Source document: https://docs-lawep.s3.us-east-2.amazonaws.com/1697723434625.pdf (Dominica)
Environmental and Social Management Plan (ESMP) Rehabilitation of the Ground Floor of the DBMC Building (Vanoulst House) Subcomponent B.1: Restoration of Key Infrastructure in Agriculture December 8, 2021 DRAFT FOR PUBLIC DISCLOSURE Front view of DBMC Building Side view of DBMC Building Revision Record Revision Date Author(s) Remarks October 4, 2021 EALCRP PIU & IST Preliminary Draft December 8, 2021 EALCRP PIU & IST Draft – Internal Review Draft – Disclosure and Consultation 1.

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Table of Contents Chapter 1.

Introduction and Background ..................................................................................................... 3 1.1 1.2 EALCRP Project Overview and Objectives ..................................................................................... 3 ESMF and ESMP for the Project .................................................................................................... 3 Chapter 2.
Project Description ...................................................................................................................... 4 2.1 2.2 Location and Regional Setting ....................................................................................................... 4 Project Details and Status ............................................................................................................. 4 2.2.1 2.2.2 2.2.3 Study of Alternatives ............................................................................................................. 4 Floor Plan Layout .................................................................................................................. 5 Disposal of Construction Waste and Materials ..................................................................... 7 Chapter 3.
The Legal and Administrative Framework .................................................................................. 8 3.1 Relevant National Laws and Policies for the project .................................................................... 8 3.1.1 3.1.2 3.1.3 3.1.4 Ministry of Health COVID 19 Guidelines ............................................................................... 8 Physical Planning Act (2002) ................................................................................................. 8 Solid Waste Management Act 2002 ...................................................................................... 8 Pesticides Control Act (Cap.
40:10) ....................................................................................... 9 3.2 World Bank Social and Environmental Safeguards ....................................................................... 9 3.2.1 3.2.2 Safeguard Policies ................................................................................................................. 9 EHS Guidelines ...................................................................................................................... 9 Chapter 4.
Potential Environmental and Social Impacts ............................................................................ 10 4.1 Renovation Phase ....................................................................................................................... 10 4.1.1 4.1.2 4.1.3 4.1.4 4.1.5 4.1.6 COVID -19 Measures ........................................................................................................... 10 Site Access and Security ...................................................................................................... 10 Noise and dust control ........................................................................................................ 10 Debris and solid waste management .................................................................................. 11 Traffic management ............................................................................................................ 11 Community Health and Safety Plan .................................................................................... 11 4.1.7 Workers Health and Safety ................................................................................................. 12 4.1.8 Pest Management ............................................................................................................... 12 4.2 Operation Phase.......................................................................................................................... 12 Chapter 5.
Mitigation Measures ................................................................................................................. 14 5.1 Renovation Phase ....................................................................................................................... 14 1 5.2 Operation Phase.......................................................................................................................... 19 Chapter 6.
Project Management and Institutional Arrangements ............................................................. 21 6.1 6.2 6.3 ESMP Implementation Responsibilities ...................................................................................... 21 Contractor Responsibilities ......................................................................................................... 22 Supervision, Monitoring and Reporting ...................................................................................... 22 Chapter 7.
Stakeholder Engagement .......................................................................................................... 23 7.1 Stakeholder Identification........................................................................................................... 23 7.1.1 7.1.2 Occupants of DBMC Building to be Impacted ..................................................................... 23 Final Beneficiaries of DBMC ground floor Renovations ...................................................... 23 7.2 7.3 7.4 Consultations .............................................................................................................................. 23 Disclosure .................................................................................................................................... 25 Grievance and Redress Mechanism (GRM) ................................................................................ 26 7.4.1 EALCRP PIU GRM ................................................................................................................. 26 7.4.2 World Bank Redress Mechanism ........................................................................................ 27 Chapter 8.
ANNEXES ................................................................................................................................... 29 Annex 1: Environmental and Social Screening Checklist ............................................................................ 29 Annex 2: COVID 19 GUIDELINES FOR CONSTRUCTION AND CIVIL WORKS ................................................. 33 Annex 3: ESF/SAFEGUARDS INTERIM NOTE - COVID 19 CONSIDERATIONS IN CONSTRUCTION/CIVIL WORKS PROJECTS ....................................................................................................................................... 40 Annex 4: Sample Code of Conduct ............................................................................................................... 1 Annex 5: DBMC Building – Ground Floor Design-as an attachment ............................................................. 4 2 Chapter 1.
Introduction and Background 1.1 EALCRP Project Overview and Objectives After the passage of Hurricane Maria in 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.

Subcomponent B.1 will help in the process of restoring key public sector infrastructure and assets damaged by the hurricane and restore the essential public services that farmers livelihoods depend on.
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 avoided, mitigated, or compensated.
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.

This ESMP describes the status and details of the project, due-diligence of the works accomplished to date, and the evidence and certification that the facility has and will continue to be undertaken in compliance with applicable World Bank safeguards requirements and laws of Dominica.
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 ground floor of the DBMC Building (Vanoulst House) is compliant with national and regional environmental regulations, and consistent with international best practices and World Bank safeguards policies, and the ESMF created for the project.1 Specifically, it will ensure the protection of workers and Staff of the Ministry of Blue and Green Economy, Agriculture and National Food Security, Central Agricultural Extension Office and Contractors from environmental and social impacts and risks 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 ground floor of the DBMC can be accessed at EALCRP website http://www.piu.agriculture.gov.dm/.

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 Chapter 2.
Project Description 2.1 Location and Regional Setting The proposed project site is the ground floor of the Dominica Banana Marketing Corporation (DBMC) Building also known as Vanoulst House, with coordinates of 15°18'23"N latitude and 61°23'20"W longitude, located on Charles Avenue, Goodwill.

The proposed building (ground floor) will be used as EALCRP PIU main office for administrative function.
The first floor is occupied by two offices; the back section is used by Housing Division and the front section is used by the Government Housing Loan Board.

The second floor of Vanoulst House is being occupied by Land and Surveys.

The building is L-shape with an area of 5,614 square feet, with the Central Agricultural Extension Office occupying the longer part of the L (The back section).
Figure 1: Site Location Map 2.2 Project Details and Status 2.2.1 Study of Alternatives The Project Implementation Unit of the Emergency Agricultural Livelihood and Climate Resilient Project (EALCRP) office was initially located at the DAPEX Building at Fond Cole.

However, during its occupation several health and safety concerns were identified: • The DAPEX Building proved to be unsafe structure due to several cracks in the building walls and ceiling and water leaks during heavy rains.
A structural assessment of the building was undertaken, and it confirmed structural deficiencies and recommended that the upstairs part of the building be repaired.

• Workspace is insufficient to accommodate all PIU staff.

The limited workspace results in some PIU staff having to work at one table.

This situation has been further exacerbated 4 by the COVID 19 pandemic which is affecting Dominica and the EALCRP PIU adhering to the COVID 19 Protocols that are mandated by the Government of Dominica.
Against this background, the EALCRP PIU identified alternative office space at 19 – 21 King George V Street, Roseau, Commonwealth of Dominica, as a temporary solution.

This location also presents a number of concerns such as inadequate workspace for PIU staff and no parking for PIU staff and beneficiaries.

Parking is very difficult as the office is situated along a heavily used bus stop.
While the EALCRP PIU has separated its operations it is important for all staff to be housed at one specific location, given the need for the team to interact and correspond among each other to address project activities and respond to beneficiaries.

The proposed solution is to renovate the ground floor of the DBMC Building to accommodate the entire EALCRP PIU staff, as the DBMC building is assigned to the Division of Agriculture, but is not currently being fully utilised.
This option is cost effective due to the high rental cost for additional office space located at 19 – 21 King George V Street, adequate workspace to accommodate all the EALCRP PIU staff and no safety or structural issues.

On completion of the EALCRP project, the renovated ground floor will be handed over the Division of Agriculture.
2.2.2 Floor Plan Layout The renovation of the ground floor of the DBMC Building will only be inside and will consist of minor civil works, such as electrical, tile removal and re-tiling, plumbing, dressing of windows, partitioning for office space and the removal of unwanted materials/debris.

Construction activities for this renovation of the office is expected to occur over a three (3) month period.
Upon completion of the refurbishment, the ground floor is expected to accommodate the administrative offices of the EALCRP PIU.

The ground floor will be divided into offices and cubicles to provide sufficient space for 20 staff including 11 support staff of the PIU.

The area will also be equipped with a Kitchenette, two separate male and female washrooms and filing/storage area.
At the end of the EALCRP Project, the refurbished office space will be reassigned to the Division of Agriculture as shown in the floor plan layout (Annex 5).

The floor plan of the ground floor was done by Public Works Department Architect for the Division of Agriculture.

The Division of Agriculture is currently located at the Botanical Gardens under several roofs.
A decision has been taken to have the Division under one roof, which is the ground floor of the DBMC building, the layout floor plan was therefore design for such accommodation.

The ground floor layout can be divided into three sections: a) Section 1 (see floor layout 1G to 3G) is vacant and will be the main section of the proposed EALCRP PIU Office.

The section will hold seven offices, a kitchenette, washrooms and a reception area.
b) Section 2 (layout 3E to 5E) is currently housed by the Central Agricultural Regional Extension Office, this will be modified to also house the South Agricultural Regional Extension Office 5 c) Section 3 (5E to 7E) is vacant and will be occupied by the EALCRP staff until the end of the project, after which it will be taken up by the Plant Quarantine Unit, of the Division of Agriculture.
This section is infested with termite and will be treated according to the Integrated Pest Management Plan (IPMP) of this (EALCRP) Project.

A detailed review of the proposed floor plan has identified some key omissions in the design layout.

These are as follows: o The exit door needs to be larger, preferably a double door to facilitate a quick exit from the building (emergency).

o Location of kitchenette, which makes it cumbersome to navigate through several offices/cubicles to access.
o There is no meeting or conference room.

o The proposed storeroom could be used as a much-needed extra office o Electrical wiring would need to be replaced and installed o Floor would need to be tiled o Miscellaneous items were identified for disposal.

