The World Bank Education for Human Capital Development Project (P172434) Public Disclosure Authorized

For Official Use Only

Public Disclosure Authorized Appraisal Environmental and Social Review Summary Appraisal Stage (ESRS Appraisal Stage)

Date Prepared/Updated: 03/09/2021 | Report No: ESRSA01335 Public Disclosure Public Public Disclosure Authorized Public Disclosure Authorized

Mar 09, 2021 Page 1 of 13 The World Bank Somalia Education for Human Capital Development Project (P172434)

BASIC INFORMATION

A. Basic Project Data

Country Region Project ID Parent Project ID (if any)

Somalia AFRICA EAST P172434

Project Name Somalia Education for Human Capital Development Project

Practice Area (Lead) Financing Instrument Estimated Appraisal Date Estimated Board Date

Education Investment Project 3/1/2021 5/17/2021 Financing For Official Use Only Borrower(s) Implementing Agency(ies)

Ministry of Finance Ministry of Education, Culture and Higher Education, FMS Ministries of Education

Proposed Development Objective Increase access to primary education in underserved areas, with a focus on girls, and improve quality of instruction

Public Disclosure Public Financing (in USD Million) Amount

Total Project Cost 43.00

B. Is the project being prepared in a Situation of Urgent Need of Assistance or Capacity Constraints, as per Bank IPF Policy, para. 12? No

C. Summary Description of Proposed Project [including overview of Country, Sectoral & Institutional Contexts and Relationship to CPF] The project will have national coverage. Project interventions will focus on: (1) building core government systems to sustainably deliver, measure, and improve education outcomes; (2) increasing the supply of schools with a focus on promoting gender and geographic equity and quality; (3) fostering effective teaching and assessment practices through training, coaching, and technology-based solutions; and (4) ensuring inputs are learning-focused, especially in terms of making the schooling environment and learning materials more learner friendly and aligned with teaching needs. To maximize impact of the project in improving overall access to schooling, the focus will be on a selected number of districts (provisionally, 14 out of 93 districts) that have the lowest participation in education (as measured

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by gross enrollment rates). About 180 new schools will be established under the project which will receive a full package of interventions. However, all schools in Somalia are expected to benefit from stronger capacity of the system to manage education delivery and from technology-based interventions to improve teacher quality.

D. Environmental and Social Overview D.1. Detailed project location(s) and salient physical characteristics relevant to the E&S assessment [geographic, environmental, social] Situated in the , Somalia is bordered by Ethiopia to the west, Djibouti to the northwest, the to the north, the Guardafui Channel and Somali Sea to the east, and Kenya to the southwest. With a total land area of 637,657 km2 and situated between 2°S and 12°N latitudes and 41° and 52°E longitudes, Somalia has the longest coastline on Africa's mainland. The country’s terrain consists mainly of plateaus, plains and highlands. Climatically, hot conditions prevail year-round, with periodic monsoon winds and irregular rainfall. Somalia is a generally dry and arid For Official Use Only country, with poor rainfall that averages only 100 mm in the northeast and between 200 and 300 mm in the central plateaus annually: most of the country receives less than 500 mm of rain. Therefore, the unavailability of water is one of the most pressing problems in the country. The country has only two permanent rivers, the Jubba and the Shabelle, both of which begin in the Ethiopian highlands and flow southwards.

About 72 percent of women aged 15-49 years living in rural areas and 59 percent of women from urban areas have never attended formal schooling. The gender gap in school enrolment is wide with girls estimated to account for 43 percent of those enrolled in school in Somalia. Large distances to school which leads to increased risks of gender- based violence create barriers to girls accessing education services. Importantly, over 90 percent of primary school teachers in Somalia are male which plays a role in girls’ enrolment in school. Social norms around early marriage, expectations that girls support households and rearing of younger siblings and greater ‘social value’ in boys accessing education over girls also play a role in lower enrolment rates of girls. The COVID-19 pandemic is expected to Public Disclosure Public disproportionately impact girls, including by increasing the burden and constraints due to social expectations such as taking on household responsibilities and care-related tasks. In Somalia, the availability of water, gender segregated WASH facilities and sanitary materials for girls has also shown to minimize the risk of girls dropping out of school.

