Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697799149914.pdf (Dominica)
Environmental and Social Management Plan (ESMP) Reconstruction of Delices Forest Service Centre (Forest Station) Restoration of Key Infrastructure in Agriculture, Livestock, and Forestry August 31, 2022 Revision Record Revision Date Author(s) Remarks 1.

June 7, 2022 EALCRP PIU Preliminary Draft 2.

August 31, 2022 EALCRP PIU & IST Draft – Internal Review 3.

4.

5.
4.

5.

September 26,2022 World Bank Safeguards Specialist Draft – World Bank Review December 15, 2022 World Bank Safeguards Specialist Draft – World Bank Clearance Draft – Disclosure and Consultation Table of Contents Chapter 1.
Introduction and Background ..................................................................................................... 3 1.1 1.2 1.3 EALCRP Project Overview and Objectives ..................................................................................... 3 ESMF and ESMP for the Project .................................................................................................... 3 Forest Extension Services .............................................................................................................. 4 1.3.1 Duties of Forest Staff ................................................................................................................... 5 Chapter 2.
Project Description ...................................................................................................................... 7 2.1 2.2 Location and Regional Setting ....................................................................................................... 7 Project Details and Status ............................................................................................................. 8 2.2.1 Floor Plan Layout .................................................................................................................. 8 Chapter 3.
The Legal and Administrative Framework .................................................................................. 9 3.1 Relevant National Laws and Policies for the project .................................................................... 9 3.1.1 3.1.2 Ministry of Health COVID 19 Guidelines ................................ Error!

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Physical Planning Act (2002) ................................................................................................. 9 3.1.3 Forestry and Wildlife Act (1990) .................................................................................................. 9 3.1.4 Forest Act (1990) .......................................................................................................................... 9 3.1.5 Water and Sewage Act (1989) ..................................................................................................... 9 3.1.6 National Parks and Protected Areas Act (1990) ........................................................................... 9 3.1.7 3.1.8 Solid Waste Management Act 2002 .................................................................................... 10 Pesticides Control Act (Cap.
40:10) ..................................................................................... 10 3.2 World Bank Social and Environmental Safeguards ..................................................................... 10 3.2.1 3.2.2 Safeguard Policies ............................................................................................................... 10 EHS Guidelines .................................................................................................................... 10 Chapter 4.
Potential Environmental and Social Impacts ............................................................................ 12 4.1 Demolition Phase .............................................................................................................................. 12 4.1.1 4.1.2 4.1.3 Site Access and Security ...................................................................................................... 12 Noise and dust control ........................................................................................................ 12 Disposal of Demolition waste ............................................................................................. 12 4.2 Renovation Phases ...................................................................................................................... 13 4.2.1 4.2.2 4.2.3 Site Access and Security ...................................................................................................... 13 Noise and dust control ........................................................................................................ 13 Debris and solid waste management .................................................................................. 13 1 4.2.4 Traffic management ............................................................................................................ 14 4.2.5 Workers Health and Safety ................................................................................................. 14 4.2.6 Pest Management ............................................................................................................... 14 4.2.7 Sewage Management ................................................................................................................ 15 4.2.8 4.2.9 Forced Labour ..................................................................................................................... 15 Child Labour ........................................................................................................................ 15 4.2.10 Gender Based Violence ............................................................................................................ 15 4.1.4 Disability Inclusion ..................................................................................................................... 15 4.3 Operation Phase.......................................................................................................................... 16 4.3.1 Wastewater ................................................................................................................................ 16 4.3.2 Waste management ................................................................................................................... 16 4.3.3 Energy and water consumption ................................................................................................. 16 4.3.4 Emergency Response ................................................................................................................. 16 4.3.5 Occupational Health and Safety................................................................................................. 16 Chapter 5.
Mitigation Measures ................................................................................................................. 17 5.1 Demolition Phase ....................................................................................................................... 17 5.3 Operation Phase .............................................................................................................................. 23 Chapter 6.
Project Management and Institutional Arrangements ............................................................. 25 6.1 6.2 6.3 ESMP Implementation Responsibilities ...................................................................................... 25 Contractor Responsibilities ......................................................................................................... 26 Supervision, Monitoring and Reporting ...................................................................................... 26 Chapter 7.
Stakeholder Engagement .......................................................................................................... 27 7.1 7.2 7.3 Consultations .............................................................................................................................. 27 Disclosure .................................................................................................................................... 29 Grievance and Redress Mechanism (GRM) ................................................................................ 29 7.3.1 EALCRP PIU GRM ................................................................................................................. 29 7.3.2 World Bank Redress Mechanism ........................................................................................ 31 Chapter 8.
ANNEXES ................................................................................................................................... 32 Annex 1: Environmental and Social Screening Checklist ............................................................................ 32 Annex 2: Sample Code of Conduct .............................................................................................................. 37 2 Chapter 1.
Introduction and Background 1.1 EALCRP Project Overview and Objectives After the passage of Hurricane Maria on September 18, 2017, The Government of the Commonwealth of Dominica (GoCD) with funding from the World Bank Group commenced with implementing the Emergency Agricultural Livelihoods and Climate Resilience Project (EALCRP).
The objectives of the Project are to contribute to restoring agricultural livelihoods and enhancing climate resilience of farmers and fisher folks affected by Hurricane Maria in Dominica.

Under component B, the project is design to deliver a series of infrastructure projects for the Division of Agriculture in the Ministry of Blue and Green Economy, Agriculture and National food Security.
The Forestry, Wildlife and National Parks Division also benefited from this intervention, through three upgraded field offices, referred to as Forest Stations.

This Subcomponent B.1 will facilitate the process of restoring forest stations and associated forest extension services that severely impacted as a result of the passage of Hurricane Maria on September 2017.

These facilities are located at Delices in South East, Calibishie in the Northeast and D’leau Gommier in the Central Forest Reserve.
1.2 ESMF and ESMP for the Project The established Environmental and Social Management Framework (ESMF) for the project requires all project related activities, including sub-project activities to be reviewed and assessed to ensure that environmental and social impacts associated with their implementation throughout the project’s life cycle are mitigated (prevented, reduced or avoided).
The Environmental and Social Management Plan (ESMP) is one of the safeguards instruments used to address the environmental and social impacts and risks of projects, and as a result this ESMP has been prepared.

Based on the screening conducted for this project (see Annex 1), an Environmental and Social Management Plan (ESMP) is required to identify and appropriately manage environmental, social, health and safety impacts and risks.
This ESMP has been prepared to provide guidance and mitigation measures to the implementing entities (Local Government Authorities, and contractors/sub-contractors) to ensure that the renovation of the Delices Forest Service Centre is compliant with laws of Dominica, consistent with international best practices and the World Bank safeguards standards.1 Specifically, it will ensure the protection of workers, staff of the Ministry of Blue and Green Economy, Agriculture and National Food Security, Forestry Division, Ministry of the Environment, Rural Modernization and Kalinago Upliftment and Contractors from environmental and social impacts and risks 1 The Environmental and Social Management Framework (ESMF) for the EALCRP in Dominica can be found at: dominica_EALCRP_ESMF.pdf (agriculture.gov.dm) 3 associated with the renovation activities, such as fugitive dust, waste management, health and safety, and providing timely and clear public information on the project.
This ESMP will be disclosed on the EALCRP website after World Bank`s approval, and the records of the disclosure will be documented and recorded.

This ESMP for the renovation of the Delices Forest Service Centre can be accessed at EALCRP website http://www.piu.agriculture.gov.dm/.

1.3 Forest Extension Services The Forestry, Wildlife and National Parks Division is the government agency charged with the day to day responsibility for managing the country’s Forests.
The State Forest comprises of the three legally established National Parks and two Forest Reserves together that are owned by the Government of Dominica, and referred to as State Lands.

National Parks include the Morne Daiblotin National Park, the Morne Trois Piton National Park and the Cabrits National Park all which are lands set apart as protected areas and are hereby entrusted in the State and dedicated to the people of Dominica for their benefit, education and enjoyment.
Note that the Cabrits National Park has a marine component which is managed by the Fisheries Division and the terrestrial section managed by Division of Forestry, Parks and Wildlife.
Protected forest is any area of private land declared by the President of Dominica for specific purposes including to be used for the protection of rare and endangered species of plant and animals, to be used as wind breaks against storm, for the prevention of landslides and soil erosion, for the conservation of timber resources, for the maintenance of water supplies and for the protection of roads, bridges and importantly health benefits for all users.
Forest Reserves is an area of State land declared by Order by the President of Dominica for the protection and conservation of fauna, flora and physical resources of forested lands.

Forest Reserve are demarcated by surveying and describing its boundaries giving bearings and distances which must be published in the Order.

Forest reserves cannot be developed, sold or used for agriculture and or other purposes.
In order to better managed and conserve all these State-owned lands, four administrative regions known as Forest Ranges were created.

These are the Northern or Portsmouth Forest Reserve, The Roseau or the Southern Forest Range, the La Plaine or Eastern Forest Range and the Central Forest Range.