Disposal of these items, especially hazardous materials will be done in accordance and approval of the Dominica Solid Waste Management Corporation.
o Termite infestation was noted, and a pest management treatment will have to be undertaken prior to occupation and during the renovation activities Figure 3: Electrical and Ceiling replacement Figure 4: removal and replacement of tiles Figure 5: Materials for disposing Figure 6: Termite infestation 6 2.2.3 Disposal of Construction Waste and Materials The reconstruction works of the ground floor is not expected to generate significant volume of waste.
The waste generated from the demolition works will primarily consist of: • old tiles estimated at 11,818 kgs together with its associated mortar and grout • 2304 board feet (192 cubic feet) of termite infested wooden partition (Figure 6) • Electrical conduit tubing and associated electrical wires are estimated at 50kg of electrical waste.

All construction waste materials will be disposed at the Fond Cole landfill which is operated by the Dominica Solid Waste Management Corporation.

7 Chapter 3.
7 Chapter 3.

The Legal and Administrative Framework The ESMP was prepared against the background of ensuring the proposed DBMC building renovation 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.

This ESMP attempts to address the most significant environmental and social impacts and risks associated with the proposed DBMC building rehabilitation, such as covid-19 guidelines, waste management, integrated pesticide management, physical planning, etc.
3.1 Relevant National Laws and Policies for the project 3.1.1 Ministry of Health COVID 19 Guidelines Since the outbreak and spread of COVID-19, people have been mandated by national policies and regulations to exercise social distancing and to avoid public gatherings to prevent and reduce the risk of the virus transmission.
Countries have taken various restrictive measures, some imposing strict restrictions on public gatherings, meetings and people’s movement, and others advising against public group events.

At the same time, the general public has become increasingly aware and concerned about the risks of transmission, particularly through social interactions at large gatherings.
The major risk of the COVID-19 is its mode of transmission and that an increase in physical contact as well as shared social spaces, enables the spread of the coronavirus.

It is important that the established COVID protocols of the World Health Organization (WHO) and the Ministry of Health, Wellness and New Health Investment be applied to Emergency Agricultural Livelihoods and Climate Resilience Project (EALCRP) activities, PIU personnel, beneficiaries and contractors.
3.1.2 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.
This Act does not appear to be relevant at this stage, as the proposed building rehabilitation will be limited to internal modifications and not result in an expansion/increase of the existing building footprint.

3.1.3 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 8 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.

This Act is relevant as the rehabilitation of the DBMC building and the EALCRP PIU’s operations will generate waste.

3.1.4 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 DBMC building will adhere to pest management plan.

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 please thorough (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 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 9 Chapter 4.
Potential Environmental and Social Impacts The proposed renovation of the DBMC building is expected to generate positive benefits such as increasing available office for the Government of Dominica, employment of contractors, improved working environment, etc.

Notwithstanding the numerous positive benefits expected to accrue from the project, the following negative environmental and social impacts have been identified for renovation works on the ground floor of Vanoulst House.
Mitigation measures for each of the impacts and risks identified below are presented in Chapter 5.

4.1 Renovation Phase Prior to the commencement of site preparation, there is a need for contractor to adopt COVID 19 measures to reduce health risks of construction workers, and neighbouring offices and small snackettes (food businesses) (Annexes 2 and 3).
Renovation activities may pose significant hazards related to the stockpiling and removal of construction debris, fugitive dust formation from raw materials, noise from equipment and improper use of tools and equipment by construction workers, disposal of construction debris and waste materials.

Potential fall of materials or tools, as well as ejection of solid particles from abrasive or other types of power tools can result in contractor and workers injuries.
4.1.1 COVID -19 Measures The Government of Dominica’s COVID procedures require contractors to protect their operations and workers to reduce the risk of spread of the COVID 19.
As a result, the EALCRP PIU will require the contractor to prepare and submit a detailed COVID19 Plan demonstrating their ability to safeguard health and safety of workers/employees while on site in compliance with the GoCD and consistent with the WB guidelines on COVID-19 precaution measures for the construction sector (See Annex 2 and 3).

The COVID 19 Plan will be provided to all employees working on site.
4.1.2 Site Access and Security It was noted that there is one main entrance providing access to the ground, first and second floor of Vanoulst House.

Therefore, anyone wishing to access Land and Surveys located on the second floor, Housing Division located on the first-floor back section or the Government Housing Loan- the front section of the first floor, would have to pass through this main entrance.

The major risk was outlined and the mitigation measure to be taken by the contractor.
Access to the building shall be controlled by directing the general public away from the worksite while trying to access the upstairs offices.

4.1.3 Noise and dust control During renovation activities, noise and vibration may be caused by the operation of motorized equipment or power tools such as jackhammer electric saw, tile cutters.

Recommended noise reduction and control strategies to be applied as there are neighbouring offices (next door and 10 on the upper floor).
Fugitive dust formation from demolition, tiling, cutting activities can trigger respiratory illnesses for contractor workers, as well as persons in neighbouring offices.

4.1.4 Debris and solid waste management It was noted during the preliminary inspection of the DBMC building that there are a number of miscellaneous items that will require proper handling and disposal.
These items will be disposed of in accordance with the Dominica Solid Waste Management Corporation requirements and at an approved disposal site.

The Resettlement Project Officer of the Housing Division will be responsible for removing stored materials occupying the space for renovation.

The EALCRP PIU will officially request confirmation from the Housing Division to ensure proper disposal or relocation of items/materials prior to construction.
The EALCRP PIU Environmental Safeguards Specialist will monitor the relocation/disposal of these materials to ensure compliance with the laws of Dominica and the World Bank standards and policies.

The renovation of the DBMC building will likely generate construction wastes such as damaged tiles, pieces of glass, cement bags, pieces of wood, building materials, etc.
All waste materials from renovation works will be separated and disposed of at a disposal site approved by the Dominica Solid Waste Management Corporation (DSWMC).

4.1.5 Traffic management Renovation works of the ground floor of the DBMC building will increase traffic in the already limited parking space, due to stock piling of aggregates and building materials, parking of contractor workers vehicles and movement of vehicles transporting construction materials and equipment.
This will increase the risk of traffic-related accidents and injuries to workers and individuals from neighbouring offices and adjacent businesses.

The incidence of road accidents involving project vehicles during construction should be minimized through a combination of education and awareness-raising, adoption of road safety procedures and mounting or placement of directional and cautions signs to reduce traffic congestion and increase the safety of all road users.
Caution signs will be used to demark the construction site.

In addition, a Community Health and Safety Plan will also be developed and implemented during the rehabilitation works.

4.1.6 Community Health and Safety Plan The DBMC Building is located in an established commercial area and along a major road and E. O. Leblanc Highway.

Also, within its immediate sphere of influence there is the AID Bank, a roofing factory, hardware retail and a chain of snackettes (official vending area).
The renovation of the DBMC Building will be confined internal minor works on the ground floor within an enclosed structure and the proposed works will be conducted within the designated business working hours, 8 am to 5 pm.

Where necessary, a Community Health and Safety Plan will be developed and be incorporated into the Contractor-ESMP to ensure the health and safety of all the users and businesses within its immediate sphere of influence during the renovation of the DBMC building.
11 4.1.7 Workers Health and Safety The renovation works to DBMC ground floor will expose contractor and workers to potential health and safety risks.

Exposure to health and safety risks will require the contractor to develop 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 stock 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 and reported to the PIU.
Supervisor must first check to see if there are any immediate risk of danger, 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.

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.

4.1.8 Pest Management It was observed during the initial site assessment that a section of the building, proposed Import and Export (Plant Quarantine) as indicated in the proposed floor plan above is infested with termites.

This must be treated thoroughly to include removal of the infested partition and pesticide apply to the entire perimeter of the building.
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.
4.2 Operation Phase The potential impacts of the office operations include wastewater, waste management, energy and water consumption, staff health and safety, COVID 19 measures and emergency response.

The operations of the project will not cause any additional environmental or social impacts on the immediate environment as building is existing brownfield site and is already connected to electricity, water and sewage infrastructure.
12 During the operational phase, the occupants will adhere to the Government of Dominica’s COVID protocol to protect employees and visitors during operational hours to reduce the risk of spread of the COVID 19.

On entry all employees and visitors will be required to wear face mask, temperature check and sanitize hands.

The COVID 19 guidelines will be provided to all employees working on site (See Annex 2 and 3).

13 Chapter 5.
13 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 ground floor respectively.
EALCRP PIU personnel must utilize physical distancing, practice personal hygiene, and wear face masks, in addition to the designated personal protective equipment (PPE) to minimize the spread of the virus and safeguard themselves and project beneficiaries.

COVID 19 protective measures will also be applied to all consultations and stakeholder engagements.
Contractors will be required to prepare and submit a detailed COVID plan to EALCRP PIU demonstrating their ability to safeguard health and safety of workers/employees while on site.
The COVID Plan should include, but not be limited to (refer to Annexes 2 and 3 for complete guidance): • Site access control and traffic management • Checking of body temperature, physical distancing, personal hygiene • Disinfection of premises, offices, workspaces and equipment • Train all staff in the signs and symptoms of COVID-19 • Communicating health and safety matters relating to COVID-19, including wearing of personal protective equipment (PPE) - Wear gloves, glasses and masks, etc.
• COVID incident notification, including the need to immediately report to the Bank if (a) an outbreak occurs in the project offices or worksites, or (b) the infection rate in the project office or worksite is higher than the average.
5.1 Renovation 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.

14 Proposed Mitigation o Designating an area or waste bin construction stockpiling for materials.
o Work activities will be conducted during regular working hours 8 am to 5 pm.