Under the project, priority will be given to districts in which children do not attend school because of either an inadequate supply of school places or because they experience social hardships that inhibit their demand for schooling. Districts will be selected based on current education access rates; those with Gross Enrollment Rates (GER) below 10% would be considered eligible, with priority given to districts that engage directly in social safety net support programs, thereby ensuring demand-side support that enables children to attend school. Districts that are not accessible due to security reasons for adequate supervision by the World Bank will be excluded at this stage. The third stage and final selection stage targets the first 14 of the 26 short-listed districts to sign onto a Participation Agreement stipulating that they will comply with minimum education policy conditions, including the mandatory use of the national curriculum, submission of a feasible plan to maintain the schools supported under the project, and a commitment to specified targets for girl’s enrollment. It is anticipated that two districts each from Banadir, , Hirshabelle, Jubaland, , Southwest and possibly Somaliland will be selected.

Once districts selection has been confirmed, new schools will be constructed in areas where there are no existing schools in a 30 min radius thus they are expected to be in rural areas only. This assessment will likely be carried out by

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a consortium of organisations working in the different districts using a participatory methodology. The assessment will screen out areas where there is contested land or where resettlement is needed. Consultations with all residents, users and claimants on the land that they are willing to donate the land for the school will be an important aspect of site selection. Consideration will be made of geographical spread, and inclusivity ensuring that in any particular district all schools are not selected in one clan’s area. The assessment will also explain the objectives and criteria of the project and provide information about stakeholder engagement plans and GRM focal points. The assessment will also help identify the existence and capacity of potential construction companies and their capacity to comply with E&S requirements as well as measures to prevent elite capture by involving CECs and other community oversight mechanisms. D. 2. Borrower’s Institutional Capacity The proposed project will be the first World Bank project the Ministry of Education has designed and implemented as their own Government program, thus E&S capacity is low.

For Official Use Only Implementation responsibilities for the proposed project will be both with the federal and state level Ministries of Education as outlined in the Memorandum of Understanding (MoU) between the Federal MoECHE and the State Ministries of Education. According to the Provisional Somali Constitution of 2012, the states are mandated to implement education programs and policies. Administrative structures of the MoECHE, having been established only in the last few years, started virtually from scratch, and as a result, capacity within the Ministry remains generally low in relation to staffing, skills and training of personnel. Gender disparities and representation of disadvantaged groups including minority groups are especially prevalent among education ministry personnel and teachers. Further, there is limited infrastructure in place to support the organizational capacity of the MoECHE (offices, vehicles, computers, and logistics). There is also likelihood of limited capacity among contractors to implement the mitigation E&S measures, thus the FMS social specialist will be based in the district where construction is ongoing to provide daya to day support and supervision. Due to inherent system and staffing weaknesses, the MoECHE (like many other ministries) relies on additional support in the form of technical advisors who typically come from the Somali diaspora

Public Disclosure Public community with the aim of supporting state building and recovery processes inside the country.

In the last several years, RCRF has invested heavily in establishing key system and strengthening capacities as it related to teacher management, including the development and adoption of key policies on teachers and their payroll management. These systems provide a substantial base that can be further enhanced through the proposed project for institution strengthening. Additionally, relationships with existing non-government education actors, including UN agencies, NGOs and private sector organizations, will be strengthened to ensure the project is supported by other agencies within the education space.

Both the FGS and the FMS levels have limited capacities to identify, understand and overcome E&S risks and impacts. a needs assessment for E&S capacity as well as TORs, an action plan and timeline for capacity building will be included in the ESMF and will also be referenced in the ESCP.

At the federal level, the PMU in coordination with FMS implementation teams will have overall project monitoring responsibilities. Specific activities include (a) regular supervision of project implementation sites; (b) preparing biannual implementation progress reports by compiling implementation reports from various implementing units, which would include the progress toward PDOs through reporting of key performance indicators; (c) carrying out assessment and evaluation studies; and (e) conducting citizens’ engagement surveys for ensuring beneficiaries’ and communities’ feedback in improving project performance. The PMU will include: separate social and environmental

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safeguard specialists, a part-time GBV/SEA expert and will liaise with the labour inspectorate where it exisits and the civil service commission to ensure labour requirements are impelmented.