Each of these forest ranges is equipped with a Forest Service Centre where forest officers can conduct their daily function of protecting Dominica’s forest resource base.
The Delices Forest Service Centre is staffed with a Forester I, who is the Officer in charge and who is assisted by a Forester II and other temporary staff as required for specific work programs or projects.

As with other facilities with similar administrative functions, the Delices Forest Service Centre has been the hub for all forest management related activities in the South-eastern Forest 4 Range.
The Forester I and his subordinate staff are assigned to work in the range and function out of the Delices Forest Service Centre.

The Forestry Staff at each Forest Service Centre is responsible for ensuring that the forest estate is protected and guarded against illegal human activities.

Foresters duties includes patrolling the forests, support and conduct research activities, manage the process for timber sales (e.g.
timber cutting licences, and permits for the removal of forest produce), undertake various wildlife protection programs such as issuing hunting and fishing licences or for keeping wildlife in captivity; undertake forestry extension services such as visits to schools and other institutions for environmental awareness purposes and generally carry out the directives of the Director of Forestry that would ensure the sustainable utilization of the country’s forest and wildlife resources.
1.3.1 Duties of Forest Staff a.

Issuing of Removal Permits Forest Officers are responsible for issuing timber removal permits to both State owned and private forests within the Southeast Forest Range.

This function also provides for the monitoring of harvested timber and the specific location of removal.

This effectively reduces on the incidents of theft of forest products.

b.

Forest and Wildlife Patrol This is a basic activity for all Forestry Officers.
This entail patrolling the forested areas of Dominica (on foot) to deter and or mitigate theft of forest products; illegal occupation of State-owned lands (squatting); illegal hunting of wildlife.

c. Timber Harvesting There is a great demand for timber and timber products both from locals and individuals outside the immediate community.

This is an important socio-economic activity which sustains livelihood of the local communities.
d. Forest Plantation Management An important management tool is to thin out the plantation at set intervals to allow for a more robust development of the remaining trees in the plantation.

The trees that have been thinned, depending on their size and intended use may be sold to the public.
e. Environmental Education and Awareness Forest Officer are engaged in forest education to local schools, University students as well as community organizations on either side of the forest range, who wish learn about various natural resources management issues.

On occasions there are requests from visiting researchers to camp out at the facility in order to remain sufficiently close to their subject of research during their field research exercise.
5 f. Forestry/Agriculture Relationships Forest Officers must maintain a constant presence with local farmers in promoting the concept of agroforestry and increase crop production without compromising the integrity of the forest resources and enhancing their livelihood.

Forestry Officers are integral to any program aimed at promoting sustainable agriculture and resource conservation / management.

6 Chapter 2.
6 Chapter 2.

Project Description 2.1 Location and Regional Setting This Forest Service Centre is located in the village of Delices on the Southeast side of the Island.

The site is approximately ¼ of an acre and is owned by the Government of Dominica.

The site is in close proximity to the Delices Police Station and a small silviculture unit for the propagation of forest trees.
Figure 1: Location of the Delices Forest Service Centre Figure 2: Baseline condition of Delices Forest Service Centre (exterior) 7 Figure 3: Interior of Forest Station used as a nursery 2.2 Project Details and Status 2.2.1 Floor Plan Layout The Delices Forest Service Centre was destroyed (75%) by Hurricane Maria and will require a complete reconstruction of the building.
The proposed reconstructed building will be designed to include the following amenities: o A small meeting room that can also double up for overnight camping purposes when there are larger numbers of people visiting.

o A small kitchenette equipped with stove, fridge, sink and other facilities for the preparation of meals for Forest Officers or stayover visitors (researchers).

o Separate male and female washroom.

o An office for the resident Forest Officers.


o The installation of solar panel for the provision of solar energy in the absence of electric power from the national grid.

8 Chapter 3.
8 Chapter 3.

The Legal and Administrative Framework The ESMP was prepared against the background of ensuring the proposed Delices Forest Service Center reconstruction activities are managed, mitigated and compliant with the relevant laws of Dominica and the World Bank Environmental and Social Safeguards and Environmental, Health and Safety Guidelines.
A comprehensive review of the policy, regulatory and legal framework in Dominica is described within the general ESMF for the Emergency Agricultural Livelihoods and Climate Resilience Project (EALCRP).

This ESMP attempts to address the significant environmental and social impacts and risks associated with the proposed Delices Forest Service Centre rehabilitation.
3.1 Relevant National Laws and Policies for the project 3.1.1 Physical Planning Act (2002) The Physical Planning Act (2002) provides for the orderly and progressive development of land and for the granting of permission to develop land and for other powers of control over the use of land.

This Act details the application and approval process which is executed through the Physical Planning Division of the Physical Planning and Development Authority.
The Act states that ‘No person shall carry out any development of land except under and in accordance with the terms of a development permission granted in that behalf prior to the commencement of such development.

It makes provision for the Authority to consult with local authorities where such consultation is desirable in the interests of good planning.
3.1.2 Forestry and Wildlife Act (1990) This Act provides for the protection, conservation and management of wild mammals, fresh water fishes and amphibians, crustaceans and reptiles, and for the purpose connected therewith.

Forest reserve means any area declared by the President by Notice in the Gazette to be a forest reserve.

3.1.3 Forest Act (1990) This Act make provision for the conservation and control of forest.
This is critical especially where forest land (reserves) is bordering with agricultural lands.

3.1.4 Water and Sewage Act (1989) This Act conserves and preserves water and the protection of the catchment areas.

This Acts stipulated that water management is vested in the Dominica Water and Sewage Company (DOWASCO).

There is a shared responsibility of the catchment areas between the Forestry, Park and Wildlife Division.
3.1.5 National Parks and Protected Areas Act (1990) An Act respecting national parks and protected areas.

National Parks are all lands in the parks and all lands set apart as protected areas shall constitute the national parks system and are hereby vested in the State and dedicated to the people of Dominica for their benefit, education and enjoyment.
9 Notwithstanding any other Act, the lands within the national park system shall be maintained and made use of so as to leave them unimpaired for the enjoyment of future generations.

3.1.6 Solid Waste Management Act 2002 Solid Waste Management Act (2002) is mandated by the Dominica Solid Waste Management Corporation (DSWMC).

It sets out requirements for Waste Management licenses and permits.

It prohibits the importation of waste and establishes liability and ownership of waste.
It outlines requirements for the handling of waste, and provides for the management of used oil.

It also addresses derelict motor vehicles, white goods and other scrap metal.

The DSWMC is the authority responsible for the management of the landfill, where the majority of the projects waste will be disposed.
The functions of the DSWMC are: (a) provided storage facilities for solid waste; (b) procure equipment for the collection, transportation and disposal of solid waste; (c) oversee the management of all solid waste collection and disposal systems in the State.

3.1.7 Pesticides Control Act (Cap.

40:10) The Pesticides Control Act provides for the control of the importation, sale, storage and the use of pesticides.
It creates a Pesticides Control Board to advise the Minister and to carry out provisions of the Act and its Regulations.

It gives power of entry to an inspector.

The Minister may make regulations to affect the provisions of the act.

Subsidiary legislation includes the Pesticides Control (Labelling of Pesticides) Regulations and the Pesticides Control (Registration and Licensing) Regulations.
This Act is relevant as the rehabilitation of the Delices Forest Service Centre will be treated for the prevention of termites’ infestation.

3.2 World Bank Social and Environmental Safeguards 3.2.1 Safeguard Policies The World Bank (WB) has developed Safeguard Policies that guide the development of projects including the EALCRP.

Accordingly, the ESMF was prepared for the EALCRP as a guidance document, and currently the ESMP has been prepared for this project.
World Bank Safeguards triggered by rehabilitation/construction cover aspects such as assessment and management of environmental and social risks and impacts, health and safety, pollution prevention and management, public disclosure, natural habitat, and antiquities protection, among others.

For a document thorough please (http://piu.agriculture.gov.dm/publications) website (https://www.worldbank.org/en/projects-operations/environmental-and-social-policies).
refer or ESMF WB discussion to the these, the of 3.2.2 EHS Guidelines Environmental, Health and Safety guidelines have also been prepared by the WB.

There are general guidelines that cover most activities related to construction projects involving the renovation of existing buildings or construction of new facilities.

Some parts of these general guidelines are applicable to the project, particularly such aspects as dust and noise control and 10 workers’ health and safety.
For more information refer to the EHS Guidelines on the WB website.2 2https://www.ifc.org/wps/wcm/connect/topics_ext_content/ifc_external_corporate_site/sustainability-at- ifc/policies-standards/ehs-guidelines 11 Chapter 4.
Potential Environmental and Social Impacts The proposed demolishment and construction of the new Delices Forest Service Centre is expected to generate positive benefits such as increasing available office space for the Forest Officers/Guard, employment of improved working environment, etc.

Notwithstanding these numerous positive benefits expected to accrue from the project, the following negative environmental and social impacts have been identified for construction of the Delices Forest Service Centre.
Mitigation measures for each of the impacts and risks identified below are presented in Chapter 5. contractors, 4.1 Demolition Phase 4.1.1 Site Access and Security During the demolition of the Delices Forest Service Centre access from the general public will be restricted by barricading the area with caution tape or signs indication demolition works.
The demolition process will be done by a heavy machinery namely a backhoe and is expected to last for 2 to 3 days during which time the neighbour will be informed and will be required to vacate the areas during the actual demolition to avoid any accident that may occur.

