | CBT through PCU, PFIs, SMEs |
| ESS 4: COMMUNITY HEALTH AND SAFETY | |||
| 4.1 | TRAFFIC AND ROAD SAFETY : Develop and implement measures and actions to assess and manage traffic and road safety risks. | Same time as for the adoption and implementation of the ESMS | CBT through PCU |
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 4.2 | COMMUNITY HEALTH AND SAFETY: Relevant aspects of this standard shall be considered, as needed, under action 1.2 above including, inter alia, measures to: minimize the potential for community exposure to communicable diseases and COVID-19 infections; ensure that individuals or groups who, because of their particular circumstances, may be disadvantaged or vulnerable, have access to the development benefits resulting from the Project. | Guidelines and mitigation measures as part of the ESMS. To be implemented throughout Project implementation and to be set prior the commencement of project activities. | CBT through PCU |
| 4.3 | GBV AND SEA RISKS : The GBV/SEAH risk assessment is Low. Adopt and implement GBV/SEAH risk mitigation measures for low risk as per the Good Practice Note | Adopt and implement the GBV/SEAH risk mitigation measures within 180 days after the Effective Date They shall be implemented throughout Project implementation | CBT through PCU |
| 4.4 | EMERGENCY RESPONSE MEASURES : Develop and implement measures to address emergency events and ensure coordination with measures under 2.4. Measures will be defined in the ESMS and disseminated as part of the SEP. | Part of the LMP and ESMS. | CBT through PCU |
| ESS 9: FINANCIAL INTERMEDIARIES | |||
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 9.1 | ESMS : CBT shall prepare, disclose, maintain, implement, and update as appropriate, the ESMS to meet the requirements of ESF as per ESS9. This shall include ensuring that there is adequate capacity to maintain it through the appointment of the E&S specialists CBT and each of the PFIs shall assign both a senior management representative to have overall accountability for environmental and social performance and a staff member or consultant as E&S Focal Point to manage the day-to-day implementation of ESMS. The Terms of Reference of the E&S Focal Point, including required technical skills and experience shall be included in the ESMS and Project Operations Manual (POM). | The ESMS shall be prepared and disclosed by the Effective Date, updated when required and implemented throughout project implementation PFIs shall establish their respective ESMS before the selection of any subproject to be supported under Components 1 and 2 of the Project. Once established, maintain and implement the ESMS throughout Project implementation | CBT through PCU and PFIs. |
| 9.2 | EXCLUSIONS CBT shall ensure that the project’s exclusion list, following action 1.4, is adhered to in accordance with the Loan Agreement. During the implementation stage of this project, all candidate PFIs and SMEs shall be screened against the project’s exclusion list of the ESMS, categorized and assessed for their E&S risks and impacts prior to receiving any financing under the project. | PFI subprojects shall be screened before determining whether they are eligible to receive support from the Project. | CBT through PCU |
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 9.3 | FI ORGANIZATIONAL CAPACITY : PFIs shall also establish and maintain the organizational capacity and competence to implement ESMS with functions and responsibilities in accordance with ESS9 and in a manner acceptable to the Bank . | Prior to the commencement of any project activities and maintain throughout project implementation. | CBT through PCU, and PFIs. |
| ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE | |||
| 10.1 | STAKEHOLDER ENGAGEMENT PLAN PREPARATION AND IMPLEMENTATION Prepare, disclose, consult, adopt and implement the Stakeholder Engagement Plan (SEP) including a grievance mechanism (GM), consistent with ESS10, which shall include measures to, inter alia, provide stakeholders with timely, relevant, understandable and accessible information, and consult with them in a culturally appropriate manner, which is free of manipulation, interference, coercion, discrimination and intimidation. The Borrower shall ensure that the SEP is amended and updated as required during the Project implementation following inclusive stakeholder consultations. | SEP was prepared, consulted upon and disclosed on December 13, 2022, on the CBT website. Update SEP as needed throughout project implementation. The SEP shall be implemented throughout the Project | CBT through PCU CBT through PCU |
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| 10.2 | PROJECT GRIEVANCE MECHANISM : A project GMis already established and operational within CBT. It will also need to be established at PFIs and SMEs once selected as specified in the SEP. Implement, maintain and operate a grievance mechanism, as described in the SEP. Accessible grievance arrangements (telephone, email, online form,…) shall be made publicly available to receive, process and facilitate resolution of concerns and grievances in relation to the Project, promptly and effectively, in a transparent manner that is culturally appropriate and readily accessible to all Project- affected parties, at no cost and without retribution, including concerns and grievances filed anonymously, consistent with ESS10, in a manner acceptable to the Bank. The GMshall be equipped to receive, register, and facilitate the resolution of SEA/SH complaints, including through the referral of survivors to relevant gender-based violence service providers, all in a safe, confidential, and survivor-centered manner. GMs shall also be established within each of the PFIs to handle complaints and grievances relating to the project, in accordance with the requirements of ESS10 and in a manner acceptable to the Bank. | Throughout project implementation as described in ESMS under section 1.2 and in the SEP under section 10.1 The PFIs shall establish the grievance mechanism prior to the commencement of project activities and thereafter maintain and operate the mechanism throughout Project implementation. | CBT through PCU |
| CAPACITY SUPPORT (TRAINING) | |||
| MATERIAL MEASURES AND ACTIONSTIMEFRAMERESPONSIBILE ENTITY/AUTHORITY | |||
| CS1 | As example, training may be performed by the PCU, through recruited specialist, for the required following items: • Performing Environmental and Social screening of sub- projects • Specific aspects of social assessment, including GBV SEA/SH risks, impacts and mitigation measures • Training on occupational health and safety including on emergency prevention and preparedness and response arrangements to emergency situations. emergency preparedness and response and OHS measures related to COVID-19 as per the national health requirements • Grievance redress mechanism • PFIs ESMS preparation, implementation, and monitoring | CBT through PCU |
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