The FMS will establish and maintain a PMT staffed by a project manager, one social/GBV (full-time) and one environmental (part-time) specialist. The social specialists will be based in the districts where the construction is ongoing to provide hands on support in implementing social safegaurds at the project site.

To address this, robust environmental and social safeguards capacity building activities are built into the project design. This will cover both identification and training of E&S personnel as well as the development of E&S systems within the Ministries of Education. This will include the whole range of E&S aspects on environmental protection of school ecosystems, stakeholder and community engagement, grievance redress processes, security management, social inclusion, due diligence, GBV and labor influx management as well as land acquistion and resettlement, and community agreements on the use of land. At the grassroots levels, the community education committees (CECs), For Official Use Only responsible for educational matters in the villages and urban areas, will be supported with grievance redress skills and competencies, and would be responsible for general monitoring and supervision of not only environmental and social inclusion and sustainability aspects, but also construction activities. Design and Supervision Consultants will be recruited and will have the capacity for technical review of construction quality through qualified engineers and signing off on construction milestones and contributing to structural safety.

A central PIU for technical, FM, monitoring, safeguards and procurement will be established with dedicated state and federal focal points for coordination. Further, a capacity building plan will be prepared and implemented before project activities commence and throughout project implementation as necessary. Public Disclosure Public

II. SUMMARY OF ENVIRONMENTAL AND SOCIAL (ES) RISKS AND IMPACTS

A. Environmental and Social Risk Classification (ESRC) High

Environmental Risk Rating Moderate The environmental risk rating is Moderate at this time due to the school construction in remote areas, with undefined construction companies who have unknown capacities for E&S implementation, and lack of regulations for ESIAs and OHS requirements. The schools to be supported in the project, including any new constructions or refurbished schools, will be modelled along the Safe Schools standards of UNICEF, meaning that the schools will be designed and constructed to secure the children while at the same time having minimal adverse environmental risks and impacts. The Safe Schools standards focus on school designs for the protection of children and their educational prospects in areas prone to armed conflicts. The envisaged environmental risks and impacts include solid waste generation and disposal issues, air and noise pollution, fire hazards, spread of communicable diseases among children, and outbreak of pests and vermin. The Safe Schools standards focus on school designs for the protection of children and their educational prospects in areas prone to armed conflicts. The envisaged environmental risks and impacts include solid

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waste generation and disposal issues, air and noise pollution, fire hazards, spread of communicable diseases among children, and outbreak of pests and vermin. Social Risk Rating High The project is designed to have a positive social impact, purposely targeting poor and disadvantaged populations including girls, rural and nomadic pastoralist communities. The project will be implemented in areas of fragility due to endemic poverty, acute drought, floods and protracted conflict and insecurity which may make direct access by the PIU to beneficiaries challenging and amplify risks related to lack of effective stakeholder engagement, community participation, grievance redress and application of other risk mitigation measures. Other cumulative risks include systemic weaknesses related to MOECHE’s capacity for preventing adverse social impacts on the project and mitigating and offsetting impacts of social harm whenever they occur. Direct risks from project activities relate to civil works from construction which could lead to land acquisition, restrictions on land use, resettlement and labor influx. In addition, the use of local labor and the reliance on For Official Use Only community partnerships and management could lead to cases of child labor. But this will be mitigated through due diligence, developing a construction C-ESMP, capacity building and close monitoring of the contractors including basing the FMS social specialists in the districts where construction is ongoing. The risks of GBV including sexual exploitation and abuse (SEA) is assessed as substantial based on the predominantly rural sites, proposed scope of works, weaker mitigation systems and lower absorption capacity. Despite this, there are number of civil society groups who have GBV programs also, an independent mechanism for GBV reporting and service provision will be included.

B. Environment and Social Standards (ESSs) that Apply to the Activities Being Considered

B.1. General Assessment

ESS1 Assessment and Management of Environmental and Social Risks and Impacts Public Disclosure Public Overview of the relevance of the Standard for the Project: The assessment of environmental and social risks is based on the review of the PAD that elaborates the technical design of the project, analytical papers on similar interventions in the past, UNDP development reports and education sector strategic plans. Due diligence has been conducted on government capacity, existing safeguards capacity, and the general security situation. In addition, a GBV risk assessment has been finalised.