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 in demolition when working Aspect Potential Impacts Proposed Mitigation areas, etc.
(according to 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 adjacent offices or public road etc.

o Maintain vehicles and Contractors to machinery maintenance requirements.
according Construction Waste and Debris o and/or Improper storage disposal of materials o Dispersion of materials in nearby, streets and adjacent Offices or businesses o o The contractor shall handle demolition /construction material solid waste debris and in accordance approved with procedures of Dominica Solid Waste Management Corporation (DSWMC).
o Construction wastes must be stockpile away from circulation areas and not pose safety hazards to workers, Office Staff and visitors; 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 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, environmental the authority shall be informed, and restoration measures shall be applied.

relevant o o Workers be issued PPEs to include helmets, ear plugs, face shield, goggles, gloves, safety shoes etc.
15 Aspect Potential Impacts Pesticide application o The pesticide of risk lead to application may accidental exposure inhalation, spillage and entry into the natural ecosystem Hazardous materials handling, storage, use and transportation Potential generation of hazardous wastes (lubricants, oils, painting, thinners, etc.).

The risk of accidental discharge of hazardous products, empty gas cylinders, of hydrocarbons, oils or grease from construction machinery.
leakage 16 Proposed Mitigation o Provide PPE`s including hearing protection when working around machinery noise exceeds 85 dB; wear dust masks / respirators.

o Maintain vehicles and Contractors to machinery maintenance requirements.

o Neighbouring Offices, snackette and businesses will be informed of works.

according o Prevent unauthorized persons access to the Site.

o Ensure immediate cleaning of any of after remediation areas and spills contaminated construction.
o Sprinkle driveway with water on dry days to reduce dust.

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 & disposal, direction for use, precautionary statements and first aid.
o Pesticides should be applied after working hour and Staff In- Charged of the neighbouring Offices and Adjacent snackette Owners should be notified of spraying time schedule.

o Follow the project IPMP .

o Ensure that storage containers of hazardous substances are always in good condition and tightly closed.
o Ensure that storage facilities are provided impervious surfaces and bunds/secondary containment to control spill in case of accidental spillage Aspect Potential Impacts Sewage/Wastewater Management Improper disposal and treatment of sewage/wastewater Dust and noise construction demolition activity from or 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 Proposed Mitigation o Maintain Material Safety Data for hazardous Sheets (MSDS) materials onsite o Portable sanitary units will be established to collect human wastes.
Human waste will be disposed at sewage treatment facility to comply with local laws and regulations of Dominica.

o Dust suppression methods such dust as wetting materials, 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) 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 schools’ and residential areas etc.

such as 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.
17 Aspect Potential Impacts 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.

Proposed Mitigation 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 pedestrian and walkways are provided when required.
temporary from o Enforce access control measures to restrict contractor workers and public the construction site during and outside working hours by placing posters, tapes and erecting barriers.

reflecting going to Workers’ health and safety Workers’ accidents on the construction site 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 implement Management Strategies and Implementation including a site- Plans (MSIP) specific OHS management plan for the most dangerous activities, such as, working on heights (ladder or scaffolding), among others and develop Standard 18 Aspect Potential Impacts Proposed Mitigation COVID Measures 19 Response Exposure and spread of infection 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 Operation Procedures -SOP prior to the start of works.
o Contractors must also develop a Job Hazard Analysis and convene Daily Safety Talks.

For COVID -19 management on the construction site follow the infection control protocol in Annexes 2 and 3. 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) Labour conditions and working treatment unfair discrimination opportunity of project workers and unequal and o No person under the age of 18 years will not be employed or engaged in any project activity.
o Contractor will enforce Code of Conduct to prevent child labour i.e any personal 18 year 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 concerns are address.
5.2 Operation Phase Aspect Occupational Health and Safety Potential Impacts Worker/employee accidents/injury on property on property Proposed Mitigation o Train staff how to use PPE and ensure there is adequate supply o Regularly monitor performance and conduct maintenance of equipment 19 Aspect Sewage/Wastewater Management Potential Impacts Improper treatment sewage/wastewater disposal and of Proposed Mitigation o The building is connected to the public sewage Thus, system.
sewage/wastewater disposal and treatment system will comply with local regulations of Dominica.

laws and Waste Management Improper disposal of solid waste o Solid waste will be stored in designated lids between collection times, collected and disposed of by DSWMC.

containers with COVID Response Measures 19 Exposure and infection spread of Emergency Preparedness and Response o Accidental fire o Injury to staff o Natural disasters (hurricane, earthquake, flooding, etc.)
20 o Upon entering office staff and visitors must wear a face mask, have their temperature checked and hands sanitized.

o Adopt social distancing or physical distancing (at least 6 feet) for staff workstations o Report any occurrence of any Covid - 19 cases of any workers or family members or persons in contact with those infected.

o Record and monitor occurrence rates in order to identify when infection rates become higher than the average and must be reported to the Bank.
o Follow national guidelines and the for construction WHO guidelines works ESF in Annex 2 and the Safeguards Interim Note Construction Civil Works COVID.pdf.

(Annex 3).

o Develop an Emergency Preparedness and Response Plan to address the most common and likely emergency medical, and natural 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 evacuation and firefighting (earthquakes, hurricane and flooding 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 The PIU will have the overall responsibility for project implementation.
The 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 and implementation of the relevant safeguards instruments or through contractors hired for specific E&S or safeguards related tasks.
21 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 site 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.

The Environmental Safeguard Specialist will monitor and report to the Bank (monthly/quarterly) on the clearing of the ground floor prior to construction.
All useful materials to include gas cylinders and other housing items will be relocated and all waste material will be taken to the landfill by the Dominica Solid Waste Management Corporation.

During the renovation 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.

22 Chapter 7.
22 Chapter 7.

Stakeholder Engagement 7.1 Stakeholder Identification The following stakeholders were identified for the project, specifically, the current occupants of the DBMC building and the beneficiaries of the proposed renovation of the ground floor.
7.1.1 Occupants of DBMC Building to be Impacted Entity/Department Director- Housing Contact Hillarian Jules Director- Land and Surveys Marcus Lestrade Team Leader- Central Region Norman Alexander Senior Clerk, Government Housing Loans Board Lisa Robert Address/Location 1st floor, Vanoulst House (Back Section), Charles Avenue, Goodwill, Commonwealth of Dominica 2nd Floor Vanoulst House, Charles Avenue, Goodwill Commonwealth of Dominica Ground Floor Vanoulst House (Back section), Charles Avenue, Goodwill, Commonwealth of Dominica 2nd floor, Vanoulst House (Front Section), Charles Avenue, Goodwill, Commonwealth of Dominica 7.1.2 Final Beneficiaries of DBMC ground floor Renovations Entity/Department Division of Agriculture, Director Agriculture Ricky Brumant Ag Director/ Chief Veterinary Officer Technical Officer/Project and Services Dr. Reginald Thomas Ryan Anselm Contact Team Leader/South Extension Region Brent Symes 7.2 Consultations Address/Location Botanical Gardens Botanical Gardens Main Office Botanical Garden Botanical Gardens The consultation strategy developed prior to COVID-19, already provided for multi-media approaches to collect feedback and collaboration from stakeholders.
This included information disclosure and face-to-face meetings to present the project’s safeguards documents.

The COVID 19 pandemic resulted in the consultation strategy delivery method to be changed from face-to- 23 face to virtual meetings.
The Government of Dominica, Ministry of Health, Wellness and New Health Investment’s and Ministry of Blue and Green Economy and Agriculture and National Food Security COVID Guidelines and Protocols have been adopted and will be implemented throughout the project’s life cycle, where applicable.

These measures will be used and adopted by the EALCRP PIU for consultations and stakeholder engagement activities, as well as publicly disclosing the ESMP on its website.
Due to the increase surge of Covid-19 cases in Dominica, communication with relevant stakeholders were done virtually.

On August 12th, 2021, telephone discussions were held with heads of department that are most likely to be impacted by the renovation works of the ground floor of Vanoulst House.
Consultations engaged the following individuals: Manager of Housing Division, Team Leader for the Central Agricultural Office, Senior Clerk to the Government Housing Loan Boards discussing the renovation works to be undertaken on the ground floor of Vanoulst House.

These individuals were also contacted via email, to include the Director of Land and Surveys Division.
On August 27, 2021, a consultation meeting was conducted via ZOOM with the key Staff of the Division of Agriculture to discuss the floor layout and the designation of offices.

The Division of Agriculture will inherit and occupy the DBMC ground floor, once the EALCRP PIU has been completed.
Participants Designation Dr. Reginald Thomas Chief Veterinary Officer/ Director (ag) Ryan Anselm Technical Officer/Projects and Services Solution/Result Waiting area can be used for office space and should not surpass the reception area Waiting area can be used for office space to accommodate secretarial space.

Also waiting area should not surpass the reception area Concerns Initially the whole building was supposed to be assign to the Agriculture.
of Ministry However, currently only the ground floor is assigned to the Division of Agriculture.

It would be difficult to state the current purpose of the ground floor.
The space size and dimension can be easily adjusted and therefore we should proceed with the layout No space was allocated for Plant and Quarantine, Protection Produce Chemist Lab, DRM/Soil scientist and Plant Protection Officer) Plant protection require office space for the officers, furthermore it was discussed that activities and functions of the agri labs would be 24 Participants Designation Joshua Kelshall Project Engineer/PIU Michael McIntyre Environmental Safeguards Specialist/PIU Nelson Laville Plant Protection and Quarantine Concerns accommodated in the area of the old NIPPA office Also note space for clerical staffs that will require space as well as assistant secretaries that need to be as close to the respective technical Officers Rows 5 to 7 can be used for offices space as see fit by the Division.
All offices must be completely separated/partitioned as a Covid- 19 safety guideline.

Emergency exit needs wider.

Waiting space needs to be closer to entrance and not adjacent to the offices Can`t endorse this space for Plant Quarantine, it is more than just permits and collecting payments to be Solution/Result Used areas between 5 and 7 as more office space.

obstruct Exit door to remain as 3` as if widen will the stairways.

All office regardless of size or designation of Staff will be totally enclosed.
More space will be allocated from section 5 and 7 on the design There are ongoing discussions with the Department of Public Work Architect in making the necessary changes to the design of the DBMC ground floor, which will reflect the much-needed additional office space for the Division of Agriculture staff.

Also, note that it was also decided to leave the 3ft exit door as is, since replacing it with a double door would be obstructing the adjacent steps.
7.3 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.

