Author: КУШНІРОВА Олена Володимирівна
Last saved by: РЯБЦЕВА Олена Володимирівна

Recipient: Ministry for Development of Economy, Trade and Agriculture of Ukraine
Implementing Entities:
•	Ministry for Development of Economy, Trade and Agriculture of Ukraine
•	National Agency of Ukraine for Civil Service

Public Finance Management Support Programme for Ukraine Project 

DRAFT
ENVIRONMENT and SOCIAL COMMITMENT PLAN (ESCP)

Date: 

1.	Ukraine (“Recipient”) shall implement the “Public Finance Management Support Program for Ukraine Project” (the Project) with the involvement of the Ministry for the Development of Economy, Trade and Agriculture of Ukraine (MEDT) and the National Agency of Ukraine for Civil Service (NACS). Following the implementation of “Strengthening Public Resource Management Project” under the “EU Program for the Reform of Public Administration and Finances (EURoPAF)” the Delegation of the European Union to Ukraine and the International Bank for Reconstruction and Development (hereinafter the Bank) has agreed to finance the Project as the Recipient-Executed Trust Fund Program under the “Public Finance Management Support Program for Ukraine (EU4PFM)”. 

2.	The Recipient, represented by MEDT, shall implement material measures and actions in accordance with the Environmental and Social Standards (ESSs). This Environmental and Social Commitment Plan (ESCP) sets out material measures and actions, any specific documents or plans, as well as the timing for each of these.

3.	The Recipient shall also comply with the provisions of any other Environmental and Social (E&S) documents required under the ESF and referred to in this ESCP, Stakeholder Engagement Plans (SEP), and the timelines specified in those E&S documents.

4.	The Recipient is responsible for compliance with all requirements of the ESCP, including the implementation of specific measures and actions conducted by the MEDT and NACS.

5.	Implementation of the material measures and actions set out in this ESCP shall be monitored and reported to the Bank as required by the ESCP and the conditions of the legal agreement. The Bank shall monitor and assess progress and completion of the material measures and actions throughout the implementation of the Project.

6.	As agreed by the Bank and the Recipient, this ESCP may be revised during the Project implementation when required to reflect adaptive management of Project changes and unforeseen circumstances or in response to an assessment of Project performance conducted under the ESCP. In such circumstances, the Recipient shall agree to the changes with the Bank and shall update the ESCP to reflect them. Agreement on changes to the ESCP shall be documented through the exchange of letters signed between the Bank and the Recipient. The Recipient shall promptly disclose the updated ESCP.

7.	When any changes in the Project or unforeseen circumstances or performance issues during the Project implementation result in increasing risks, including social or labor ones, and creating adverse impacts, the Government of Ukraine shall provide additional funds, if needed, to implement actions and measures to address such risks and impacts.

MATERIAL MEASURES AND ACTIONS | TIMEFRAME | RESPONSIBLE ENTITY/AUTHORITY
MONITORING AND REPORTING

A

REGULAR REPORTING
Prepare and submit regular monitoring reports on environmental and social performance of the Project, including but not limited to the implementation of the ESCP, stakeholder engagement activities, functioning of the grievance mechanisms.

Semi-annually, throughout Project implementation starting from the Project Effectiveness Date. Coordinate with the WB ISR Report

MEDT
NACS

B

INCIDENTS AND ACCIDENTS
Promptly notify the Bank of any incident or accident related to the Project which has, or is likely to have, a significant adverse effect on the environment, the affected communities, the public, or workers. Provide sufficient detail regarding the incident or accident, indicating immediate measures taken or that are planned to be taken to address it, and any information provided by any contractor and supervising entity, as appropriate. Subsequently, as per the Bank’s request, prepare a report on the incident or accident and propose any measures to prevent its recurrence.

Notify the Bank within 48 hours after learning of the incident or accident

Throughout Project implementation

A report would be provided within a timeframe acceptable to the both sides.

MEDT
NACS

ESS 1: ASSESSMENT AND MANAGEMENT OF ENVIRONMENTAL AND SOCIAL RISKS AND IMPACTS

1.1

ORGANIZATIONAL STRUCTURE
Establish an organizational structure with qualified staff to support management of social risks including environmental and social specialist responsible for ensuring compliance with the ESF (Environmental and Social Framework) and stakeholder engagement as required for the Project.
Maintain as necessary throughout Project implementation

Organizational structures in MEDT and NACS, including one ES specialist will be established within four months after Project effectiveness

On-going throughout Project implementation

MEDT
NACS

1.2

MANAGEMENT TOOLS AND INSTRUMENTS

Develop Project Operations Manual(s) that will include, inter alia, measures to ensure compliance with the ESS2, satisfactory to the Bank.

POMs will be applied throughout Project
Implementation (May 2023)

MEDT
NACS

1.4

MANAGEMENT OF CONTRACTORS
Incorporate the relevant aspects of the ESCP, including the Labor Management Procedures and grievance mechanisms, into specifications of the procurement documents with contractors.

Prior to the preparation of procurement documents
Supervise contractors in Program implementation

MEDT
NACS

ESS 2: LABOR AND WORKING CONDITIONS

2.1

LABOR MANAGEMENT PROCEDURES

Ensure strict adherence to the Bank guidelines on employment of consultants.  
Implement the Labor Management Procedure Section that would be incorporated in the POM

Throughout Project implementation.

MEDT
NACS

2.2

GRIEVANCE MECHANISM FOR PROJECT WORKERS
Establish, operate and maintain grievance mechanisms for relevant types of Project workers as described in the LMP section of the POM and consistent with ESS2. 

PIU shall monitor number of received complaints and fill respective GRM log

Grievance mechanism operational prior to engaging Project workers and maintained throughout Project implementation.

Ongoing throughout Project implementation

MEDT
NACS

ESS 3: RESOURCE EFFICIENCY AND POLLUTION PREVENTION AND MANAGEMENT
| Currently not relevant to the Project | |
ESS 4: COMMUNITY HEALTH AND SAFETY
| Currently not relevant to the Project | |
ESS 5: LAND ACQUISITION, RESTRICTIONS ON LAND USE AND INVOLUNTARY RESETTLEMENT
| Currently not relevant to the Project | |
ESS 6: BIODIVERSITY CONSERVATION AND SUSTAINABLE MANAGEMENT OF LIVING NATURAL RESOURCES
| Currently not relevant to the Project | |
ESS 7: INDIGENOUS PEOPLES/SUB-SAHARAN AFRICAN HISTORICALLY UNDERSERVED TRADITIONAL LOCAL COMMUNITIES
| Currently not relevant to the Project | |
ESS 8: CULTURAL HERITAGE
| Currently not relevant to the Project | |
ESS 9: FINANCIAL INTERMEDIARIES
| Currently not relevant to the Project | |
ESS 10: STAKEHOLDER ENGAGEMENT AND INFORMATION DISCLOSURE

10.1

Implement the SEP prepared for the Project. The SEP may be updated (and redisclosed) as needed during Project implementation.

A Stakeholder Management Plan (SEP) was prepared and disclosed on April 19, 2021 and will be implemented by Project with annual reporting on implementation of SEP activities.

MEDT
NACS

10.2

Prepare, adopt, and operate a grievance mechanism for the entire Project as described in SEP.
GRM log should be used to report on the status of the received complains.

GRM in place before the Project effectiveness. 
Operate and maintain throughout Project implementation.

CAPACITY SUPPORT (TRAINING)

CS1

Training will be required for MEDT/NACS staff and stakeholders on:
•	stakeholder mapping and engagement
•	Bank Environmental and Social Standards requirements

Three months after Project effectiveness followed by annual refresher training