Because of the nature and relatively moderate scale of the works expected under the project, the environmental impacts will be minor, temporary, and confined to the area immediately surrounding the construction. The project will also adhere to the recently published national construction standards by the Ministry of Public Works and Reconstruction which establishes standards for construction or renovation projects funded by, or on behalf of, the government of Somalia. The policy aims at providing access to public buildings by people with disabilities (PWDs) through “universal design,” which ensures usability by all people, to the greatest extent possible, without the need for adaptation or specialized designs.

In addition, the project has adopted the use of UNICEF-supported Safe Schools standards, which are used as guidelines for construction of schools in conflict-prone areas, and which will serve to reduce adverse impacts of school construction and operation on the environment. The project will also explore the use of safety audits for the

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education sector, to ensure project activities take into consideration key safety consideraitons in design and implementation. Furthermore, cumulative effects of the project are likely to be insignificant. Anticipated environmental risks and impacts include (i) solid waste generation and disposal issues, (ii) noise and air pollution during construction work for new schools, (iii) fire hazards, (iv) spread of communicable diseases among children due to poor sanitation and crowded classrooms, (v) outbreak of pests and vermin, and (vi) community and worker’s health and safety risks associated with school infrastructure construction. These short-term impacts can be prevented or mitigated with standard operating procedures and good construction management practices, providing a clean and safe environment, which is critical for achieving the project outcomes.

Key social risks and impacts include: land acquisition which may lead to physical and economic displacement, although this is expected to be minor given the new classrooms will be mainly built in rural areas. There is also the risk of elite capture and clannism in the awarding of contracts and employment of personnel.

For Official Use Only Sexual exploitation and abuse, sexual harassment, and other forms of gender-based violence (SEA/H, GBV) may occur in the recruitment or retention of skilled or unskilled female workers as well as the interaction of students and teachers with construction workers and the community. As such, the GBV-related risks are assessed to be Substantial. These measures include establishment of clear recruitment and retention policies that both emphasize equity and increase the register of female staff supported by the project, and are meant to outline clear standards and policies to minimize potential for sexual harassment, exploitation and abuse and other forms of GBV. This will also include development of a GBV Action Plan that will include, among other things, a response and accountability framework to outline key response measures should incidence occur, and identification of GBV Service Providers to enable appropriate and immediate care should a problem arise.

Risks of exclusion will be further addressed through awareness raising on the inclusion of all children in education without discrimination including children living with disabilities, and those from minortiy groups as well as nomadic

Public Disclosure Public pastoralist communities. New schools will not be built in localities where school places are already available, including as provided by public or nonstate schools.

Other risks include security risks: stakeholders may be targeted by terrorist groups including project workers, teachers, students and schools. The district selection criteria includes security, at least to ensure acessibility and monitoring. A security management plan will be prepared for the project including the World Bank Guidance Note on Managing the Risks and Impacts of the Use of Security Personnel where security is required for schools or for monitoring of activities.

To mitigate these risks, a stakeholder engagment plan and an environmental and social commitment plan have been prepared, and an ESMF and RPF will be finalised and cleared before appraisal. The rest of the instruments will be deferred as outlined below and completed and cleared before disbursement as the geographic selection of project districts has not been finalised. No work will commence on the ground before all these instruments are in place and approved. These are: a) A standalone GBV Action Plan b) Labor Management Procedures (LMP) c) A Security Management Plan (SMP)

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During project implementation, site specific resettlement plans (RPs) and livelihood plans (LPs) and environment and social management plans (ESMPs) will be prepared to guide site specific application of environment and social risks mitigation measures as appropriate and will be included in the bidding documents for all contractors inlcuding those carrying out the assessment and any third party monitors or other companies.