25 7.4 Grievance and Redress Mechanism (GRM) 7.4.1 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 DBMC building 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: • 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 • 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 26 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.
7.4.2 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 27 • 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 28 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 Agriculture ☐ New Structure ☐ Expansion of existing structure ☒ Renovation of existing structure ☐ Construction of waste disposal system Charles Avenue, Goodwill Subproject Location Subproject property ownership ☒ Government of the Commonwealth of Dominica ☒ Own ☐ Lease Agreement Subproject current property use ☐ Industrial ☐ Commercial ☐ Agricultural ☐ Residential Subproject Component Estimated Investment Start/Completion Date Refurbishment of ground floor of Vanoulst House 279,730.57USD January 2021 to March 2022 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 X No X X X X If answers to any of the above is ‘yes’, please include an ESMP in sub-project implementation.

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

29 YES NO X 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?

X X X X X X X X X X X X X If answers to any of the above is ‘yes’, please include an ESMP in sub-project implementation.
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?
Section E: Natural Habitat NO X X YES X X X X X X X X X X X X X 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).
30 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.
Section G: Vulnerable and Marginalized Groups meeting requirements for OP 4.10 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.)?
YES NO X X X X 31 Require temporary relocation for a vulnerable population affected (children, physically challenged, elderly, minority group etc.)?

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.
(ii) Guidance All the above answers are ‘No’ There is at least one ‘Yes’ (iii) Recommended Course of Action • 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).

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.
32 Annex 2: COVID 19 GUIDELINES FOR CONSTRUCTION AND CIVIL WORKS3 COVID-19 SAFETY ON THE CONSTRUCTION SITE - MANAGING THE RISKS WHAT IS CORONA (COVID-19) DISEASE: The Coronavirus disease (COVID-19) is an infectious disease caused by a newly discovered coronavirus.

It is a respiratory disease and is contagious.

Common symptoms include: fever, tiredness, dry cough.
Other symptoms include: shortness of breath, aches and pains, sore throat and some people report diarrhea, nausea or runny nose; https://www.who.int/health- topics/coronavirus#tab=tab_1.

In March 2020, the World Health Organisation (WHO) declared the COVID-19 a pandemic.

HOW THE COVID-19 DISEASE SPREADS: When someone who has COVID-19 coughs or exhales they release droplets of infected fluid.
Most of these droplets fall on nearby surfaces and objects, people could catch COVID-19 by touching these contaminated areas and then touching their eyes, nose, mouth or face in general.

If they are standing within 2 metres (6.4 feet) of a person with COVID-19 they can catch it by breathing in droplets coughed out or exhaled by them.

COVID-19 spreads in a similar way to flu.

ANYONE can become infected.


It is highly recommended that any worker who has any symptoms related to cold, flu or COVID- 19 should be immediately isolated and proper procedure followed as advised by the Ministry of Health.
SIMPLE GUIDELINES TO PREVENT/MANAGE THE SPREAD OF COVID-19 ON YOUR CONSTRUCTION SITE: The World Health Organisation and the Ministry of Health in Dominica advises that physical/social distancing, frequent handwashing and respiratory etiquette are important to help prevent the spread of this disease.

Please see details of these and other recommended measures to safeguard health and safety while on site as follows: Note: The Contractor remains responsible for Health and Safety on site.

1.
1.

Physical Distancing: Maintain at least 2 metres (~6 feet) distance between yourself and anyone.

Keeping physical distancing between everyone on construction sites will be challenging at times but is a key measure to minimise the spread of COVID-19.
To manage risks: • Limit visitors to the site, only allow authorised, essential personnel 3 This guidance is consistent with the World Bank ESF/SAFEGUARDS INTERIM NOTE: COVID-19 CONSIDERATIONS IN CONSTRUCTION/CIVIL WORKS PROJECTS (April 2020), which is included herein in full as an appendix to this Annex.. 33 • Limit physical interactions between workers, workers and clients, and workers and other persons at the site (e.g.
deliveries) and use other methods such as mobile phone or radio to communicate • Limit worker numbers on site where possible • Split shifts where possible into AM and PM or different days based on activity • Reduce the number of tasks to be completed each day where possible • Create specific walkways through the construction site to maintain physical separation • Stagger meal times and breaks to limit the number of workers congregating in one area • Conduct toolbox and other meetings online, including through an app, where you can.
If not, conduct such meetings in wide open spaces to enable workers to keep the required physical distance • Limit the number of workers in any one particular area, e.g., to use ladder, stairway, etc.

• Postpone non-essential training • Place signage about physical distancing around the work site where you can Identify responsible persons to make sure workers are following the rules for physical distancing.
If physical distancing measures causes other health and safety risks, you need to manage those risks too.

2.

Health Checks by Contractor Monitor your workers for key symptoms of COVID-19, such as fever.
Direct all workers (whether they are at the construction site or not) to report to you if: • They are experiencing any symptoms associated with this disease • They have been, or have potentially been, exposed to a person who has been diagnosed with COVID-19 or is suspected to have COVID-19 (even if the person who is suspected to have COVID-19 has not yet been tested) • Encourage workers to report if they observe another worker is displaying any symptoms • Prohibit workers accessing the site and working if they are displaying any symptoms • Prohibit workers who have contracted COVID-19 from returning to the workplace until they provide official medical evidence that they are cleared of the virus and fit to work • Immediately inform the Project Coordinating Unit (PCU), Disaster Vulnerability Reduction Project A responsible person should be at the entrance of the site at the beginning of each work day to do these basic health checks and record yes/no to the checks.
3.

Workers Hygiene All workers/persons on site are required to practice good hygiene.

This includes: • Frequent Hand Washing - Properly wash your hands as often as possible with soap and water for no less than 20 seconds, including before and after eating and after going to the toilet.

Use designated hand washing areas located on the site.

Signs identifying the locations should be posted.


34 • Use alcohol-based hand sanitisers with at least 60% ethanol or 70% isopropanol as the active ingredient where hand washing is not possible • Respiratory Etiquette - Use adequate face mask at all times.

If unavoidable, cover your mouth and nose with your bent elbow or tissue if you cough or sneeze.

Then dispose of the used tissue immediately in a closed bin and wash your hands.

• Have their own personal tools.


Where larger tools/equipment/machinery are used, these should be cleaned and disinfected by them before and after each person has used and worker must also wash hands, both before and after using tools/equipment/machinery • If gloves are used avoid touching surfaces where possible and clean and disinfect areas or equipment handled.

Dispose of gloves in covered bin (if disposable) or sanitise and wash if reusable.
Do not share gloves • Clean and disinfect surfaces frequently • Practice good personal hygiene, washing body, hair (including facial hair) and clothes thoroughly every day • Comply with physical distancing of 2 metres/ 6 feet away from others • Stay home if sick and inform employer immediately • Avoid touching their face • Avoid handshakes, knocks, high fives or any other close physical contact • Refrain from spitting at all times • No smoking (cigarette butts can carry the virus from your mouth) • Walk with personal utensils and water.
Do not share anything • Dispose of garbage in a covered bin immediately • Disinfect and clean all common areas (e.g.

washroom, water cooler) after use Encourage workers to ensure that their co-workers are following the recommendations to protect their own health, workers health and the health of each their families and friends.

4.

Hygiene on Site: Environmental Cleaning The amount of time the COVID-19 virus survives on objects and surfaces will vary.
Environmental cleaning is one way to remove COVID-19 particles.

Construction work unavoidably requires regular touching of objects and surfaces.

This means that the usual cleaning schedules on construction sites will need to be increased and specific measures employed.
The Contractor is responsible for providing cleaning supplies and ensuring that: • Frequently touched surfaces on a construction site, including equipment, wheelbarrow, buckets, machinery, ladders, lifts, hoists, handrails and doors, are cleaned and disinfected frequently using appropriate detergent or disinfectant solutions.

• Personal items and items used for work such as tools, glasses and phones are frequently cleaned and disinfected (e.g.

using isopropyl alcohol wipes).


• Site amenities, including lunch rooms, site offices, change rooms, toilets, showers, water coolers/ fountains and are to be cleaned industrially and the frequency of this cleaning should increase.

35 • Workers are trained to clean down tools, machinery, equipment, etc.

immediately after use.

5.

Deliveries, other contractors/suppliers to the site • Non-essential visits to the site must be cancelled!
• Deliveries and other contractors who need to be on site should be given clear instructions (in advance) of the requirements while they are on site (This also includes the Client and Consultant).

• Minimise the number of workers attending to deliveries and contractors as much as possible.

Make alcohol-based hand sanitiser available for workers after physically handling deliveries.
• Direct all visiting truck drivers to remain in vehicles and use contactless methods such as mobile phones to communicate with your workers wherever possible.

• Use, and ask deliveries and contractors to use, electronic paper work where possible, to minimise physical interaction.

Where possible, set up alternatives to requiring signatures, e.g.

confirmation email or a photo of the loaded or unloaded goods as proof of delivery or collection.

6.
6.

EMPLOYER/ CONTRACTOR RESPONSIBILITY: • Hand washing areas - at least three (3) areas should be set up to allow for handwashing; at the entrance to the site, the washroom area and lunch/break area.

These should be equipped with liquid soap, running water, paper towels and foot-operated covered bins.

• Cleaning and Sanitising - Adopt/schedule more frequent cleaning.
To minimise the risk of exposure to COVID-19, the person(s) cleaning should wear gloves (where required) and use alcohol-based hand sanitiser before and after wearing gloves or thoroughly wash hands.

This person must take care not to cross-contaminate and should not touch their face.

If gloves are used these should be disposed of in a covered bin.

Alcohol-based hand sanitiser should be made available throughout the construction site, where practical.
• Garbage Disposal - Closed bins with foot pedal or no touch should be provided for workers where appropriate to hygienically dispose of waste and rubbish such as used tissues, immediately after use (or if away from amenities, as soon as possible).

Alcohol-based hand sanitiser should be available for workers to use after they dispose of their waste.
• Washroom facilities - the construction site should have adequate supplies for good hygiene, such as adequate supply of liquid soap, running water and toilet paper.

Washroom facilities must be kept clean, properly stocked and in good working order.