4.1.2 Noise and dust control There will be an extensive amount of noise and dust during the demolition of the old forest station.

The area and building will be watered down to reduce the dust generated by demolition.
The Police Officers in the neighbouring police station will be informed of the demolition activity.

4.1.3 Disposal of Demolition waste The renovation of the Delices Forest Service Centre will generate construction wastes such as damaged tiles, pieces of glass, pieces of wood, concrete waste, pieces of blocks, nails and scraps metal, etc.

Waste generated from demolition works will be sorted based on organic and inorganic material.
Most of the waste will which will be concrete material, bedded with steel and other metals.

The distance from the demolition site to the landfill is approximately 27 miles and will take between an hour to an hour and a half (1hr to 1.5hrs) one way to transport materials.

This is not practical approach as it will be adding concrete material in the already limited space landfill.
Further, this practice would be uneconomically feasible making several trips transporting concrete waste material from the demolition site to Dominica`s only landfill, but also the risk of materials falling and potentially causing accidents must also be considered.
There are several options for disposing of demolition waste that the Contractor can consider to include: Firstly, is to use all concrete waste to backfill the lower section of the land to create a level platform and the same can be used to expand the footprint of the Forest station which can be used for further development, such as a nursery (see figure # 4) The second option is to dispose of the concrete waste void of steel and other metals in an area designated approved by the Dominica Solid Waste Management Corporation.
12 The Contractor can contact other Contractors, landscapers or community groups who may need material to backfill on their project.

The EALCRP PIU Environmental Safeguards Specialist will monitor the disposal of these materials to ensure compliance with the laws of Dominica and the World Bank standards and policies.

Figure # 4.

Area to be backfilled.


4.2 Construction Phase 4.2.1 Site Access and Security During the reconstruction of the Delices Forest Service Centre access from the general public will be restricted by barricading the area with caution tape or signs indication of reconstruction works.
The Delices Service Centre is in close proximity to the Delices Police Station and as such Police Officers will be required to provide some form of security services after working hours ensuring that there is no vandalism of the property.

4.2.2 Noise and dust control During reconstruction activities, noise and vibration may be caused by the operation of motorized equipment or power tools such as drills, electric saws, tile cutters.
Noise from these small tools will not significantly impact the function of the police station nor the one neighbour dwelling nearto the reconstrcution site.

Fugitive dust formation from tiling cutting, cutting lumber activities can trigger respiratory illnesses for contractor workers.

However, such dust will not impact the occupants of the dwelling house nor that of the Police Station.
4.2.3 Debris and solid waste management The renovation of the Delices Forest Service Centre will generate construction wastes such as damaged tiles, pieces of glass, cement bags, pieces of wood, concrete waste, pieces of blocks, nails and scraps of building materials, etc.

Waste generated from the renovation works will be sorted based on organic and inorganic material.
All inorganic waste in small quantities, primarily 13 metals and hard plastic will be disposed of at the landfill managed by the Dominica Solid Waste Management Corporation.

The EALCRP PIU Environmental Safeguards Specialist will monitor the disposal of these materials to ensure compliance with the laws of Dominica and the World Bank standards and policies.
4.2.4 Traffic management The risk of traffic congestion or disturbance will be kept at minimal by installing traffic signs cautioning motorist that are traveling in and around the reconstruction site.

The reconstruction site is not located along a main road therefore it is not expected to have heavy traffic.

However, truckers delivering materials need to exercise caution.
4.2.5 Workers Health and Safety The reconstruction works on the Delices Forest Service Centre will expose contractor and workers to potential health and safety risks.

Exposure to health and safety risks will require the contractor to develop and implement an occupational health and safety plan (OHS), including, but not limited to, providing personal protection equipment (PPE) to workers, to prevent or reduce the risk of accidents at the work site.
Specifically, the contractor will be responsible for implementing international good practice and safe work procedures in high-risk activities (such as when working on heights, scaffolds and ladders), and providing the appropriate PPE such as safety boots, helmets, reflector vest, gloves, protective clothes, dust mask, goggles, and ear protection at no cost to the workers.
A well-stocked first aid kit equipped with medication and supplies to treat basic construction related injuries, must be available to workers.

The Contractor will also be required to prepare and submit a Code of Conduct to the EALCRP PIU for review and acceptance (Annex 4).

Any accidents or near misses on the construction site must be documented by the Contractor and reported to the EALCRP PIU, Environmental Specialist.
The Supervisor or Safety Officer assigned to the project must also check to see if there are any immediate risk of danger associated with the accident; secondly, ensure that the injured receives the appropriate medical attention.

Thirdly, the matter should be reported to the PIU Office, where it is investigated as to the cause and provision of preventative measures.
4.2.6 Pest Management Prior to reconstruction of the Delices Forest Service Centre the entire perimeter of the Construction site must be treated to prevent the infestation of termites.

All necessary precautions must be taken and enforced according to the Integrated Pest Management Plan set for the EALCRP (http://piu.agriculture.gov.dm/) safeguard section.

Safety pesticide application guidelines are also outlined in Chapter 5 of this ESMP.
Contractors or Pesticide Applicators can also refer to easy to follow guidelines on the Safe and Effective Use of Pesticides (SEUP), that can be found on the project website (http://piu.agriculture.gov.dm/) safeguard section.

14 4.2.7 Sewage Management The management of human wastes on site is also critical for maintaining a healthy working environment and reducing the risk of faecal contamination.

The contractor will be responsible for providing and adequately managing portable sanitary units.
4.2.8 Forced Labour The Project will not use forced labour and/or child labour.

Forced labour; persons working against their own free will.

The Contractor shall have in place, a grievance redress mechanism for workers to raise workplace concerns and grievances including instances of forced labour.

If the Contractor is unable to develop and implement a grievance redress mechanism (GRM), workers will be directed to use the EALCRP PIU’s GRM to register complaints, issues or concerns.
The Contractor needs to provide an avenue that avoid discrimination especially of vulnerable groups and allow employees to raise workers concerns.

4.2.9 Child Labour No person under the age of 18 years will be employed or engaged in any project activity.

Contractor will enforce Code of Conduct (see Annex 4) to prevent child labour; i.e., any person, 18 year or below.

4.2.10 Gender Based Violence This project does not foresee and is not at high risk project for SEA/SH cases.
However, some cases such as that of sexual exploitation and sexual abuse/ sexual harassment (SEA/SH) are sensitive and may not be reported due to the risks of stigmatization, rejection and reprisals against survivors.

This creates and reinforces a culture of silence and survivors may be unwilling to approach the authorities.

Therefore, the contractor will need to put in place multiple channels for mitigating and registering complaints in a safe and confidential manner.
The Contractor should also include in the code of conduct (annex 4) measures to address sexual exploitation and abuse and sexual harassment incidents that may occur in the work place.

4.2.11 Disability Inclusion The Project is keen to include people with disabilities into design and implementation of the project activities and prevent discrimination against disability.
Discrimination on the basis of disability means creating a distinction, exclusion, or restriction which has the purpose or effect of impairing or excluding a person with disability from being on an equal basis with others, thereby potentially enhancing the negative impacts of the project or limiting project benefits or being able to voice comments or concerns during stakeholder engagement.
The project will analyse and identify people with disabilities and provide opportunities 1) to include vulnerable and disadvantaged stakeholders in the information disclosure and consultation process in a meaningful way and 2) to include accessibility measures in project design, where financially and technically feasible, if disability risks and impacts have been identified as part of potential project impacts.
Sound mitigation measures can result in not only an inclusive project, but demonstrate 15 good international practice, and can raise awareness on disability issues and accommodating needs of vulnerable groups.

4.3 Operation Phase The potential impacts of the office operations include wastewater, waste management, energy and water consumption, staff health and safety and emergency response.
The operations of the project will not cause any additional environmental or social impacts on the immediate environment as building is an existing brownfield site.

4.3.1 Wastewater Wastewater from the Delices Forest Centre will include water generated from kitchen, bathroom and washing activities.

The contaminants from such water will be minimal and will have little impact on surface or ground water as this water is drained into the existing soak away system.
4.3.2 Waste management The Delices Forest Center will generate mainly paper, kitchen waste and other office waste, which will be stored in garbage bins for weekly pick-up by the Dominica Solid Waste Management Corporation.

4.3.3 Energy and water consumption The energy demand for Delices Forest Service Center will include water, electricity and air conditioning units.
Energy efficiency methods will be applied to reduce losses in energy distribution, improve energy conversion efficiency, exploit energy purchasing opportunities and overall lower the use of carbon fuels.

Energy saving appliances to include LED light bulbs, and air condition unit with the correct BTU based on the area of the building to be air conditioned.

Architectural designs will allow for sufficient natural lighting and location of windows for adequate ventilation in the absence of AC or power.
4.3.4 Emergency Response An Emergency Response Plan is a set of scenarios–based procedures to assist staff and emergency response teams during real life emergency and training exercises.

