The overall E&S risk of the project is Substantial. The project’s primary beneficiaries are vulnerable adolescent girls and the project will be implemented in seven participating states (including states affected by conflict and violence) where there is potential for a wide range of impacts to occur and the Borrower having limited, capacity to manage. In addition, because the number of people likely to be affected is significant, there will also be potential for social conflict and safety issues given that some communities may be in conflict regarding the social norms being advocated, and others may feel aggrieved if they do not benefit from the construction of schools in their communities. Furthermore, the laws underpinning E&S requirements for the project are weakly enforced.
Supervision of the project will also represent a challenge for the NPCU due to the need to monitor a range of impacts in seven states. Furthermore, challenges in project implementation could include GBV SEA risks, potential for social conflict, and limited local capacity to systematically mitigate these risks. To identify and prevent potential E&S risks and impacts, the project has prepared and disclosed an Environmental and Social Management Framework (ESMF), Stakeholder Engagement Plan (SEP), Resettlement Policy Framework (RPF) and Labor Management Procedures (LMPs) to identify and mitigate social risks and impacts (SEP was updated and disclosed on World Bank and Government platforms on June 30, 2020 and the rest of the documents were disclosed on the World Bank platform on February 21, 2020 and Country platform on January 29, 2020). To actively address the social risks, the Borrower has prepared an expanded ESMF within which a social assessment is embedded. The assessment helps the Borrower understand the key social inclusion and social risk issues and determine the potential impacts on different stakeholders. Similarly, as required by the World Bank’s Good Practice Note for Addressing GBV, the Borrower undertook a GBV assessment which identifies risks and mitigation measures, and appropriate mitigation plans have been incorporated into the project design and the assessment and costed action plan that will inform measures to prevent and respond to GBV during implementation. These plans will be adjusted as needed during the life of the project.
ESS1: Assessment and Management of Environmental and Social Risks and Impacts
Assessment and management of E&S risks and impacts are required for the whole project, but at this stage, the activities of Subcomponent 1.1 are identified as the most likely to generate E&S risks and impacts. Subcomponent 1.1 will include civil works to build new or rehabilitate existing secondary schools (classrooms, offices, multi-purpose labs, and latrines), while Subcomponent 1.2 will improve learning conditions. Furthermore, the project will also engage in behavioral change campaigns, which will be instrumental in mitigating some exclusion and community conflict risks, along with an early, continuous and inclusive SEP which the Borrower has prepared. The project will make use of ESS1 to assess and manage risks and impacts such as waste and wastewater, sewage, and safety (e.g., electrical, fire, safe materials such as no lead-based paint, and traffic safety) of the students. The Borrower has prepared an ESMF that outlines the principles, procedures, timing and steps that will be taken in preparing site specific safeguards instruments (ESIA, ESMP site-specific Resettlement Action Plans (RAPs), and so on) during project implementation. In addition, an Environmental and Social Commitment Plan (disclosed on June 30, 2020) has been prepared by the Borrower and sets out the Client’s commitments to prepare and implement E&S instruments throughout the lifecycle of the project.
The site-specific ESMPs will include clearly defined mitigation measures for construction and operational phases, roles and responsibilities, timetables, budgets and implementation arrangements for each mitigation measure recommended, and will be prepared once sites are identified and before civil works begin. Construction contractors will be required, as a condition of their contracts with the project, to implement and comply with the ESMP, including LMP and occupational health and safety measures outlined in the ESMF. The site-specific ESMPs developed by the SPIUs will define mitigation measures in addressing social risks/impacts, with assigned responsibilities including procedures for responding to risks of SEA. The ESMP will make use of the general and sector-specific Environmental Health and Safety Guideline for the identified activities in relation to occupational and community health and safety.
The project is expected to primarily benefit adolescent girls to improve their secondary education opportunities. It proposes to do so through the construction and rehabilitation of schools, the provision of financial packages to families, engaging in behavioral change campaigns and providing girls with life and digital literacy training. The major social risks could include: school-based violence that may be inflicted by fellow students (e.g., bullying) or teachers (e.g., corporal punishment); and acquisition of land for the rehabilitation/construction of schools that may result in physical and/or economic displacement (due to the potential of displaced persons occupying derelict school facilities); exclusion of persons with disabilities and other vulnerable groups (e.g., internally displaced people – IDPs) from the benefits of the project; labor influx that may heighten risks of SEA and GBV associated with any construction workforce, teachers, fellow students and community members; intercommunity/intra-community level conflicts that may arise from the promotion of social norms given existing patriarchal norms and/or isolation or stigmatization of persons/communities (especially adolescent girls) who endorse norms; intimate partner violence (IPV) arising from, or exacerbated by, the distribution of financial support packages to families; risks of elite capture/corruption in the transfers of SIGs managed by SBMCs and/or support packages to families; community disputes about the rationale for beneficiary targeting; and challenges to adequate implementation supervision and risks to beneficiaries in conflict/fragile states.