• Separation of workspace - adequately delineate between the construction site and the common areas.
This could include reminding workers (with posters or through training) to frequently wash their hands with soap and water for at least 20 seconds, or thoroughly sanitise their hands with alcohol-based hand sanitiser, before entering and exiting a common area.

• Schedule breaks - adopt a coordinated approach to reducing the number of workers utilising the common areas at a given time (staggering meal/water breaks, start times, coordinating work and planning).
36 • Information - inform workers of workplace etiquette and policies/standards that are expected when utilising common areas (cleaning up after themselves, placing rubbish in bins provided, avoiding putting items such as phones on meal surfaces or prohibit use, sanitising surfaces, etc.)

• Reducing touch points - consider reducing the number of touch points for workers, e.g.

leaving access doors open where appropriate.


• Air flow - consider limiting/ reducing recirculated air-conditioning in common areas (if applicable).

• Disinfectants/Sanitisers - the construction site should also be well stocked with alcohol- based hand sanitizer, soap liquids, disinfectants and other suitable cleaning agents, paper towels, etc.

7.
7.

EMPLOYEE RESPONSIBILITY: • Has a duty to take reasonable care of his/her own health and safety, and to not adversely affect the health and safety of others • Follow any reasonable policies/directions the Contractor has put in place in response to COVID-19.
• Follow authorized Government directives • Clean and sanitise work area as advised • If you suspect or know you have the COVID-19 virus you should: Isolate and seek medical advice by calling the COVID-19 hotline • • Do NOT go to work • Inform your employer as soon as possible and update them if your situation changes, e.g.

if it’s confirmed you have the virus 8.


OTHER GENERAL GUIDELINES: • Consultation and Communication - The Contractor should keep workers informed • Where possible consult with workers on health and safety matters relating to COVID-19.

Allow workers to express views before decisions are made.

Involving them will help build worker commitment to this process and any required changes.

• Avoid/reduce in-person meetings and other gatherings or hold tailgate meetings in open spaces.
• Ensure there is a means for workers to raise concerns (if any) about the steps being taken to manage the risks or any other related concerns.

• Provide all workers with information about the risks of exposure to COVID-19.

Where required, workers should be trained in infection control.

• Communicate clearly with workers about control measures.

• Provide clear direction and guidance about what is expected of workers.
Workers should know: • When to stay away from the workplace • What action to take if they become unwell 37 • What symptoms to be concerned about • Remind workers they have a duty to take reasonable care for their own health and safety and to not adversely affect the health and safety of others.

• Provide workers with a point of contact to discuss their concerns, and access to support services, note that dealing with this current pandemic has psychosocial effects as well.
• Ensure that the DVRP project signboard is erected/visible in case the public wishes to communicate with the PCU.

9.

Remain up-to-date • Keep your knowledge of the COVID-19 situation up-to-date.

• Follow advice from authorised sources only.

• Ensure the site is properly resourced to manage Workplace Health and Safety (WHS) risks during the COVID-19 outbreak, and check that the resources are being used.
• Review your policies, procedures and reporting process to ensure they remain current for any incidents, hazards and other WHS issues that arise during this time.

Update these materials if necessary.

• Ensure these are communicated clearly to all employees and that processes are being followed.

10.

Maintain Electronic Employee Register • Daily track and monitor workforce present on site • Prior to commencement of workday record the presence of each worker as they arrive.
Also check off against this list as they leave at the end of the workday Inform the PCU immediately, once the critical measures have been taken Include this register of employees in daily report to Client • Record if anyone was absent, sent home or isolated for suspected symptoms of COVID-19 • • • Due to the latency period of COVID-19, it is also important to track where employees have worked, if previously assigned to another worksite or transferred during works.
If an employee tests positive for COVID-19, this information would be critical to the public health authorities for contact tracing.

11.

Incident Notification • • Notification must be made immediately to the PCU after the Contractor becomes aware of if it is suspected that a worker may have contracted COVID-19: the incident.
If the incident is discovered while the worker is on site: • - He/she should be immediately isolated and wear a mask - The Contractor should inform the relevant health authorities through the required means - The Contractor should then subsequently inform the PCU 38 • If a person who has been at the site is suspected or confirmed to have COVID-19, the site must be closed and the Contractor must thoroughly clean and disinfect all areas of suspected contamination • A record of each person on site must be taken, especially noting those in immediate, direct, or close contact with the suspected case • All workers on the site should also follow recommended guidelines from the Ministry of Health before leaving the site • Contractor should also monitor and record the rates of infection on site and, in case an outbreak occurs or the rate of infection is higher than normal, it must inform the PIU and the PIU must inform the Bank.
12.

Health and Safety Audits • This should be updated to reflect the COVID-19 requirements, including visible signage on site • The H&S Audits should now be submitted weekly 13.

Worker Transportation • Recommended measures should be followed on public transportation • If the Contractor provides transportation for workers, an assessment of the number of workers being transported at any one given time should be made and measures taken to ensure required distance.
• Measures include having workers sit one to a seat with riders staggered; adjusting the number of workers taken per trip; and the overall number of trips needed to transport workers to the site.

Use of larger vehicles to ensure physical distancing or use of multiple vehicles may be required.

If these are not possible then use other control measures such as adequate PPE where appropriate.

• • Vehicles should be cleaned and sanitized before and after each trip.
• Whenever possible, workers should travel alone in their vehicles.

N.B: ONLY AUTHORISED ESSENTIAL VISITORS ARE ALLOWED ON SITE AND MUST FOLLOW ABOVE REQUIREMENTS!
39 Annex 3: ESF/SAFEGUARDS INTERIM NOTE - COVID 19 CONSIDERATIONS IN CONSTRUCTION/CIVIL WORKS PROJECTS INTERIM GUIDANCE ON COVID-19 VERSION 1: APRIL 7, 2020 ESF/SAFEGUARDS INTERIM NOTE: COVID-19 CONSIDERATIONS IN CONSTRUCTION/CIVIL WORKS PROJECTS This note was issued on April 7, 2020 and includes links to the latest guidance as of this date (e.g.

from WHO).
from WHO).

Given the COVID-19 situation is rapidly evolving, when using this note it is important to check whether any updates to these external resources have been issued.

1.

INTRODUCTION The COVID-19 pandemic presents Governments with unprecedented challenges.
Addressing COVID-19 related issues in both existing and new operations starts with recognizing that this is not business as usual and that circumstances require a highly adaptive responsive management design to avoid, minimize and manage what may be a rapidly evolving situation.
In many cases, we will ask Borrowers to use reasonable efforts in the circumstances, recognizing that what may be possible today may be different next week (both positively, because more supplies and guidance may be available, and negatively, because the spread of the virus may have accelerated).
This interim note is intended to provide guidance to teams on how to support Borrowers in addressing key issues associated with COVID-19, and consolidates the advice that has already been provided over the past month.

As such, it should be used in place of other guidance that has been provided to date.

This note will be developed as the global situation and the Bank’s learning (and that of others) develops.

This is not a time when ‘one size fits all’.


More than ever, teams will need to work with Borrowers and projects to understand the activities being carried out and the risks that these activities may entail.

Support will be needed in designing mitigation measures that are implementable in the context of the project.
These measures will need to take into account capacity of the Government agencies, availability of supplies and the practical challenges of operations on-the-ground, including stakeholder engagement, supervision and monitoring.

In many circumstances, communication itself may be challenging, where face-to-face meetings are restricted or prohibited, and where IT solutions are limited or unreliable.
This note emphasizes the importance of careful scenario planning, clear procedures and protocols, management systems, effective communication and coordination, and the need for high levels of responsiveness in a changing environment.
It recommends assessing the current situation of the project, putting in place mitigation measures to avoid or minimize the chance of infection, and planning what to do if either project workers become infected or the work force includes workers from proximate communities affected by COVID-19.

In many projects, measures to avoid or minimize will need to be implemented at the same time as dealing with sick workers and relations with the community, some of whom may also be ill or concerned about infection.
Borrowers should understand the obligations that contractors have under their existing contracts (see Section 3), require contractors to put in place appropriate organizational structures (see Section 4) and develop procedures to address different aspects of COVID-19 (see Section 5).

40 2.

CHALLENGES WITH CONSTRUCTION/CIVIL WORKS Projects involving construction/civil works frequently involve a large work force, together with suppliers and supporting functions and services.
The work force may comprise workers from international, national, regional, and local labor markets.

They may need to live in on-site accommodation, lodge within communities close to work sites or return to their homes after work.

There may be different contractors permanently present on site, carrying out different activities, each with their own dedicated workers.
Supply chains may involve international, regional and national suppliers facilitating the regular flow of goods and services to the project (including supplies essential to the project such as fuel, food, and water).

As such there will also be regular flow of parties entering and exiting the site; support services, such as catering, cleaning services, equipment, material and supply deliveries, and specialist sub-contractors, brought in to deliver specific elements of the works.
Given the complexity and the concentrated number of workers, the potential for the spread of infectious disease in projects involving construction is extremely serious, as are the implications of such a spread.

Projects may experience large numbers of the work force becoming ill, which will strain the project’s health facilities, have implications for local emergency and health services and may jeopardize the progress of the construction work and the schedule of the project.
Such impacts will be exacerbated where a work force is large and/or the project is in remote or under-serviced areas.

In such circumstances, relationships with the community can be strained or difficult and conflict can arise, particularly if people feel they are being exposed to disease by the project or are having to compete for scarce resources.

The project must also exercise appropriate precautions against introducing the infection to local communities.

3.
3.

DOES THE CONSTRUCTION CONTRACT COVER THIS SITUATION?

Given the unprecedented nature of the COVID -19 pandemic, it is unlikely that the existing construction/civil works contracts will cover all the things that a prudent contractor will need to do.

Nevertheless, the first place for a Borrower to start is with the contract, determining what a contractor’s existing obligations are, and how these relate to the current situation.
The obligations on health and safety will depend on what kind of contract exists (between the Borrower and the main contractor; between the main contractors and the sub-contractors).

It will differ if the Borrower used the World Bank’s standard procurement documents (SPDs) or used national bidding documents.