ESS10 Stakeholder Engagement and Information Disclosure The project will engage a large and diverse array of stakeholders during both the preparation and implementation of this project. Primarily the project will engage with the Federal Government of Somalia (FGS) and the participating Federal Member States (FMS), who will be responsible for project implementation and management. Non-state actors such as Development Partners (DPs), communities, CECs, parents, teachers and students will be engaged regularly through the life of the project. Religious and other leaders and providers of religious education, who may For Official Use Only influence uptake or the involvement of girls or minority groups and IDPs will also be specifically engaged. Additional diverse groups who will support and provide input into implementation include e-learning providers, teacher training institutes, entrepreneurs, professional associations, and community groups who will similarly be engaged as appropriate. Relationships with existing non-government education actors, including UN agencies, NGOs and private sector organizations, will also be strengthened to promote synergy and collaboration.

The project has developed a detailed, stakeholder engagement plan which includes a stakeholder identification and analysis summary, plans for engagement (e.g., type, regularity, etc.), communication activities and grievance redress mechanisms. The SEP outlines both the initial and ongoing process by which stakeholders will be engaged to ensure the design of the project aligns with stakeholders current and ongoing needs. Consultations have been done on the SEP with a variety of actors in the education sector in Somalia, and a number of comments received and addressed. All stakeholder engagements have and will continue to observe government and WHO guidelines for Covid 19

Public Disclosure Public prevention.

The SEP also includes the description for a project Grievance Redress Mechanism. The GRM will also embed a wider beneficiary feedback mechanism that would look at service standards, beneficiary satisfaction, and other citizen engagement tools. To ensure closer community linkages with the GRM, the Community Education Committees (CECs) will be sensitized on workings of the grievance redress systems.

Transparency and accountability will be promoted as well as trust building and promotion of confidential complaints channels and whistle blower protection measures. Social accountability committees are suggested at community level to report to the FMS social specialists (who will be based in the districts) to be an independent focal point for grievances and promote transparency and accountability.

B.2. Specific Risks and Impacts

A brief description of the potential environmental and social risks and impacts relevant to the Project. ESS2 Labor and Working Conditions

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The specific nature and requirements of labor for the project is yet to be fully determined (including the number of project workers, their characteristics and timing of workforce mobilization or the type of contractors). This will be better understood during the assessment to identify potential schools and Labour Management Procedures will be developed prior to disbursement of component 2. The assessment will also identify the likely capacity of construction companies and suppliers of construction materials to meet E&S requirements and assess the likely labour influx and use of community labour. The LMP will outline requirements for construction companies and primary suppliers including mechanims to prevent child and forced labour and reporting requirements on serious incidents. However, it is expected that the CECs will have a significant role in monitoring of any social impacts of construction and community awareness and social accountability on the same.

It is anticipated that the project workers engaged or employed will include contracted workers that will be directly involved in the projects works, teachers and other government officers such as Regional and District Education Officers. This may include community members engaged by the contractors from disadvantaged groups such as IDPs, For Official Use Only minority groups and female workers. Other stakeholders working in connection with the project include government civil servants, teachers (such as federal, state and district officers and district police officers). All civil servants will remain subject to the terms and conditions of their existing public sector employment. It is expected there will be use of security personnel to help secure schools and construction sites as required.

Potential risks related to labor and working conditions include (1) OHS risks; (2) child labor; (3) labor influx; (4) labor disputes over terms and conditions of employment; (5) discrimination and exclusion of disadvantaged groups; (6) security risks (workers exposure to attacks); and (7) GBV risk for students, teachers community members from construction workers and other teachers. The LMP will detail the modalities of a GRM for project workers that will be established during project implementation. Dedicated channels to enable reporting of sexual harassment and other forms of GBV will be elaborated under the GBV Action Plan.

Public Disclosure Public To prevent engagement of under-aged labor, all contracts shall have contractual provisions to comply with the minimum age requirements including penalties for non-compliance. The contractor and primary suppliers will be required to maintain labor registry of all contracted workers with age verification. Minimum working age under the project is 18 years.