These risks are however largely site-specific and not likely cumulative and so can, therefore, be mitigated. Cognizant of these social risks, the project has prepared relevant instruments, plans and actions to address social risks flagged and associated with the project. To address GBV risks, the project will develop CoCs, and an accountability and response framework that identifies clear enforcement mechanisms and a CoC that, among other elements, prohibit sexual harassment, sexual contact with students, or other abuses of students/teachers and provide training and sensitization to teachers, students, parents and the wider community on the CoCs. This training is currently underway and will be completed in the initial phase of the project. The project will establish clear, confidential, safe, accessible procedures to report GBV and determine information-sharing agreements that could be communicated to the project GRM.
Use of security personnel. A Security Risk Assessment (SRA) will be carried out by the Federal Project Management Unit. The SRA will then inform the Security Management Plan (SMP) which will be developed as part of the site specific ESMP
For other project-specific grievances, the project will set-up a GRM to allow all aggrieved persons to lodge their complaints and receive feedback on time. The GRM will: (a) provide information on project implementation; (b) provide clear procedures for resolving grievances and disputes in the communities where the sub-projects will be implemented; (c) resolve disputes on time and effectively; (d) build trust with project beneficiaries and stakeholders for their buy-ins; and (e) allow communities to express views, on project activities (for example, civil work quality and malpractices). The mechanism is envisaged to operate at multiple levels (community, LGA, state, national) and will address complaints, including lodging, tracking, and resolving grievances during project implementation according to a specific GRM timeframe. Detailed procedures for the project GRM will be provided in the PIM and in annex 8.During implementation, the project will identify and designate at least one counselor (for instance, the female counselors for the ‘safe spaces’) who can be a first point of contact for students who report sexual harassment in each school. This will ensure that students can be provided confidential support and tools to help them without any negative repercussions. Teachers, with a focus on counselors, will also receive training in identifying children and youth experiencing psychological distress and in providing psychosocial support. In case beneficiaries wish to escalate some complaints, the project GRM will include protocols specific to GBV complaints that would allow for confidential reporting and can connect survivors to women’s and children’s rights organizations (preferably specialized in GBV) or groups who can refer them to support services. Provisions to escalate these issues through the GRM will be integrated so that the SPIU and the NPCU can respond in real time.
The Government has developed a costed GBV action plan. This plan will be included as part of the PIM. The plan details how the participating states and other partners will put in place the necessary protocols and mechanisms to address the GBV risks and how to address any GBV incidents that may arise. Further, the plan provides an indication of resources required to implement risk mitigation measures. To address labor related risks, an LMP have been developed as a chapter in the ESMF. The LMP will be further updated as required in the PIM. In addition, a GRM specifically for direct and contracted community workers will be provided. As mentioned above, the project will build on existing structures to set up a project specific GRM for people to report concerns or complaints, if they feel unfairly treated or are negatively affected by the project.
To address security risks, notably in Borno but also in other states affected by violence, an SRA will be conducted within the first six months of effectiveness. A Security Management Plan will be prepared as a part of the site-specific ESMPs to address potential security risks and issues in managing the risks of the use of security personnel. Third party monitoring will also be used in hard to supervise areas of the projects, with special attention to monitoring the implementation of the GBV/SEA Action Plan (that is, prevention and mitigation measures developed on the basis of the GBV Assessment).
Inclusive education. The project will support the Government in integrating people with disabilities in school. The school construction, SIGs, scholarships and other interventions supported under the project aiming at increasing the participation of girls have been designed to promote inclusion of children and adolescents with disabilities. To fill prevailing knowledge gaps, the project will fund a study assessing barriers and opportunities for girls with disabilities to access secondary education. On the basis of study findings, the project will try to address some of the issues identified during the MTR; specifically targeting adolescent girls with disabilities under the GSP ensuring qualified female teachers with disabilities are well supported and ensuring counselors leading the ‘safe space sessions’ incorporate non-discrimination sensitization related to persons with disabilities and other marginalized groups (e.g., IDPs). Close co-operation with other donors supporting inclusive education and providing targeted support to vulnerable groups will also inform the project’s efforts to promote inclusion.