If a FIDIC document has been used, there will be general provisions relating to health and safety.
For example, the standard FIDIC, Conditions of Contract for Construction (Second Edition 2017), which contains no ‘ESF enhancements’, states (in the General Conditions, clause 6.7) that the Contractor will be required: • • • • to take all necessary precautions to maintain the health and safety of the Contractor’s Personnel to appoint a health and safety officer at site, who will have the authority to issue directives for the purpose of maintaining the health and safety of all personnel authorized to enter and or work on the site and to take protective measures to prevent accidents to ensure, in collaboration with local health authorities, that medical staff, first aid facilities, sick bay, ambulance services and any other medical services specified are available at all times at the site and at any accommodation to ensure suitable arrangements are made for all necessary welfare and hygiene requirements and for the prevention of epidemics 41 These requirements have been enhanced through the introduction of the ESF into the SPDs (edition dated July 2019).
The general FIDIC clause referred to above has been strengthened to reflect the requirements of the ESF.
Beyond FIDIC’s general requirements discussed above, the Bank’s Particular Conditions include a number of relevant requirements on the Contractor, including: • • • • • to provide health and safety training for Contractor’s Personnel (which include project workers and all personnel that the Contractor uses on site, including staff and other employees of the Contractor and Subcontractors and any other personnel assisting the Contractor in carrying out project activities) to put in place workplace processes for Contractor’s Personnel to report work situations that are not safe or healthy gives Contractor’s Personnel the right to report work situations which they believe are not safe or healthy, and to remove themselves from a work situation which they have a reasonable justification to believe presents an imminent and serious danger to their life or health (with no reprisal for reporting or removing themselves) requires measures to be in place to avoid or minimize the spread of diseases including measures to avoid or minimize the transmission of communicable diseases that may be associated with the influx of temporary or permanent contract-related labor to provide an easily accessible grievance mechanism to raise workplace concerns Where the contract form used is FIDIC, the Borrower (as the Employer) will be represented by the Engineer (also referred to in this note as the Supervising Engineer).
The Engineer will be authorized to exercise authority specified in or necessarily implied from the construction contract.

In such cases, the Engineer (through its staff on site) will be the interface between the PIU and the Contractor.

It is important therefore to understand the scope of the Engineer’s responsibilities.
It is also important to recognize that infectious diseases such as COVID-19, project management – through the in the case of Contractor/subcontractor hierarchy – is only as effective as the weakest link.

A thorough review of management procedures/plans as they will be implemented through the entire contractor hierarchy is important.
Existing contracts provide the outline of this structure; they form the basis for the Borrower to understand how proposed mitigation measures will be designed and how adaptive management will be implemented, and to start a conversation with the Contractor on measures to address COVID-19 in the project.

4.

WHAT PLANNING SHOULD THE BORROWER BE DOING?


Task teams should work with Borrowers (PIUs) to confirm that projects (i) are taking adequate precautions to prevent or minimize an outbreak of COVID-19, and (ii) have identified what to do in the event of an outbreak.

Suggestions on how to do this are set out below: • The PIU, either directly or through the Supervising Engineer, should request details in writing from the main Contractor of the measures being taken to address the risks.
As stated in Section 3, the construction contract should include health and safety requirements, and these can be used as the basis for identification of, and requirements to implement, COVID-19 specific measures.

The measures may be presented as a contingency plan, as an extension of the existing project emergency and preparedness plan or as standalone procedures.

The measures may be reflected in revisions to the project’s health and safety manual.
This request should be made in writing 42 • • (following any relevant procedure set out in the contract between the Borrower and the contractor).

In making the request, it may be helpful for the PIU to specify the areas that should be covered.

This should include the items set out in Section 5 below and take into account current and relevant guidance provided by national authorities, WHO and other organizations.

See the list of references in the Annex to this note.
The PIU should require the Contractor to convene regular meetings with the project health and safety specialists and medical staff (and where appropriate the local health authorities), and to take their advice in designing and implementing the agreed measures.

• Where possible, a senior person should be identified as a focal point to deal with COVID-19 issues.

This can be a work supervisor or a health and safety specialist.
This person can be responsible for coordinating preparation of the site and making sure that the measures taken are communicated to the workers, those entering the site and the local community.

It is also advisable to designate at least one back-up person, in case the focal point becomes ill; that person should be aware of the arrangements that are in place.
• On sites where there are a number of contractors and therefore (in effect) different work forces, the request should emphasize the importance of coordination and communication between the different parties.

Where necessary, the PIU should request the main contractor to put in place a protocol for regular meetings of the different contractors, requiring each to appoint a designated staff member (with back up) to attend such meetings.
If meetings cannot be held in person, they should be conducted using whatever IT is available.

The effectiveness of mitigation measures will depend on the weakest implementation, and therefore it is important that all contractors and sub-contractors understand the risks and the procedure to be followed.
The PIU, either directly or through the Supervising Engineer, may provide support to projects in identifying appropriate mitigation measures, particularly where these will involve interface with local services, in particular health and emergency services.

In many cases, the PIU can play a valuable role in connecting project representatives with local Government agencies, and helping coordinate a strategic response, which takes into account the availability of resources.
To be most effective, projects should consult and coordinate with relevant Government agencies and other projects in the vicinity.

• • Workers should be encouraged to use the existing project grievance mechanism to report concerns relating to COVID-19, preparations being made by the project to address COVID-19 related issues, how procedures are being implemented, and concerns about the health of their co-workers and other staff.

5.

WHAT SHOULD THE CONTRACTOR COVER?


The Contractor should identify measures to address the COVID-19 situation.

What will be possible will depend on the context of the project: the location, existing project resources, availability of supplies, capacity of local emergency/health services, the extent to which the virus already exist in the area.
A systematic approach to planning, recognizing the challenges associated with rapidly changing circumstances, will help the project put in place the best measures possible to address the situation.

As discussed above, measures to address COVID-19 may be presented in different ways (as a contingency plan, as an extension of the existing project emergency and preparedness plan or as standalone procedures).
PIUs and contractors should refer to guidance issued by relevant authorities, both national and international (e.g.

WHO), which is regularly updated (see sample References and links provided in the Annex).

43 Addressing COVID-19 at a project site goes beyond occupational health and safety, and is a broader project issue which will require the involvement of different members of a project management team.
In many cases, the most effective approach will be to establish procedures to address the issues, and then to ensure that these procedures are implemented systematically.

Where appropriate given the project context, a designated team should be established to address COVID-19 issues, including PIU representatives, the Supervising Engineer, management (e.g.

the project manager) of the contractor and sub-contractors, security, and medical and OHS professionals.
Procedures should be clear and straightforward, improved as necessary, and supervised and monitored by the COVID-19 focal point(s).

Procedures should be documented, distributed to all contractors, and discussed at regular meetings to facilitate adaptive management.

The issues set out below include a number that represent expected good workplace management but are especially pertinent in preparing the project response to COVID-19.
(a) ASSESSING WORKFORCE CHARACTERISTICS Many construction sites will have a mix of workers e.g.

workers from the local communities; workers from a different part of the country; workers from another country.

Workers will be employed under different terms and conditions and be accommodated in different ways.
Assessing these different aspects of the workforce will help in identifying appropriate mitigation measures: • • The Contractor should prepare a detailed profile of the project work force, key work activities, schedule for carrying out such activities, different durations of contract and rotations (e.g.

4 weeks on, 4 weeks off).

This should include a breakdown of workers who reside at home (i.e.
workers from the community), workers who lodge within the local community and workers in on-site accommodation.

Where possible, it should also identify workers that may be more at risk from COVID-19, those with underlying health issues or who may be otherwise at risk.

• Consideration should be given to ways in which to minimize movement in and out of site.
This could include lengthening the term of existing contracts, to avoid workers returning home to affected areas, or returning to site from affected areas.

• Workers accommodated on site should be required to minimize contact with people near the site, and in certain cases be prohibited from leaving the site for the duration of their contract, so that contact with local communities is avoided.
• Consideration should be given to requiring workers lodging in the local community to move to site accommodation (subject to availability) where they would be subject to the same restrictions.

• Workers from local communities, who return home daily, weekly or monthly, will be more difficult to manage.
They should be subject to health checks at entry to the site (as set out above) and at some point, circumstances may make it necessary to require them to either use accommodation on site or not to come to work.

(b) ENTRY/EXIT TO THE WORK SITE AND CHECKS ON COMMENCEMENT OF WORK Entry/exit to the work site should be controlled and documented for both workers and other parties, including support staff and suppliers.
Possible measures may include: • Establishing a system for controlling entry/exit to the site, securing the boundaries of the site, and establishing designating entry/exit points (if they do not already exist).

Entry/exit to the site should be documented.

44 • • Training security staff on the (enhanced) system that has been put in place for securing the site and controlling entry and exit, the behaviors required of them in enforcing such system and any COVID - 19 specific considerations.
Training staff who will be monitoring entry to the site, providing them with the resources they need to document entry of workers, conducting temperature checks and recording details of any worker that is denied entry.

• Confirming that workers are fit for work before they enter the site or start work.

While procedures should already be in place for this, special attention should be paid to workers with underlying health issues or who may be otherwise at risk.
Consideration should be given to demobilization of staff with underlying health issues.

• Checking and recording temperatures of workers and other people entering the site or requiring self-reporting prior to or on entering the site.

• Providing daily briefings to workers prior to commencing work, focusing on COVID-19 specific including cough etiquette, hand hygiene and distancing measures, using considerations demonstrations and participatory methods.
• During the daily briefings, reminding workers to self-monitor for possible symptoms (fever, cough) and to report to their supervisor or the COVID-19 focal point if they have symptoms or are feeling unwell.

• Preventing a worker from an affected area or who has been in contact with an infected person from returning to the site for 14 days or (if that is not possible) isolating such worker for 14 days.
• Preventing a sick worker from entering the site, referring them to local health facilities if necessary or requiring them to isolate at home for 14 days.
(c) GENERAL HYGIENE Requirements on general hygiene should be communicated and monitored, to include: • Training workers and staff on site on the signs and symptoms of COVID-19, how it is spread, how to protect themselves (including regular handwashing and social distancing) and what to do if they or other people have symptoms (for further information see WHO COVID-19 advice for the public).