ESS3 Resource Efficiency and Pollution Prevention and Management As discussed in the ESS1 Section, because of the nature and relatively moderate scale of the school construction, the risks and impacts related to resource efficiency and pollution will be minor, temporary, and confined to the area immediately surrounding the construction. These risks related to ESS3 include the normal impacts of civil works (i.e., generation of solid waste, dust and noise generation, soil erosion, pollution from construction wastes and water use). To address these short-term impacts, the ESMP/ESIAs will include standard operating procedures (such as appropriate classroom designs and provision of refuse bins and sanitary bins) and good construction management practices, including those proposed in WB Environmental and Health Safety Guidelines (EHSGs). The project teams will adopt climate-resilient school designs, while daily school operations will be guided by the seven qualities of resilience: reflective, robust, flexible, integrated, resourceful, redundant, and inclusive. The project team will look

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closely into the possibilities for incorporating into the school construction designs green-growth aspects, including solar power systems, in order to not only minimise the carbon footprint but also contribute to mitigation. Finishing and furnishings in the 180 or so schools will be low-maintenance and durable to reduce O+M costs, thereby reducing carbon footprint of the new infrastructure. All of these will contribute to the reduction in energy and water use by the project-supported schools and communities.

ESS4 Community Health and Safety Due to poor sanitation enviroment, there could be outbreaks of communicable diseases, compounded by pests and vermin infestations. The standard operating procedures to be developed by the project team will include steps to minimize these risks to the health and safety of children and Covid prevention measures.

As the project will be implemented in areas experiencing fragility due to endemic poverty, recurrent droughts, For Official Use Only ocassional floods and protracted conflict and insecurity, some project activities may require use of armed security. Risks associated with use of armed security to communities including GBV/SEA will be included in the Security Management Plan before disbursement.

To address risks related to SEA/H, a GBV Action Plan will be developed. The GBV Action Plan will articulate the key risks, as well as the full scope of mitigation measures relevant for infrastructure elements, in alignment with the identified level of risk. These include gender appropriate community consultations and sensitization, as well as identification of culturally appropriate mechanisms for raising awareness of potential risks of SEA/H; development and enforcement of Codes of Conduct for all project workers, including appropriate CoCs for teachers, schools administrators and other education-related staff, identification of communications and training requirements for all project-related staff, including dedicated training for teachers and school-based staff; identification of sensitization and awareness raising needs of students, parents and community members of GBV and SEA/H risks; development of

Public Disclosure Public accountability and response framework, as well as referral and reporting protocol to guide response should allegations arise; identification of GBV services providers to enable safe, confidential and survivor-centered care; identification of specific channels to enable reporting of SEA/H and GBV for students, parents and teachers to be integrated into the project GRM; hiring of a GBV expert for the PIU to monitor implementation; and potential contracting of a Third Party Monitor to oversee implementation and monitoring of implementation of mitigation measures. The project will also identify a range of mitigation measures specific to the education sector to enhance safety of students and of the school environment.

ESS5 Land Acquisition, Restrictions on Land Use and Involuntary Resettlement The project will provide new school infrastructure largely on new sites, although adding classrooms and rennovation of existing government buildingsmay be considered. This might require some land acquisition of private land or voluntary land donations or agreements on using community land. Given that there are many areas that are likely to fit the criteria for new schools, the contribution of land for a public facility is unlikely to be a constraint and communities will, therefore, have a selection of land to be used for schools. The district assessment will focus on excluding areas where land is contested or with multiple claims. The team believes that government mediated

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community land contribution is an appropriate approach given that there is no process of eminent domain in Somalia.

The goverment mediated community land contribution will entail the following apporach: district assessments will collect basic information on the site and exclude contested land or land with multiple claims. The E&S screening will determine whether there is a land title and map out all residents and users of the land for consultation on the proposed site, and gather information on which traditional leaders and government officials have jurisdiction over the land for their concurrence. It will recommend what private and community land agreements are necessary as well as whether a resettlement plan (RP) or livelihood plan (LP) is in case of physical or economic displacement, respectively. Community consultations with all residents and users of the land, including disadvantaged groups, will be carried out. Meetings will be minuted and land agreements signed by community representatives and government officials. The and RP and or LP prepared. This process will be included in the summary safeguards report and submitted to the Bank for review and clearance. Only once clearance has been provided can construction start Any For Official Use Only squatters or land owners must be compensated so their lives and livelihoods are not negatively affected.