Delices Forest Station will be equipped with a functional fire extinguisher and a well-stocked first aid kit.

Workers must be trained to use fire extinguishers to put out any fire that may occur.
4.3.5 Occupational Health and Safety Supervisors of the Delices Forest Service Center are obliged to implement all reasonable precautions to protect the health and safety of workers.

Preventive and protective measures should be introduced to eliminate and if not mitigate negative impacts.

Delices Forest Service Center must be structurally safe, provide appropriate protection against the climate, and have acceptable lighting and noise 16 conditions.
This forest service centre must have available a first aid kit that is well equipped and easily accessible Chapter 5.

Mitigation Measures This section of the ESMP provides the mitigation measures to address each of the environmental and social risks identified in Chapter 4.

Detailed/specific mitigation measures are provided in sections 5.1, 5.2 and 5.3 below for site preparation and renovation of the Delices Forest Service Centre respectively.
5.1 Demolition Phase Aspect Site preparation activity Potential Impacts o Respiratory impacts on site residents workers, nearby and pedestrians o Noise generation from the and of machines use demolition equipment with its impact on workers and neighbouring buildings.

Demolition Disposal Waste o Creating disposing indiscriminately.

land pollution by of materials 17 Proposed Mitigation o Prevent unauthorized persons access to the Site.
o Designating an area or waste bin construction stockpiling for materials.

o Dust suppression methods such as wetting materials, covering loose materials, or slowing work should be employed as needed to avoid visible dust from site preparation.

o When and if necessary, install dust protection curtains/barriers.

o PPEs - Dust masks / respirators to (according when working.
approved procedures) o PPEs - Hearing protection for working around machinery where the noise exceeds 85 dB (sound from a lawn mower) o The location of noisy machinery can be positioned away from the police station or public road etc.

o Maintain vehicles and Contractors to machinery maintenance requirements.
o The contractor shall dispose of material debris and solid waste in approved with accordance according Aspect Potential Impacts Proposed Mitigation procedures of Dominica Solid Waste Management Corporation (DSWMC).

o Demolition wastes can be used for backfilling, given to other contractor filling purposes.

back for o The contractor dispose of materials approved by the DSWMC.
should only in areas Dust and noise demolition activity from o Poor air quality due to dust generated o Respiratory impacts on site workers o Noise from generation demolition equipment with its impact on workers and neighbour.

o Dust suppression methods such as wetting materials, dust barriers/curtains, or slowing work should be employed as needed to avoid visible dust from demolition activities o Dust masks / respirators when working in closed areas such as access manholes, etc.
(according to approved procedures) o PPEs - Dust masks / respirators in demolition when working areas, etc.

(according to approved procedures) o PPEs - Hearing protection for working around machinery where the noise exceeds 85 dB (according approved to procedures) o The location of noisy machinery (including generators) can be positioned away from sensitive sites such as Police Stations and residential areas etc.

o Maintain vehicles and Contractors to machinery maintenance requirements.
according 18 5.2 Construction Phase Aspect Site preparation activity Potential Impacts o Poor air quality due to emissions from vehicles and dust generated o Respiratory impacts on site residents workers, nearby and pedestrians o Noise generation from the use and of machines construction equipment with its impact on workers and neighbouring buildings.

Construction Waste and Debris o Improper storage disposal of materials and/or o Creating land pollution by in dispersion of materials nearby streets.
Proposed Mitigation o Designating an area or waste bin construction stockpiling for materials.

o Dust suppression methods such as wetting materials, covering loose materials, or slowing work should be employed as needed to avoid visible dust from site preparation.

o When and if necessary, install dust protection curtains/barriers.

o PPEs - Dust masks / respirators to (according when working.
approved procedures) o PPEs - Hearing protection for working around machinery where the noise exceeds 85 dB (sound from a lawn mower) according o The location of noisy machinery can be positioned away from the police station or public road etc.

o Maintain vehicles and Contractors to machinery maintenance requirements.

o The contractor shall dispose of material debris and solid waste in accordance approved with procedures of Dominica Solid Waste Management Corporation (DSWMC).
o Construction wastes must be stockpiled away from circulation areas and not pose safety hazards to construction workers, wastes must be stored in containers and removed from the site on a regular basis; containers must not overflow.

o The contractor dispose of materials approved by the DSWMC.

should only in areas 19 Aspect Potential Impacts Proposed Mitigation o Collect and segregate wastes based on their classification and ensure disposal by the DSWMC.
o No burning of waste material o Ensure appropriate and safe disposal of contaminants such as fuels, construction materials and wastes.

In case of accidental waste spills, the environmental authority shall be informed, and restoration measures shall be applied.

relevant o o Ensure immediate cleaning of any of after remediation areas and spills contaminated construction.
Pesticide application o The pesticide of risk lead to application may accidental exposure inhalation, spillage and entry into the natural ecosystem Sewage/Wastewater Management Improper disposal and treatment of sewage/wastewater can have adverse impacts on human health and the environment Dust and noise construction activity from o Poor air quality due to emissions from vehicles and dust generated o Respiratory impacts on site residents workers, nearby and pedestrians o Noise generation from the use and of machines construction equipment with 20 o Ensure that pesticides to be used registered by Dominica are Pesticide Board o Ensure workers the appropriate PPE`s when applying pesticides use o Read label and abide by the instructions, to include storage & for use, disposal, direction precautionary statements and first aid.
o Pesticides should be applied after working hours.

o Follow the project IPMP.

o Portable sanitary units will be to collect human established wastes.

Human waste will be disposed at sewage treatment facility to comply with local laws and regulations of Dominica.
o Dust suppression methods such as wetting materials, dust barriers/curtains, or slowing work should be employed as needed to avoid visible dust from demolition or construction activities o Dust masks / respirators when working in closed areas such as access manholes, etc.

(according to approved procedures) Aspect Potential Impacts its impact on workers and neighbouring buildings Proposed Mitigation o PPEs - Dust masks / respirators when working in demolition areas, etc.
(according to approved procedures) o PPEs - Hearing protection for working around machinery where the noise exceeds 85 dB (according approved to procedures) o The location of noisy machinery (including generators) can be positioned away from sensitive sites such as Police Stations and residential areas etc.

Traffic during activities Management renovation Traffic congestion and unsafe transportation of construction materials on and off site.
according o Maintain vehicles and Contractors to machinery maintenance requirements.

o Ensure that a Traffic Management Plan is in place where this might be an issue.

o Ensure that contractor employs safe drivers.

o Prevent storage of construction materials, and machineries on the road traffic lanes.

o Avoid transporting materials equipment during wet conditions.

o Maintain the free movement of traffic on project access roads.

o Site access roads are to remain free of any spillage.
o Establish road signage to warn and inform pedestrians and vehicular traffic of the proposed site and movement of equipment.

o Ensure that a Traffic Management Plan and a Community Safety Plan is in place where this might be an issue.

o Ensure that sites are properly barricaded during construction and pedestrian walkways are provided when required.
temporary o Enforce access control measures to restrict contractor workers and Community Health and Safety o Movement of supply vehicles and equipment may cause traffic problems and create unsafe situations for local motorists entering site.

o Unauthorized entry of local persons may place them in jeopardy if they are on work locations.

21 Aspect Potential Impacts Proposed Mitigation to from going public the construction site during and outside working hours by placing tapes and posters, erecting barriers.
reflecting Workers’ health and safety Workers’ accidents on the construction site o Ensure that appropriate signs are individuals of erected alerting ongoing construction.

o Contractor must prepare and submit incident reports to the PIU.

o Train workers on prevention of managing and accidents incidents.

o Workers must wear personal protective equipment (PPE).

o Provide aid first and emergency plan for accidents or incidents.

kit o Proper supervision of the construction workforce.
o Contractor must develop and Management implement Implementation Strategies and Plans (MSIP) including a site- specific OHS management plan for the most dangerous activities, such as, working on heights (ladder or scaffolding), among others and develop Standard Operation Procedures -SOP prior to the start of works.

o Contractors must also develop a Job Hazard Analysis and convene Daily Safety Talks.

o Contractor must prepare and submit incident reports to the PIU and World Bank.
o Contractor is required to develop and implement a Code of Conduct reflecting community, health and safety prevention and mitigation measures, including, prevention of gender-based violence and sexual exploitation and abuse (Annex 4) Workers sexual exploitation, sexual abuse and sexual harassment Physical, psychological abuse of a sexual nature interferes with the productivity of work and displays a lack of respect for project workers 22 Aspect Labour conditions and working Potential Impacts unfair discrimination opportunity of project workers treatment and and unequal Proposed Mitigation o No person under the age of 18 years will be employed or engaged in any project activity.
o Contractor will enforce Code of Conduct to prevent child labour i.e any person 18 years or below avoid forced and discrimination of vulnerable groups and allow employees raise workers concerned.

labour, especially to o The Contractor will develop a Grievance Redress Mechanism, so that workers can file complaints or develop a means where employees are addressed.
concerns Proposed Mitigation o Train staff how to use PPE and ensure there is adequate supply o Regularly monitor performance and conduct maintenance of equipment sewage o The building is connected to the Thus, system.

existing sewage/wastewater disposal and treatment system will comply with local regulations of Dominica.

laws and o Solid waste will be in designated lids between collection times, collected and disposed of by DSWMC.
containers with stored 5.3 Operation Phase Aspect Occupational Health and Safety Potential Impacts Worker/employee accidents/injury on property Sewage/Wastewater Management disposal Improper treatment sewage/wastewater and of Waste Management Contamination of land and water, impacting the aquatic life.
23 Aspect Wastewater Management Potential Impacts Contaminated water can cause disease and can increase nitrates level in the soil Emergency Preparedness and Response o Accidental fire o Injury to staff o Natural disasters (hurricane, earthquake, flooding, etc.)