• Placing posters and signs around the site, with images and text in local languages.
• Ensuring handwashing facilities supplied with soap, disposable paper towels and closed waste bins exist at key places throughout site, including at entrances/exits to work areas; where there is a toilet, canteen or food distribution, or provision of drinking water; in worker accommodation; at waste stations; at stores; and in common spaces.

Where handwashing facilities do not exist or are not adequate, arrangements should be made to set them up.
Alcohol based sanitizer (if available, 60-95% alcohol) can also be used.

• Review worker accommodations, and assess them in light of the requirements set out in IFC/EBRD guidance on Workers’ Accommodation: processes and standards, which provides valuable guidance as to good practice for accommodation.

• Setting aside part of worker accommodation for precautionary self-quarantine as well as more formal isolation of staff who may be infected (see paragraph (f)).
(d) CLEANING AND WASTE DISPOSAL 45 Conduct regular and thorough cleaning of all site facilities, including offices, accommodation, canteens, common spaces.

Review cleaning protocols for key construction equipment (particularly if it is being operated by different workers).

This should include: • Providing cleaning staff with adequate cleaning equipment, materials and disinfectant.
• Review general cleaning systems, training cleaning staff on appropriate cleaning procedures and appropriate frequency in high use or high-risk areas.

• Where it is anticipated that cleaners will be required to clean areas that have been or are suspected to have been contaminated with COVID-19, providing them with appropriate PPE: gowns or aprons, gloves, eye protection (masks, goggles or face screens) and boots or closed work shoes.
If appropriate PPE is not available, cleaners should be provided with best available alternatives.

Training cleaners in proper hygiene (including handwashing) prior to, during and after conducting cleaning activities; how to safely use PPE (where required); in waste control (including for used PPE and cleaning materials).
• • Any medical waste produced during the care of ill workers should be collected safely in designated containers or bags and treated and disposed of following relevant requirements (e.g., national, WHO).

If open burning and incineration of medical wastes is necessary, this should be for as limited a duration as possible.
Waste should be reduced and segregated, so that only the smallest amount of waste is incinerated (for further information see WHO interim guidance on water, sanitation and waste management for COVID-19).

(e) ADJUSTING WORK PRACTICES Consider changes to work processes and timings to reduce or minimize contact between workers, recognizing that this is likely to impact the project schedule.

Such measures could include: • Decreasing the size of work teams.

• • Changing to a 24-hour work rotation.


Limiting the number of workers on site at any one time.

• Adapting or redesigning work processes for specific work activities and tasks to enable social distancing, and training workers on these processes.

• Continuing with the usual safety trainings, adding COVID-19 specific considerations.

Training should include proper use of normal PPE.


While as of the date of this note, general advice is that construction workers do not require COVID-19 specific PPE, this should be kept under review (for further information see WHO interim guidance on rational use of personal protective equipment (PPE) for COVID-19).

• Reviewing work methods to reduce use of construction PPE, in case supplies become scarce or the PPE is needed for medical workers or cleaners.

This could include, e.g.


trying to reduce the need for dust masks by checking that water sprinkling systems are in good working order and are maintained or reducing the speed limit for haul trucks.

• Arranging (where possible) for work breaks to be taken in outdoor areas within the site.

• Consider changing canteen layouts and phasing meal times to allow for social distancing and phasing access to and/or temporarily restricting access to leisure facilities that may exist on site, including gyms.
• At some point, it may be necessary to review the overall project schedule, to assess the extent to which it needs to be adjusted (or work stopped completely) to reflect prudent work practices, 46 potential exposure of both workers and the community and availability of supplies, taking into account Government advice and instructions.
▪ PROJECT MEDICAL SERVICES Consider whether existing project medical services are adequate, taking into account existing infrastructure (size of clinic/medical post, number of beds, isolation facilities), medical staff, equipment and supplies, procedures and training.

Where these are not adequate, consider upgrading services where possible, including: • Expanding medical infrastructure and preparing areas where patients can be isolated.
Guidance on setting up isolation facilities is set out in WHO interim guidance on considerations for quarantine of individuals in the context of containment for COVID-19).

Isolation facilities should be located away from worker accommodation and ongoing work activities.

Where possible, workers should be provided with a single well-ventilated room (open windows and door).
Where this is not possible, isolation facilities should allow at least 1 meter between workers in the same room, separating workers with curtains, if possible.

Sick workers should limit their movements, avoiding common areas and facilities and not be allowed visitors until they have been clear of symptoms for 14 days.

If they need to use common areas and facilities (e.g.
kitchens or canteens), they should only do so when unaffected workers are not present and the area/facilities should be cleaned prior to and after such use.

• Training medical staff, which should include current WHO advice on COVID-19 and recommendations on the specifics of COVID-19.

Where COVID-19 infection is suspected, medical providers on site should follow WHO interim guidance on infection prevention and control during health care when novel coronavirus (nCoV) infection is suspected.
Training medical staff in testing, if testing is available.

• • Assessing the current stock of equipment, supplies and medicines on site, and obtaining additional stock, where required and possible.

This could include medical PPE, such as gowns, aprons, medical masks, gloves, and eye protection.

Refer to WHO guidance as to what is advised (for further information see WHO interim guidance on rational use of personal protective equipment (PPE) for COVID-19).
If PPE items are unavailable due to world-wide shortages, medical staff on the project should agree on alternatives and try to procure them.

Alternatives that may commonly be found on constructions sites include dust masks, construction gloves and eye goggles.

While these items are not recommended, they should be used as a last resort if no medical PPE is available.
• • Ventilators will not normally be available on work sites, and in any event, intubation should only be conducted by experienced medical staff.

If a worker is extremely ill and unable to breathe properly on his or her own, they should be referred immediately to the local hospital (see (g) below).
• Review existing methods for dealing with medical waste, including systems for storage and disposal (for further information see WHO interim guidance on water, sanitation and waste management for COVID-19, and WHO guidance on safe management of wastes from health-care activities).

(g) LOCAL MEDICAL AND OTHER SERVICES Given the limited scope of project medical services, the project may need to refer sick workers to local medical services.
Preparation for this includes: 47 • Obtaining information as to the resources and capacity of local medical services (e.g.

number of beds, availability of trained staff and essential supplies).

• Conducting preliminary discussions with specific medical facilities, to agree what should be done in the event of ill workers needing to be referred.
• Considering ways in which the project may be able to support local medical services in preparing for members of the community becoming ill, recognizing that the elderly or those with pre-existing medical conditions require additional support to access appropriate treatment if they become ill. • Clarifying the way in which an ill worker will be transported to the medical facility, and checking availability of such transportation.
Establishing an agreed protocol for communications with local emergency/medical services.

• • Agreeing with the local medical services/specific medical facilities the scope of services to be provided, the procedure for in-take of patients and (where relevant) any costs or payments that may be involved.

• A procedure should also be prepared so that project management knows what to do in the unfortunate event that a worker ill with COVID-19 dies.
While normal project procedures will continue to apply, COVID-19 may raise other issues because of the infectious nature of the disease.

The project should liaise with the relevant local authorities to coordinate what should be done, including any reporting or other requirements under national law.
(h) INSTANCES OR SPREAD OF THE VIRUS WHO provides detailed advice on what should be done to treat a person who becomes sick or displays symptoms that could be associated with the COVID-19 virus (for further information see WHO interim guidance on infection prevention and control during health care when novel coronavirus (nCoV) infection is suspected).
The project should set out risk-based procedures to be followed, with differentiated approaches based on case severity (mild, moderate, severe, critical) and risk factors (such as age, hypertension, diabetes) (for further information see WHO interim guidance on operational considerations for case management of COVID-19 in health facility and community).

These may include the following: • • • • If a worker has symptoms of COVID-19 (e.g.
fever, dry cough, fatigue) the worker should be removed immediately from work activities and isolated on site.

If testing is available on site, the worker should be tested on site.

If a test is not available at site, the worker should be transported to the local health facilities to be tested (if testing is available).

If the test is positive for COVID-19 or no testing is available, the worker should continue to be isolated.

This will either be at the work site or at home.


If at home, the worker should be transported to their home in transportation provided by the project.

Extensive cleaning procedures with high-alcohol content disinfectant should be undertaken in the area where the worker was present, prior to any further work being undertaken in that area.

Tools used by the worker should be cleaned using disinfectant and PPE disposed of.

• Co-workers (i.e.
• Co-workers (i.e.

workers with whom the sick worker was in close contact) should be required to stop • • • work, and be required to quarantine themselves for 14 days, even if they have no symptoms.

Family and other close contacts of the worker should be required to quarantine themselves for 14 days, even if they have no symptoms.
If a case of COVID-19 is confirmed in a worker on the site, visitors should be restricted from entering the site and worker groups should be isolated from each other as much as possible.

If workers live at home and has a family member who has a confirmed or suspected case of COVID- 19, the worker should quarantine themselves and not be allowed on the project site for 14 days, even if they have no symptoms.
48 • Workers should continue to be paid throughout periods of illness, isolation or quarantine, or if they are required to stop work, in accordance with national law.

• Medical care (whether on site or in a local hospital or clinic) required by a worker should be paid for by the employer.

(i) CONTINUITY OF SUPPLIES AND PROJECT ACTIVITIES Where COVID-19 occurs, either in the project site or the community, access to the project site may be restricted, and movement of supplies may be affected.
• Identify back-up individuals, in case key people within the project management team (PIU, Supervising Engineer, Contractor, sub-contractors) become ill, and communicate who these are so that people are aware of the arrangements that have been put in place.

• Document procedures, so that people know what they are, and are not reliant on one person’s knowledge.
• Understand the supply chain for necessary supplies of energy, water, food, medical supplies and cleaning equipment, consider how it could be impacted, and what alternatives are available.

Early pro-active review of international, regional and national supply chains, especially for those supplies that are critical for the project, is important (e.g.

fuel, food, medical, cleaning and other essential supplies).
Planning for a 1-2 month interruption of critical goods may be appropriate for projects in more remote areas.

• Place orders for/procure critical supplies.

If not available, consider alternatives (where feasible).