GBV/SEA. The project will support a whole safe school approach to preventing violence including GBV/SEA in schools. As described earlier, this approach supports the development of a shared vision towards violence reduction and response. Elements of this approach are integrated into project-supported activities, including online learning where training will also be provided in online safety to prevent adolescents from predatorial behavior and exploitation. The whole school approach which includes ‘comprehensive activities to help prevent violence and which involve stakeholders who are important in a young person’s life’ has been found to be more effective than focusing on one particular group. These activities and efforts will be aligned with the safe space sessions, where girls will be provided with GBV awareness and information, and a referral pathway for girls wanting additional support or needing access to additional social or health services will be established. This approach has been implemented in a number of low-resource settings and will be adapted to the Nigerian context. In addition, the states’ action plans on GBV will guide specific actions to prevent and mitigate GBV moving forward. A detailed description of activities and implementation will be included in the PIM.
The project will also conduct a mapping of GBV service providers in the relevant participating states and will liaise with, and build on, ongoing World Bank-supported projects. Service mapping will include medical care and care for survivors of IPV), case management and psychosocial support services, safety and security, including availability of safe accommodation arrangements for temporary physical safety of survivors at risks of physical harm, protection, and legal services, informal resources (including services such as the existing community based mechanisms, and actors such as community based organizations [CBOs] and women’s groups and trusted individuals such as people who have been champions to speak out about positive male norms, and the unacceptability of SEA and other forms of GBV). Also survivors of SEA and other forms of GBV89can have access to religious leaders and community leaders in the intervened area of the project using the survivor-centered and rights-based approach.
Citizen engagement. Citizen engagement (CE) will be crucial to achieving the project’s objectives, addressing social and environmental risks and building citizens buy-in to enhance sustainability. CE mechanisms are integrated in the project to also ensure the inclusion of the most vulnerable and excluded beneficiaries. Engaging beneficiaires will allow for changing non-positive attitudes and behaviors about girls access to secondary education – primarily through the use of the SEP and Subcomponent 2.1 Promoting social and behaviour change through communications campaigns, engagement with traditional rulers and advocacy. CE mechanisms will be key in ensuring that communities concerns and feedback are acknowledged and addressed; informing better targeting mechanisms for financial packages, school identification, management of school improvement grants and provision of scholarships. This will be achieved through identifying the appropriate community monitoring mechanisms that will enhance citizens voice, participation and oversight. Through CE, the project will seek inputs from stakeholders on the School Improvement Plans which will be developed and managed by School Based Management Committees (SBMCs comprised of members from school management, parents and community), on how to develop an adaptive behavioural change campaign and their feedback will be taken into account or integrated into the school imrpovement plans and activitie show to develop an adaptive behavioral campaign that addresses differentiated concerns in communities, and the likely varied adoption rates of social norms as well as how to strenghthen the management of the school and the project’s ‘whole school approach.’
Climate Screening. Nigeria is highly vulnerable to climate change and is classified as one of the ten most vulnerable countries in the world, according to the 2017 Climate Change Vulnerability For women and girls, the impact is frequently magnified as there is a direct relationship between women’s empowerment and climate change. Women and girls are more exposed and vulnerable to climate change because they depend more on natural resources for their livelihoods, receive less education and are often poorer. Mainstreaming climate change adaptation and mitigation skills in the education system will help accelerate growth, create jobs and prepare the country to combat climate change.
The overall risk to the outcome of the project is considered Substantial as project design will incorporate efforts to reduce risks associated with the project, avoid geophysical hazards and mitigate against these risks. The project approach to construction aims to ensure that construction is ‘climate safe’ by building and replacing or improving inadequate or degraded school infrastructure and promoting the use of climate resilience infrastructure in the event of future extreme weather events. The project also aims to increase awareness of climate change and support the beneficiaries in acquiring climate change adaptation skills through the life skills training program. Interventions under the project also support measures to limit the potential impact of the project on the environment, for example, using energy-saving measures when possible (including the use of solar systems and energy saving bulbs). Further, the project aims to build awareness and action in schools and communities through applying a climate-safe approach to construction, ensuring school activities supported under the SIP are environmentally friendly, and identifying a climate champion at the school level.