Proposed Mitigation o All wastewater from the Delices Forest Service Centre will be drained into the already established soakaway system.

o Waste from kitchen will be drain together with storm water.
o Develop an Emergency Preparedness and Response Plan to address the most common and likely emergency and natural medical, disasters’ events technical o Fire extinguisher strategic located in the office.

o First aid kit suitable for staff and degree of treatment likely to be required before transportation to hospital o Develop training plan to address firefighting evacuation and (earthquakes, hurricane and flooding 24 Chapter 6.
Project Management and Institutional Arrangements 6.1 ESMP Implementation Responsibilities The overall responsibility of ensuring that the mitigation measures under this ESMP are implemented are with the EALCRP Project PIU, Project Manager, Environmental and Social Safeguards Specialists.

The figure below provides an overview of the organizational structure that will support and implement the EALCRP Project.

PIU/EALCRP implementation.


The Project The PIU will have the overall responsibility for project Implementation Unit (PIU) is physically located at 19 King George V St, Roseau.

A Project Manager will lead the day-to-day implementation of the project and will report to the Permanent Secretary, Ministry of Blue and Green Economy, Agriculture and National Food Security on the coordination of efforts with other partners, and for technical coordination of activities financed under the project.
The PIU environmental and social specialists will be responsible for the day- to-day activities in instructing and monitoring compliance with World Bank safeguards and the relevant laws of Dominica, including this ESMP.

When required, additional safeguards support will be provided by the Implementation Support Team (IST) to manage the preparation, updating 25 and implementation of the relevant safeguards instruments or through contractors hired for specific E&S or safeguards related tasks.
6.2 Contractor Responsibilities Engagement of Contractors will be managed by the EALCRP PIU.

Standard environmental and social related requirements will be included in the bidding documents, including compliance with this ESMP.

Therefore, for purposes of cost estimation and budgeting, the contractors should be aware of the existence of the environmental mitigation measures and associated ESMP requirements established herein and include cost items for such purposes in their proposals.
Environmental and social related clauses will also be developed and appended to or incorporated into contracts and shall remain in force throughout the contract period.

6.3 Supervision, Monitoring and Reporting It is the responsibility of the PIU Environmental Safeguards Specialist to ensure that the ESMP is being followed by the contractor(s) and site workers.

This will be done by conducting monthly visits as required throughout out the renovation phase.
The PIU Project Engineer is the technical person for monitoring that the construction specifications are met and provides regular site inspection.

The PIU Project Engineer and the Environmental Specialist are in constant communication to ensure that all safeguard procedures are met.

During the construction phase, primary environmental and social monitoring will be carried out by the Contractor, with support from the PIU Project Engineer to provide oversight on technical aspects.
In addition, the PIU Project Engineer will be required to prepare and submit reports (monthly/quarterly) to the EALCRP PIU Project Manager.

These reports provide update on construction works to include: overall project timeline completion status, action items, project risks, non-conformities with the environmental and social and health and safety requirements and the proposed mitigation plans.

The Environmental Safeguards Specialist must provide a monitoring report to the Bank on a quarterly basis.
26 Chapter 7.

Stakeholder Engagement 7.1 Consultations On February 25, 2022 a consultation was conducted with key Staff of the Forestry, Wildlife and Parks Division to discuss the development and construction of the three Forest Stations island wide to include based on their location; Delices, Calibishie, and D`leau Gommier.

This early engagement with the primary Beneficiaries allows for input from the Forestry Staff and their expectations of the forest stations.
Outcomes for the meeting included the new design to the forest station, all Staff members agreed to a conference room/ meeting hall, separate male and female washroom, kitchen and sleeping quarters must be included at all forest station.

The project would also be entitled to secure the perimeter of the building allowing for sufficient space that a nursery can be developed independently of the project, by the Beneficiary.
Handicap facilities, such as a ramp must also be included for persons and Staff with disabilities.

Participants Designation Mitchinton Burton Director Forestry of Concerns Delay in project base on time it conducting the takes safeguard and screening development of the ESMP for Solution/Result He was assured we are in the early stages of developing these documents and ahead of any construction activities.

Procurement had just received bid from the RFQ for the supervision and Design of the Forest Stations.
Richie Laville 1 Forester Northern Range (Calibishie) Bradley Guye Norma Anthony Forest Officer Building a lumber yard for the drying of lumber.

Assistant Forest Officer -Forest Management Ronald Charles Forestry Specialist/PIU Stakeholder a Conducting engagement of the farmers in the Mangolia Plantation where the forest station is to be housed.

Contacting land and surveys to clearly identify state lands and 27 Participants Designation Concerns survey out a parcel for Calibishie Forest Station.
the Solution/Result Michael McIntyre Safeguards/PIU On July 25th 2022 a meeting was held with key Staff of the Forestry, Wildlife and Park Division to prioritize on the Forest Station.

In attendance were Acting Director of Forestry Ms. Jacklyn Andre; Francisco Maffei, Officer in Charge of conservation, protection and maintenance section.

From the PIU were Ronald Charles, Forestry Specialist and Michael McIntyre, Environmental Safeguards Specialist.
The outcome of the meeting revealed that the D`leau Gommier forest station, followed by the Calibishie Forest Station and lastly the Delices Forest Station were outline as the order of priority for the Forestry Division.

The outcome of the meeting will be forwarded to the Permanent Secretary of the Ministry of Blue, Green Economy and National Food Security for a decision.
The Acting Director of Forestry also had the responsibility to inform the Permanent Secretary of Environment of the importance of the Forest Station, to provide further justification and support for the renovation of forest stations for the Forestry Division.

On 24th October 2022, a meeting was conducted at the site of the Delices Forest Station.

In attendance were Retired Forestry Officer and sole neighbour Mr. Martin Sorhaindo and Officer in charge of the East Forestry Range Mr. Sheldon Simmon.
Both men were in favour and are fully supportive of the construction of the Delices Forest Station.

In the table below outlines the consultation.

Participants Martin Sorhaindo Sheldon Simmon Designation Neighbour/Retired Forestry Officer Officer in charge of the East Forestry Range Concerns Solution/Result • Relocation of the water meter.

Its current location will pose as an obstruction during the demolition phase • Planting material cause may obstruction during construction.
Contractor to consult with DOWASCO to relocate the meter prior to demolition.

All planting material will have to be removed from the building 28 7.2 Disclosure This ESMP is a working document and involves numerous engagements with different stakeholders prior and during construction.

The ESMP will be disclosed on the EALCRP PIU’s website at http://piu.agriculture.gov.dm/safeguards, after it has been reviewed and cleared by the World Bank.

This disclosure will allow for comments and feedback.
Comments and feedback will be incorporated into the final ESMP document.

The final ESMP will be disclosed on the EALCRP PIU’s website at http://piu.agriculture.gov.dm/safeguards, after it has been reviewed and cleared by the World Bank.

7.3 Grievance and Redress Mechanism (GRM) 7.3.1 EALCRP PIU GRM The EALCRP PIU has prepared a project-wide Grievance Redress Mechanism (GRM) to receive and facilitate the resolution of concerns and grievances associated with the PIU and/or project related activities.
Any grievances associated with the renovation of the Delices Forest Service Center will be addressed by the PIU’s GRM.

The GRM can be viewed in detail on the EALCRP PIU’s website at http://piu.agriculture.gov.dm/safeguards.

The GRM will enable the EALCRP PIU to address any grievances against this specific sub-project activity.

It must be noted that this GRM covers grievances that relate to the impacts that the project may have on people and communities.

The GRM process is outlined below.


Receive Grievance Record Grievance Screen Acknowledge Investigat e Act Follow up and Close Out The EALCRP PIU will be responsible for registering, tracking, addressing and resolving any grievances raised by individuals or groups.

Grievances can be submitted to the EALCRP PIU: 29 • Email: A complainant can email the EALCRP PIU to complain.
Complainant will receive email acknowledging complaint and be advised to complete a grievance form and sign (electronic or by reporting to nearest office).
o Project Manager, Kervin Stephenson Email: stephensonke@dominica.gov.dm o Environmental and Social Safeguards Specialist, Michael McIntyre Email: mcintyrem@dominica.gov.dm o Social Safeguards Officer, Kamarsha Sylvester email: sylvesterk@dominica.gov • Write a letter: to the EALCRP PIU, Project Manager, Emergency Agricultural Livelihoods and Climate Resilience Project (EALCRP), 19 King George V St., Roseau, Dominica to complain (respond to letters via telephone or email, inviting complainant to complete an official grievance form/transfer information from letter to grievance form; record complaint in log) • Telephone: Complainants can call the EALCRP PIU at (767) 266 3998 • In Person: Complainants can report to the EALCRP PIU office at 19 King George V St., Roseau, Dominica, to complete and submit a grievance form.
They can also register their complaint directly to the Environmental and Social Safeguards Specialists.