• Consider existing security arrangements, and whether these will be adequate in the event of interruption to normal project operations.
• Consider at what point it may become necessary for the project to significantly reduce activities or to stop work completely, and what should be done to prepare for this, and to re-start work when it becomes possible or feasible.

(j) TRAINING AND COMMUNICATION WITH WORKERS Workers need to be provided with regular opportunities to understand their situation, and how they can best protect themselves, their families and the community.
They should be made aware of the procedures that have been put in place by the project, and their own responsibilities in implementing them.

• • • • It is important to be aware that in communities close to the site and amongst workers without access to project management, social media is likely to be a major source of information.

This raises the importance of regular information and engagement with workers (e.g.
through training, town halls, tool boxes) that emphasizes what management is doing to deal with the risks of COVID-19.

Allaying fear is an important aspect of work force peace of mind and business continuity.

Workers should be given an opportunity to ask questions, express their concerns, and make suggestions.
Training of workers should be conducted regularly, as discussed in the sections above, providing workers with a clear understanding of how they are expected to behave and carry out their work duties.

Training should address issues of discrimination or prejudice if a worker becomes ill and provide an understanding of the trajectory of the virus, where workers return to work.
Training should cover all issues that would normally be required on the work site, including use of safety procedures, use of construction PPE, occupational health and safety issues, and code of conduct, taking into account that work practices may have been adjusted.

49 • Communications should be clear, based on fact and designed to be easily understood by workers, for example by displaying posters on handwashing and social distancing, and what to do if a worker displays symptoms.
(k) COMMUNICATION AND CONTACT WITH THE COMMUNITY Relations with the community should be carefully managed, with a focus on measures that are being implemented to safeguard both workers and the community.

The community may be concerned about the presence of non-local workers, or the risks posed to the community by local workers presence on the project site.
The project should set out risk-based procedures to be followed , which may reflect WHO guidance (for further information see WHO Risk Communication and Community Engagement (RCCE) Action Plan Guidance COVID-19 Preparedness and Response).

The following good practice should be considered: • Communications should be clear, regular, based on fact and designed to be easily understood by community members.

• • Communications should utilize available means.


In most cases, face-to-face meetings with the community or community representatives will not be possible.

Other forms of communication should be used; posters, pamphlets, radio, text message, electronic meetings.

The means used should take into account the ability of different members of the community to access them, to make sure that communication reaches these groups.
The community should be made aware of procedures put in place at site to address issues related to COVID-19.

This should include all measures being implemented to limit or prohibit contact between workers and the community.

These need to be communicated clearly, as some measures will have financial implications for the community (e.g.

if workers are paying for lodging or using local facilities).
The community should be made aware of the procedure for entry/exit to the site, the training being given to workers and the procedure that will be followed by the project if a worker becomes sick.

If project representatives, contractors or workers are interacting with the community, they should practice social distancing and follow other COVID-19 guidance issued by relevant authorities, both national and international (e.g.

WHO).

• 6.
WHO).

• 6.

EMERGENCY POWERS AND LEGISLATION Many Borrowers are enacting emergency legislation.

The scope of such legislation, and the way it interacts with other legal requirements, will vary from country to country.

Such legislation can cover a range of issues, for example: • Declaring a public health emergency • Authorizing the use of police or military in certain activities (e.g.
enforcing curfews or restrictions on movement) • Ordering certain categories of employees to work longer hours, not to take holiday or not to leave their job (e.g.

health workers) • Ordering non-essential workers to stay at home, for reduced pay or compulsory holiday Except in exceptional circumstances (after referral to the World Bank’s Operations Environmental and Social Review Committee (OESRC)), projects will need to follow emergency legislation to the extent that these are mandatory or advisable.
It is important that the Borrower understands how mandatory requirements of the legislation will impact the project.

Teams should require Borrowers (and in turn, 50 Borrowers should request Contractors) to consider how the emergency legislation will impact the obligations of the Borrower set out in the legal agreement and the obligations set out in the construction contracts.
Where the legislation requires a material departure from existing contractual obligations, this should be documented, setting out the relevant provisions.
ANNEX WHO Guidance Advice for the public WHO advice for the public, including on social distancing, respiratory hygiene, self-quarantine, and seeking medical advice, can be consulted on this WHO website: https://www.who.int/emergencies/diseases/novel-coronavirus-2019/advice-for-public Technical guidance Infection prevention and control during health care when novel coronavirus (nCoV) infection is suspected, issued on 19 March 2020 Coronavirus disease (COVID-19) outbreak: rights, roles and responsibilities of health workers, including key considerations for occupational safety and health, issued on 18 March 2020 Risk Communication and Community Engagement (RCCE) Action Plan Guidance COVID-19 Preparedness and Response, issued on 16 March 2020 Considerations for quarantine of individuals in the context of containment for coronavirus disease (COVID-19), issued on 19 March 2020 Operational considerations for case management of COVID-19 in health facility and community, issued on 19 March 2020 Rational use of personal protective equipment for coronavirus disease 2019 (COVID-19), issued on 27 February 2020 Getting your workplace ready for COVID-19, issued on 19 March 2020 Water, sanitation, hygiene and waste management for COVID-19, issued on 19 March 2020 Safe management of wastes from health-care activities issued in 2014 Advice on the use of masks in the community, during home care and in healthcare settings in the context of the novel coronavirus (COVID-19) outbreak, issued on March 19, 2020 ILO GUIDANCE ILO Standards and COVID-19 FAQ, issued on March 23, 2020 (provides a compilation of answers to most frequently asked questions related to international labor standards and COVID-19) 51 MFI GUIDANCE IDB Invest Guidance for Infrastructure Projects on COVID-19: A Rapid Risk Profile and Decision Framework KfW DEG COVID-19 Guidance for employers, issued on 31 March 2020 CDC Group COVID-19 Guidance for Employers, issued on 23 March 2020 52 Annex 4: Sample Code of Conduct CODE OF CONDUCT FOR CONTRACTOR’S PERSONNEL We are the Contractor, [enter name of Contractor].
We have signed a contract with The Ministry of Blue and Green Economy, Agriculture and National Food Security, for Renovation of the ground floor of the DBMC Building.

Our contract requires us to implement measures to address environmental and social risks related to the Works, including the risks of sexual exploitation and abuse and sexual harassment.

This Code of Conduct is part of our measures to deal with environmental and social risks related to the Works.
It applies to all our staff, labourer and other employees (permanent or part time/temporary) at the Works Sites or other places where the Works are being carried out.

It also applies to the personnel of each subcontractor and any other personnel assisting us in the execution of the Works.

All such persons are referred to as “Contractor’s Personnel” and are subject to this Code of Conduct.

This Code of Conduct identifies the behaviour that we require from all Contractor’s Personnel.
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.

REQUIRED CONDUCT Contractor’s Personnel shall: 1.

Carry out his/her duties competently and diligently; 2.
Comply with this Code of Conduct, the World Bank Environmental and Social Standards, and all applicable laws, regulations and other requirements, including requirements to protect the health, safety and well-being of other Contractor’s Personnel and any other person; 3.
Maintain a safe working environment including by: (a) ensuring that workplaces, machinery, equipment and processes under each person’s control are safe and without risk to health; (b) wearing required personal protective equipment (PPE); (c) using appropriate measures relating to chemical, physical and biological substances and agents; and (d) following applicable emergency operating procedures.

4.
4.

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 and serious danger to his/her life or health; 5.

Treat other people with respect and not discriminate against specific groups such as women, people with disabilities, migrant workers or children; 6.
Not engage in Sexual Harassment, which means unwelcome sexual advances, requests for sexual favours, and other verbal or physical conduct of a sexual nature with other Contractor’s or Employer’s Personnel; 7.

Not engage in Sexual Exploitation, which means any actual or attempted abuse of position of vulnerability, differential power or trust, for sexual purposes, including, but not limited to, profiting monetarily, socially or politically from the sexual exploitation of another.
In Bank VERSION 1.0 EALCRP financed operations/projects, sexual exploitation occurs when access to or benefit from Bank financed Goods, Works, Consulting or Non-consulting services is used to extract sexual gain; 8.

Not engage in Sexual Abuse, which means the actual or threatened physical intrusion of a sexual nature, whether by force or under unequal coercive conditions; 9.

Not engage in any form of sexual activity with individuals under the age of 18, except in case of pre-existing marriage; 10.
Complete relevant training courses that will be provided related to the environmental and social aspects of the Contract, including health and safety matters, Sexual Exploitation and Abuse (SEA), and Sexual Harassment (SH); 11.

Report violations of this Code of Conduct no later than 48hours from occurrence and record comprehensively in the Project records; 12.
Not retaliate against any person who reports violations of this Code of Conduct, whether to us or the Employer who makes use of the grievance mechanism for Contractor’s Personnel or the project’s Grievance Redress Mechanism.

RAISING CONCERNS If any person observes behavior 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 Contractor’s Social Expert with relevant experience in handling sexual exploitation, sexual abuse and sexual harassment cases, or if such person is not required under the Contract, another individual designated by the Contractor to handle these matters] in writing at this address [ ] or by telephone [ ] or in person at [ ]; or 2.

Call [ ] to reach the Contractor’s hotline (if any) and leave a message.
The person’s identity will be kept confidential, unless reporting of allegations is mandated by the country law.

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.

We will provide warm referrals to service providers that may help support the persons who experience the alleged incident, as appropriate.
There will be no retaliation against any person who raises a concern in good faith about any behavior prohibited by this Code of Conduct.

Such retaliation would be a violation of this Code of Conduct.

CONSEQUENCES OF VIOLATING THE CODE OF CONDUCT Any violation of this Code of Conduct by Contractor’s Personnel may result in serious consequences, up to and including termination and possible referral to legal authorities.
FOR CONTRACTOR’S PERSONNEL: VERSION 1.0 EALCRP 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/): _________________________________________________________ Countersignature of authorized representative of the Contractor: Signature: _____________________________________________________________________ Date (day/month/year/): ____________________________________________________ VERSION 1.0 EALCRP Annex 5: DBMC Building – Ground Floor Design VERSION 1.0 EALCRP