Sexual exploitation and abuse (SEA) will be understood as a facet of GBV that is defined as any actual or attempted abuse of a 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. Sexual abuse is further defined as ‘The actual or threatened physical intrusion of a sexual nature whether by force or under unequal or coercive conditions’ (IASC 2016). In the context of World Bank-supported projects, SEA occurs against a beneficiary or member of the community. The United Nations considers all sexual activity with someone younger than 18 to be sexual abuse.
GRIEVANCE REDRESS SERVICES
Communities and individuals who believe that they are adversely affected by a World Bank (WB) supported project may submit complaints to existing project-level grievance redress mechanisms or the WB’s Grievance Redress Service (GRS). The GRS ensures that complaints received are promptly reviewed in order to address project-related concerns. Project affected communities and individuals may submit their complaint to the WB’s independent Inspection Panel which determines whether harm occurred, or could occur, as a result of WB non-compliance with its policies and procedures. Complaints may be submitted at any time after concerns have been brought directly to the World Bank’s attention, and Bank Management has been given an opportunity to respond.
KEY RISKS
The overall risk rating for the project is Substantial. Although the Government commitment to the education sector is strong, the macro-economic risks, risks related to institutional capacity for implementation and sustainability, fiduciary risks and E&S risks – are all considered Substantial. These risks and accompanying mitigation measures are described in the following paragraphs.
Macro-economic risks under the project are assessed as Substantial. The current macroeconomic environment in Nigeria is challenging which directly affects the subnational governments, especially given the predominant role that federal allocation of fiscal revenues plays in the fiscal equation of each tier of government. Nigeria’s emergence from the recession and diversification away from oil remain slow though efforts by the Federal Government to strengthen non-oil revenues – including the FMF’s Strategic Revenue Growth Initiative and the re-establishment of the National Tax Policy Implementation Committee to drive tax policy reforms, a new Finance Bill which was passed into Law in January 2020 – are positive developments. Specifically, for the states the governments not being able to recruit and pay teachers considering the huge reduction in revenue from federal allocation and domestic revenue is a risk to achieving the PDO. This has been mitigated by securing governors’ ascent/approval on teachers’ recruitment as a disbursement condition.
The risks related to institutional capacity for implementation and sustainability are rated Substantial. Institutions involved in project implementation have some capacity limitations and often encounter difficulties in coordinating with other entities which could impede effective implementation of the project. To mitigate against this risk, the project design has been kept as simple as possible with capacity-building support to be provided to ensure effective implementation of project-supported activities, and significant TA to be provided at the state and federal levels to support implementation. Further, capacity building efforts will emphasize skills transfer to ensure sustainability of impact.
The E&S risks of the project are rated Substantial. The key environmental risks identified relate to hygiene and management of waste, wastewater, sewage, noise, and dust during minor construction works and the safety of the students (e.g., electrical, fire, safe materials, and no lead-based paint). The key social risks identified include: labor influx that may heighten the risks of SEA and GBV associated with any construction workforce, teachers, fellow students and community members; exclusion of persons with disabilities and other vulnerable groups (e.g., IDPs) from the benefits of the project and conflicts at the intercommunity or intra-community level that may arise from the promotion of social norms given existing patriarchal norms and/or isolation or stigmatization of persons/communities (especially adolescent girls) who endorse the norms. The nature of the potential E&S risks and impacts are not irreversible, unprecedented or complex and are easy to manage.
Fiduciary risks under the project are considered Substantial. Key procurement issues include a lack of experienced procurement government staff, lack of training and updating of skills and knowledge of World Bank procurement procedures, inadequate contract management skills, and inadequate working environment, including limited space for staff and for records keeping/filing. Mitigation measures will include the provision of: (i) training on World Bank Procurement Regulations and STEP; (ii) training on contract management; and (iii) training on procurement. It will be critical that the project ensures that government FM systems that are in place provide reasonable resources and assurance that World Bank funds will be used for the intended purposes. Mitigation measures will include continuous building of fiduciary capacity at all levels and strengthening regular monitoring and supervision through periodic interim financial reports (IFRs) and audits. Social accountability mechanisms will be employed, including the involvement of SSEBs consisting of parents, school and community representatives in school governance and the use of SBMCs to manage SIGs.