• Anonymous Complaints: are accepted through all above-mentioned channels.

Complainants can submit their grievances without providing personal contact information.

• PIU Project Manager or Staff Complaints: Complainants can telephone, email or write letters to the Permanent Secretary, Ministry of Blue and Green Economy and Agriculture and National Food Security.
A grievance will be acknowledged in writing or email, by the EALCRP PIU within five (5) working days of a grievance being submitted to the EALCRP PIU and high-level cases will be responded within 10-20 working days.

The EALCRP PIU will communicate verbally, written form or email to the complainant, as well as contact the complainant to verify that the grievance has been resolved and also gather any feedback on the grievance process.
Grievances under this GRM are classified as Level 1 (Low Risk), Level 2 (Substantial Risk) and Level 3 (High Risk).

While all grievances are considered important and critical, Levels 2 and 3 are classified as high priority, with Level 3 being the highest priority.

If the complainant is not satisfied with the resolution and/or does not agree with the proposed actions, the EALCRP PIU will need to escalate the matter to the Grievance Committee.
The EALCRP PIU is committed to resolving complainant’s grievance and as required will convene an independent Grievance Committee to resolve the grievance.

The EALCRP PIU will communicate the GRM process to its external and internal stakeholders to raise awareness and offer transparency of how stakeholders can voice their grievances.
30 7.3.2 World Bank Redress Mechanism The Grievance Redress Service (GRS) is an avenue for individuals and communities to submit complaints directly to the World Bank if they believe that a World Bank project has or is likely to have adverse effects on them, their community, or their environment.

The GRS enhances the World Bank’s responsiveness and accountability to project-affected communities by ensuring that grievances are promptly reviewed and addressed.
Any individual or community who believes that a World Bank-supported project has or is likely to, adversely affect them can submit a complaint.

Complaints must be in writing and addressed to the GRS.
They can be sent: • ONLINE – through the GRS website at www.worldbank.org/grs • BY EMAIL at grievances@worldbank.org • BY LETTER OR BY HAND delivery to any World Bank Country Office • BY LETTER to the World Bank Headquarters in Washington at The World Bank Grievance Redress Service (GRS) MSN MC 10-1018 1818 H St NW Washington DC 20433, USA 31 Chapter 8.
ANNEXES Annex 1: Environmental and Social Screening Checklist The form below identifies potential impacts of the proposed activities envisioned under Emergency Agricultural Livelihoods and Climate Resilience Project (EALCRP).

Many of the actions or activities have low or negligible potential negative impacts, such as purchase of equipment, raw materials and supplies.
Some may have impacts that are typical for small construction or rehabilitation projects, such as repair of damaged infrastructure, buildings, or facilities.
Section A: Background information Subproject Name Subproject Purpose Restoration of Key Infrastructure in Forestry ☒ New Structure ☐ Expansion of existing structure ☐ Renovation of existing structure ☐ Construction of waste disposal system Delices Subproject Location Subproject property ownership ☒ Government of the Commonwealth of Dominica ☒ Own ☐ Lease Agreement Subproject current property use ☐ Industrial ☒ Commercial ☒ Forest Administrative Office Subproject Component Estimated Investment Expected Start/Completion Date February 2023 to April 2023 ☐ Residential Rehabilitation of Delices Forest Service Centre Section B: Construction Issues Will the sub-project: Demolish existing structures and require disposal of construction materials?
?

Demolish existing structures and require disposal of hazardous materials?

Involve the generation of a significant amounts of solid and liquid waste?

Construction work generate emissions to the atmosphere (dust, odours, fumes)?

Construction work cause a noise nuisance due to the operation of heavy machinery and other on-site activities?

Construction work produce significant amounts of runoff, change drainage patterns and/or erosion?

Construction work affect traffic or public safety?


Cause physical changes in topography and land use?

Yes X X X No X X X X X If answers to any of the above is ‘yes’, please include an ESMP in sub-project implementation.

32 YES Section C: Environmental Issue Will the sub-project Create a risk of increased soil erosion?

Create a risk of increased deforestation?

Create a risk of increasing any other soil degradation?

Affect soil salinity and alkalinity?


Divert the water resource from its natural course/location?

Cause pollution of aquatic ecosystems by sedimentation and agro- chemicals, oil spillage, effluents, etc.?

Introduce exotic/alien plants or animals?

Involve drainage of wetlands or other permanently flooded areas?

Cause poor water drainage and increase the risk of water-related diseases such as Dengue?

Reduce the quantity of water for the downstream users?
Result in the lowering of groundwater level or depletion of groundwater?

Create waste that could adversely affect local soils, vegetation, rivers and streams or groundwater?

Reduce various types of livestock production?

Focus on biomass/bio-fuel energy generation?

If answers to any of the above is ‘yes’, please include an ESMP in sub-project implementation.

YES Section D: Socioeconomic Issues & Community Health and Safety Will the sub-project: Displace people from their current settlement?
Cause an influx of labour?

Interfere with the normal health and safety of the worker/community?

Reduce the employment opportunities for the surrounding communities?

Reduce settlement (no further area allocated to settlements)?

Reduce income for the local communities?

Increase safety concerns due to introduction of the project?

Increase exposure of the community to communicable diseases such as HIV/AIDS?

Induce conflict?

Introduce new practices and habits?


Lead to child delinquency (school drop-outs, child abuse, child labour, etc.?

Lead to gender disparity or gender-based violence?

Lead to poor diets?

Lead to social evils (drug abuse, excessive alcohol consumption, crime, etc.)?

Cause an increased exposure of the community to COVID-19?
NO X X X X X X X X X X X X X X NO X X X X X X X X X X X X X X X 33 Section E: Natural Habitat Will the sub-project: Be located within environmentally sensitive areas (e.g., intact natural forests, mangroves, wetlands) or threatened species?

YES NO X NB: If the answer is yes, the sub-project should prepare a Natural Habitats Plan (see ESMP).
Adversely affect environmentally sensitive areas or critical habitats – wetlands, woodlots, natural forests, rivers, protected areas including national parks, reserves or local sanctuaries, etc.)?

NB: If the answer is yes, the sub-project should not proceed.

Affect the indigenous biodiversity (flora and fauna)?

NB: If the answer is yes, the sub-project should not proceed.

Cause any loss or degradation of any natural habitats, either directly (through project works) or indirectly?
NB: If the answer is yes, the sub-project should not proceed.

Affect the aesthetic quality of the landscape?

Reduce people’s access to the pasture, water, public services or other resources that they depend on?

Increase human-wildlife conflicts?

Use irrigation system in its implementation?


X X X X X X X NB: If the answers to any of the above is ‘yes’, please include an ESMP/Natural Habitat Management Plan with sub-project application Section F: Pesticides and Agriculture Chemicals Will the sub-project: Involve the use of pesticides or other agricultural chemicals, or increase existing use?

Cause contamination of watercourses by chemicals and pesticides?

Cause contamination of soil by agrochemicals and pesticides?
Experience effluent and/or emissions discharge?

Export produce?

Involve annual inspections of the producers and unannounced inspections?

Require scheduled chemical applications?

Require chemical application even to areas distant away from the focus?

Require chemical application to be done by vulnerable group (pregnant mothers, chemically allergic persons, elderly, etc.)?

YES X NO X X X X X X X If the answer to the above is ‘yes’, please consult the IPMP that has been prepared for the project.
34 Section G: Vulnerable and Marginalized Groups meeting requirements for OP 4.10 YES Are there: People who meet requirements for OP 4.10 living within the boundaries of, or near the project?

Members of these VMGs in the area who could benefit from the project?

VMGs livelihoods to be affected by the subproject?

Affect vulnerable people and underserved groups (e.g., children, elderly poor pensioners, physically challenged, women, particularly head of households or widows, etc.)?
Require temporary relocation for a vulnerable population affected (children, physically challenged, elderly, minority group etc.)?

NO X X X X X If the answer to any of the above is ‘yes’, please consult the IPP that has been prepared for the project.

Section H: Land Acquisition and Access to Resources Will the sub-project: Require acquisition of land (public or private) (temporarily or Permanently) for its development?

Use land that is currently occupied or regularly used for productive purposes (e.g.
gardening, farming, pasture, fishing locations, forests)?

Displace individuals, families or businesses?

Result in temporary or permanent loss of crops, fruit trees and Pasture land?

Adversely affect small communal cultural property such as funeral and burial sites, or sacred groves?

Result in involuntary restriction of access by people to legally designated parks and protected areas?

Be on monoculture cropping?


YES NO X X X X X X X If the answer to any of the above is ‘yes’, please consult the mitigation measures in the ESMF, and if need be adopt the ARAP guidelines.