ESS6 Biodiversity Conservation and Sustainable Management of Living Natural Resources While some locations in Somalia may contain some land with inherent environmental sensitivity relevant to ESS6, the subproject screening process in the ESMF/ESMP will exclude such sensitive areas, which will also be screened out during the district assessments. The ESMF/ESMP will also include specific measures to avoid or minimize negative impact on critical or protected areas if the subproject screening process does not otherwise exclude these areas. The impact (whether singular or cumulative) of small-scale civil works associated with school construction on sensitive areas will be minor. Site selection will include an analysis of the immediate area in terms of population, buildings, slope, nearby wadis/seasonal water flows, and will exclude those which may be adjacent to areas with environmental

Public Disclosure Public sensitivities.

ESS7 Indigenous Peoples/Sub-Saharan African Historically Underserved Traditional Local Communities ESS7 is not relevant to the project, as the people in the project area are not considered Indigenous Peoples as defined under ESS7. This is because prior assessments have indicated that there are no groups that meet the criteria for ESS7. Furthermore, singling out minorities as indigenous could cause them harm – which is not the intention of the policies. However, the project will ensure inclusion of disadvantaged groups through project design – including in the social instruments (the ESMF, RPF and SEP which has an inclusion plan). The WB regional SSI unit is undertaking a regional IP stock-take for East Africa, which will inform any changes to current practice in Somalia.

ESS8 Cultural Heritage There is the potential for chance finds of cultural or archeological significance during construction that could potentially be impacted from the construction. The ESMF will cover risks associated with intangible cultural heritage (such as disruption to religious/cultural festivity in the community by civil work). Subproject specific ESMPs will address these issues through the inclusion of chance finds procedures and site-specific mitigation measures.

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ESS9 Financial Intermediaries This Standard is not relevant for this project.

B.3 Other Relevant Project Risks One other relevant project risk include systemic weaknesses related to MoECHE’s capacity for preventing adverse social impacts on the project and mitigating and offsetting impacts of social harm whenever they occur. As well as ESF considerations in the development of policies and guidelines and data privacy requirements in the handling of student data.

The project will invest in an integrated system for the management and analysis of the data collected through various channels for effective monitoring. The integrated monitoring system will be designed to capture the data needed to report across all the indicators outlined in the Results Framework. This system would need to incorporate capacities For Official Use Only for data importing, either manually or directly via online survey and/or SMS survey platforms, EMIS data and SNU data. Data collected on mobile devices by project monitoring officers will also be uploaded to the system. Putting in place an integrated monitoring system will provide a solid basis for ongoing learning based on emerging findings and will also streamline processes of independent data verification by third parties such as external evaluators. Key considerations for the system will include: • Ensuring that the integrated monitoring system is simple and accessible for users. • Setting up data permissions and user access to facilitate effective use of data while maintaining ethical standards and data privacy. • Secure data storage is provided. • Where relevant, encrypted data transfer methods are used.

Public Disclosure Public C. Legal Operational Policies that Apply

OP 7.50 Projects on International Waterways No

OP 7.60 Projects in Disputed Areas No

B.3. Reliance on Borrower’s policy, legal and institutional framework, relevant to the Project risks and impacts

Is this project being prepared for use of Borrower Framework? No

Areas where “Use of Borrower Framework” is being considered: The Borrower's E&S Framework is not proposed to be relied on for the Project, in whole or in part.

IV. CONTACT POINTS

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World Bank Contact: Huma Ali Waheed Title: Senior Education Specialist

Telephone No: 458-9006 Email: [email protected]

Borrower/Client/Recipient Borrower: Ministry of Finance

Implementing Agency(ies) Implementing Agency: Ministry of Education, Culture and Higher Education

Implementing Agency: FMS Ministries of Education

For Official Use Only V. FOR MORE INFORMATION CONTACT The World Bank 1818 H Street, NW Washington, D.C. 20433 Telephone: (202) 473-1000 Web: http://www.worldbank.org/projects

VI. APPROVAL

Task Team Leader(s): Huma Ali Waheed

Public Disclosure Public Practice Manager (ENR/Social) Helene Monika Carlsson Rex Cleared on 04-Mar-2021 at 03:36:20 GMT-05:00

Safeguards Advisor ESSA Peter Leonard (SAESSA) Concurred on 09-Mar-2021 at 08:50:49 GMT-05:00

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