Section I: Proposed action Summarize the above: Based on the above screening checklist results and the risk identified an ESMP will be developed.
All the above answers are ‘No’ There is at least one ‘Yes’ (ii) Guidance • If all the above answers are ‘No’, there is no need for further action; If there is at least one ‘Yes’, please • describe your recommended course of action (see below).

35 (iii) Recommended Course of Action Activities and actions with low potential E&S risk require no further safeguards actions.
Those with moderate potential risk will be managed using the general ESMF for the Emergency Agricultural Livelihoods and Climate Resilience Project (EALCRP), and will typically require that an ESMP be developed.

Those with moderate to substantial potential risk will be managed using the tools in the general ESMF for the Emergency Agricultural Livelihoods and Climate Resilience Project (EALCRP) along with the additional safety guidance and information provided in this ESMP.
36 Annex 2: Sample Code of Conduct EXAMPLE OF CONTRACTOR’S CODE OF CONDUCT ENVIRONMENTAL, SOCIAL, HEALTH AND SAFETY Our Commitment Our Company is committed to protecting the environment in which we operate and take pride in conducting our business in a safe and responsible manner.

We recognise and accept our responsibility to develop our resources with awareness of the environmental, economic and social needs and expectations of stakeholders.
Our Organisation promotes freedom of expression and open communication and we expect all employees to follow our Code of Conduct.

All third-party contractors, sub-contractors, consultants and volunteers are also expected to comply with the code as a condition of their engagement with the Organisation.

No operation is considered effective or complete without proper attention to safety and the environment as detailed in our Organisation’s Health and Safety Manual (include as Appendix 1).
The health and safety of all employees and those visiting the organisation/ work site are of the utmost importance.

We are committed to providing and maintaining a working environment that is safe and without risk to health and safety and is committed to complying with all relevant legislative and project requirements.

All parties are expected to demonstrate a high degree of tolerance and respect for all stakeholders associated with the project, including the indigenous and local communities.
The guidelines to be followed are set out in the Code of Conduct requirements below and shall apply to all associated project personnel.

Code of Conduct Requirements This Code of Conduct for the project identifies the behaviour which we require from all project personnel and is aligned with our Organisation’s Code of Conduct (add as Appendix).
Our workplace is an environment where unsafe, offensive, abusive or violent behaviour will not be tolerated and where all persons should feel comfortable raising issues or concerns without fear of retaliation.

In this document the term “child” / “children” means any person(s) under the age of 18 years.

Code of Conduct Each personnel shall comply with the following: 1.

Carry out his/her duties competently, diligently and in accordance with best practice 2.
Comply with applicable laws, rules, and regulations of the Country 37 We will inform our personnel of the applicable legal requirements as identified in the ESMP to ensure that they are aware of the requirements.

Each member of our team will be required to familiarise themselves with this document.

3.
3.

Compliance with applicable health and safety requirements to protect the local community (including vulnerable and disadvantaged groups), and the Employer’s Personnel, including wearing prescribed personal protective equipment [PPE], preventing avoidable accidents and a duty to report conditions or practices that pose a safety hazard or threaten the environment It is our duty to ensure that the health and safety requirements are strictly adhered to by all parties.
As part of our employment agreement we require that all our personnel must be knowledgeable of our Health and Safety Policy and be informed of the actions required as detailed in the Health and Safety Manual which is in accordance with the ISO 45001.

Through our Environmental Specialist, we will assess if any training is required and ensure that this is done.

We will also equip all our personnel with the required PPE, and it is mandatory that this be used once on the project site.
Safety in workplaces is an un-compromised condition and a mutual and shared responsibility for all our employees.

4.

Compliance with environmental requirements identified in the ESMP including erosion control, storm water control, noise and dust control, site cleanliness and disposal of excavated materials and construction wastes 5.
Compliance with COVID-19 Prevention Protocols of the Ministry of Health, Wellness and New Health Investment and other national guidance and related protocols We will remain alert of changing outbreak conditions, locally and regionally, including as they relate to possible community spread or clusters and implement infection prevention measures accordingly.
In accordance with OSHA guidelines, our ESHS Experts will periodically assess the hazards to which our personnel and the contractor’s workers may be exposed, evaluate the risk of exposure and select, implement, and ensure workers use controls to prevent exposure.

All project workers will be trained on the signs and symptoms of COVID-19 and an explanation of how the disease is potentially spread, including the fact that infected people can spread the virus even if they do not have symptoms.
In collaboration with the Project’s Safeguards Specialists, we will implement where necessary, standard operating procedures and employee training as it relates to potential exposures.

Through our Environmental Safeguards expert, we will ensure to keep updated on all the latest COVID-19 protocols of the Ministry of Health, Wellness and New Health Investments and inform our personnel to ensure these are complied with.

6.
6.

Compliance with applicable emergency operating procedures and health and safety requirements All personnel will be informed of the emergency procedures as prescribed in the project’s ESMP and the CESMP which must be strictly complied with.

38 7.
38 7.

Duty to report work situations that he/she believes are not safe or healthy and remove himself/herself from a work situation which he/she reasonably believes presents an imminent danger to his/her life or health Each personnel must assume responsibility for his/ her own health and safety and should report any concerns immediately to the Project Manager/ Site Supervisor, Resident Engineer or ESHS Experts.

8.
8.

Respecting reasonable work/ site instructions (including regarding environmental and social norms) All our personnel are required to be aware of related work/ site instructions and are expected to comply.

This is a condition of employment and subject to disciplinary measures if violated.

9.

The use of illegal substances Our Organisation has a zero tolerance for the use of illegal substances - all drugs, alcohol and any controlled substances or medicines.
This may result in immediate dismissal if violated.

If required, we are prepared to engage the services of a Medical Professional to perform testing for any illegal substances.

10.

Sanitation requirements (for example, to ensure workers use specified sanitary facilities provided by their employer and not open areas) Adequate sanitary facilities and well-equipped hand-washing stations are expected to be provided by the contractor on this project.
It is also expected that the contractor will ensure that these facilities are frequently cleaned and sanitised especially given the risks of COVID-19, as a prevention measure.

All project personnel, including the contractor’s, are required to use these facilities and will be reminded of this should the need arise.

11.
11.

Non-Discrimination and respect in dealing with the Indigenous Peoples, the local community (including vulnerable and disadvantaged groups), the Employer’s Personnel, the Contractor’s Personnel and other related Project Personnel (for example on the basis of family status, ethnicity, race, gender, religion, culture, language, marital status, birth, age, disability, or political conviction) Our Organisation firmly believes in respect for all and that everyone should be treated fairly.
We will ensure that our personnel are aware of the requirements as prescribed in these project documents and abide by them as a condition of employment.

We commit to working in close collaboration with all Social Specialists on this project to ensure that there is non-discrimination and respect for all stakeholders on the basis of gender, age, physical or mental disability, race, language, culture, political affiliation, philosophic or religious beliefs or any other reason.
39 Interactions with community members and any affected persons (for example to convey an attitude of respect and non-discrimination, including to their culture and traditions) All employees are expected to fulfill their duties with integrity and respect toward customers, stakeholders, and the community.
We are committed to the highest social performance standards in a manner that respects the environment, culture and customs of the communities within the area of direct and indirect influence of the project.

Any complaints received from communities or stakeholders will be investigated in accordance with the Project’s Grievance Redress Mechanism.

12.
12.

Sexual harassment (for example to prohibit use of language or behaviour, in particular towards women or children, that is inappropriate, harassing, abusive, sexually provocative, demeaning or culturally inappropriate) 13.

Violence, including sexual and/or gender-based violence (for example acts that inflict physical, mental or sexual harm or suffering, threats of such acts, coercion, and deprivation of liberty) 14.
Exploitation including sexual exploitation and abuse (for example the prohibition of the exchange of money, employment, goods, or services for sex, including sexual favors or other forms of humiliating, degrading behaviour, exploitative behavior or abuse of power) Sexual harassment, violence, including gender based, and exploitation are behaviours which are expressly prohibited in our Organisation.
These are identified as a form of harassment based on the misuse of power in human relationships and can be defined as behaviours intended to disturb, threaten or upset.

Some examples of behaviours associated with these elements are listed in Appendix 1.

Any complaints or reports received from communities or stakeholders in this regard will be investigated by our Social Specialist in accordance with the Project’s Grievance Redress Mechanism.

15.
15.

Protection of children (including prohibitions against abuse, defilement, or otherwise unacceptable behavior with children, limiting interactions with children, and ensuring their safety in project areas) The rights of the child shall be protected and any observed or reported cases of infringement will be swiftly investigated and required measures taken if deemed necessary.
Our Social Specialist will collaborate with the Ministry of Youth Development and Empowerment, Youth at Risk, Seniors Security and Dominicans with Disabilities; Social Welfare Division in this regard.
The Contractor ESHS Expert should provide training related to the environmental and social aspects of the Contract, including on health and safety matters, sexual exploitation and abuse and sexual harassment Our ESHS Experts will provide short training sessions and concise information leaflets to assist personnel in being informed of the environmental, social and health and safety aspects of the project.

40 16.
40 16.

Avoidance of conflicts of interest (such that benefits, contracts, or employment, or any sort of preferential treatment or favours, are not provided to any person with whom there is a financial, family, or personal connection) Our Company shall deal fairly and lawfully with all our Clients in accordance with our Business Ethics.

We expect our employees to avoid any personal, financial or other interests that might hinder their capability or willingness to perform their job duties.
Employees are encouraged to perform self-checks when in doubt or faced with a difficult situation to ensure that decisions are lawful.

17.

Avoidance of issues associated with influx of labour, both social and environmental These issues include many of those identified in this Code, such as sexual exploitation, sexual harassment or gender-based violence.

Both our Environmental Specialist and Social Specialist will conduct the requisite monitoring to ensure that these issues are avoided.
If any issue should arise or complaint receive, it will be investigated, and the necessary action taken.

A report will also be prepared and follow-up done.

18.

Protection and proper use of property (for example, to prohibit theft, carelessness or waste) In accordance with our Organisation’s Code each employee must ensure that their actions comply with and are within the meaning and intent of all applicable laws and regulations.

19.
19.

Duty to report violations of this Code Each employee has a duty to report any violations or suspected violations of the code.

The person by virtue of this Code will be protected from retaliation.

Any reports of violations received will be investigated.

20.

Non-retaliation against workers who report violations of the Code, if that report is made in good faith.

Our Organisation is committed to the highest standards of good governance, transparency, honesty, integrity, and accountability.
Any of our employees who report unethical conduct or violation of the Code are protected from reprisal.

Any reprisal or attempted reprisal against an employee who makes a report in accordance with the Code is considered to be in breach of the Code of Business Conduct.

If any employee should feel that they have been discriminated against as a result of reporting unethical conduct or violation of the Code, there is an opportunity to report the discriminatory actions directly to the Company’s Director.
Our Personnel are not allowed to smoke illegal substances (drugs) or make open fire in the Project area, including project’s vehicles.

Our Personnel are not allowed to carry firearms, explosives, ammunition, or other arms in the Project Area, including Project’s vehicles.

41 Our personnel are not allowed to have pets in the Project area.

Our personnel are not allowed to fish, hunt or remove vegetation from the Project area or surrounding properties.
Our Personnel are not allowed to use open areas instead of the designated sanitary facilities.

Any damage caused by the Project to any property in the Project Area must be immediately informed to the Representative of the Contractor in the Project.
Implementation of the Code of Conduct The project requires that implementation of the Code of Conduct detail the measures to ensure that there is compliance, these include how the Code will be: Introduced into the Conditions of Contract - Communicated to Personnel - - Violations will be addressed - Monitored and Reported for Compliance - Communicated to Communities in case of concerns Our ESHS Experts on this project will work in close collaboration with the Project’s Environmental Safeguards Specialist and Social Safeguards Specialist to ensure compliance with the Code of Conduct during works.
Communication to Personnel All employees must be open to communication with their colleagues, supervisors or team members.

We promote freedom of expression and open communication, but we expect all employees to follow our Code of Conduct.

The Code of Conduct for the project will be provided to each personnel on the project and will also be available in hard copy in the project office.
Our ESHS Specialists will provide short training sessions and concise information leaflets to assist personnel in being informed of the environmental, social and health and safety aspects of the project.

Training for workers will include awareness of hazards in the project area, health and safety procedures, emergency response, first-aid, incident reporting and accident prevention.
Safety and other ESHS issues will also be highlighted at tool-box meetings and monthly project meetings by the Project Manager, Resident Engineer and/or ESHS Specialists.

ESHS orientation will also be done for new personnel.

Personnel will have an open communication channel through our ESHS Experts or other designated person to be able to ask questions and make recommendations at any time during the project implementation.
Engagement Conditions and Consequences of Code Violations All our personnel on the Project are personally responsible for ensuring that their behaviour complies with this Code of Conduct.

The Code of Conduct is clearly articulated in this document and is written in plain language (English).
As part of the conditions of engagement, each employee on this project is expected to sign an agreement indicating that they have: 42 - Received a copy of the code - Had the code explained to them - Acknowledged that adherence to this Code of Conduct is a condition of employment; and - Understood that violations of the Code can result in serious consequences, up to and including dismissal, or referral to legal authorities Clarifying queries and obtaining advice – Our personnel may consult with our Compliance Officer if there are any questions or concerns about this Code of Conduct, or if advice is needed.
Our Environmental Specialist and Social Specialist on this project will also be available to provide guidance on the Code.

We will take appropriate investigative action where this Code is breached.

Our Organisation may have to take disciplinary action against employees who repeatedly or intentionally fail to follow our Code of Conduct.

Disciplinary actions will vary depending on the violation.
Possible consequences include: - Reprimand - Demotion - Suspension or termination for more serious offenses - Detraction of benefits for a definite or indefinite period - Legal action may also be taken Monitoring and Reporting If any person observes behaviour that he/she believes may represent a violation of this Code of Conduct, or that otherwise concerns him/her, he/she should raise the issue promptly.

This can be done in either of the following ways: 1.
Contact [enter name of the Consultant’s Social Safeguard’s Expert and Environmental Safeguard’s Expert or another individual designated by the Company to handle these matters] in writing at this address [insert address ] or by email [insert email address] or by telephone at [insert telephone # ] or in person at [ insert designated location and available times] 2.

Call [ insert telephone #] to reach the Project’s hotline (if any) and leave a message including contact number and brief information of issue 3.
Utilise the Project’s Grievance Redress Mechanism (GRM), available via telephone [insert #], in person at the PCU Office [insert address], through the project website [insert web address] or via the GRM App [insert link, if available] The person’s identity will be kept confidential, unless reporting of the allegation is mandated by law of the Commonwealth Of Dominica.

Anonymous complaints or allegations may also be submitted and will be given all due and appropriate consideration.
We take seriously all reports of possible misconduct and will investigate and take appropriate action in collaboration with the Project.

We will provide warm referrals to service providers that may help support the person who experienced the alleged incident, as appropriate.

There will be no retaliation against any person who raises a concern in good faith about any behaviour prohibited by this Code of Conduct.

Such retaliation would be a violation of this Code of Conduct.
43 Responsibility - Overall responsibility for monitoring and reporting lies with our Project Manager/ Site Supervisor, Resident Engineer and Social Specialist and Environmental Specialist or another designated representative on this project.

Periodic assessments will be done by these designated personnel to ensure compliance with the Code of Conduct.

Review will also be done at least every six (6) months or as may be necessary to ensure the Code remains current.
Reports will be done monthly as part of the project’s progress reporting or immediately if there is an incident.

Other reports may be prepared as requested by the Project .
Communication to Communities In collaboration with the Project’s Social Safeguards Specialist and Environmental Safeguards Specialists we will if required: - - Inform the community of our roles and responsibilities on the project Inform the community and stakeholders of the requirements of the Code of Conduct, measures for compliance and our commitment to upholding the Code - Respond to the concerns and views of stakeholders in a timely and open fashion - Engage interested parties, when necessary, to discuss our operations and the relationship to affected communities and the environment - Provide clear and candid environmental information about the operations of the Project and our responsibilities.
Appendix 1 Behaviours Constituting Sexual Exploitation and Abuse and Behaviors Constituting Sexual Harassment The following non-exhaustive list is intended to illustrate types of prohibited behaviours: Examples of Sexual Exploitation and Abuse include, but are not limited to: - Consultant’s Personnel tells a member of the community that he/she can get them jobs on the project work site (e.g.
cleaning, masonry) in exchange for sex or sexual acts - Consultant’s Personnel says that he can give priority for job considerations to women in exchange for sex - Consultant’s Personnel rapes, or otherwise sexually assaults a member of the community or project stakeholder - Consultant’s Personnel denies a person access to the site unless he/she performs a sexual favor - Consultant’s Personnel tells a person applying for employment under the Contract that he/she will only hire him/her if he/she has sex with him/her Examples of Sexual Harassment or Sexual Misconduct include, but are not limited to: 44 - Consultant’s Personnel comments on the appearance of another personnel’s or community member (either positive or negative) and sexual desirability - When a Consultant’s Personnel complains about comments made by another Consultant’s/ Contractor’s Personnel on his/her appearance, the other Consultant’s/ Contractor’s Personnel comment that he/she is “asking for it” because of how he/she dresses - Unwelcome touching of a Consultant’s/ Contractor’s or Employer’s Personnel or community member by another Consultant’s/ Contractor’s Personnel - Consultant’s Personnel tells another Consultant’s/ Contractor’s Personnel that he/she will get him/her a salary raise, or promotion if he/she sends him/her naked photographs of himself/herself.
FOR CONTRACTOR’S PERSONNEL: I have received a copy of this Code of Conduct written in a language that I comprehend.

I understand that if I have any questions about this Code of Conduct, I can contact [enter name of Contractor’s contact person(s) with relevant experience (including for sexual exploitation, abuse and harassment cases) in handling those types of cases] requesting an explanation.
Name of Contractor’s Personnel: [insert name] Signature: ____________________________________________________________________ Date (day/month/year/): _________________________________________________________ Counter signature of authorized representative of the Contractor: Signature: _____________________________________________________________________ Date (day/month/year/): ____________________________________________________ 45