Environmental & Social Management System

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Environmental & Social

Management System

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

1. Environmental And Social Management Policy

1.1 Mission
Alliance for a Green Revolution in Africa (AGRA) recognises environmental and social (E&S) risk
management as a critical issue that requires systems to monitor and control in line with legal and applicable
international requirements in its operational sectors. This E&S Policy delineates AGRA’s vision and
commitment to sustainable development and how it is fully integrated into AGRA’s core business processes
and lays the foundation of the environmental and social management system (ESMS) that is put in practice.

1.2 Goal
AGRA is committed to promote sustainable agricultural practices in its focus countries. As an
environmentally informed and socially responsible organisation, AGRA is committed to avoid or mitigate
adverse E&S impacts, if any, of its interventions.

AGRA is committed in promoting the use of an appropriate ESMS in order to improve the management of
the E&S implications of all of its funded projects and activities.

1.3 Guiding principles


In implementing this E&S Policy, AGRA shall adhere to a set of guiding principles as listed below:
• Avoid, reduce or limit negative environmental, social and climate impacts and improve the E&S benefits
of its initiatives;
• Support the preservation and protection of biodiversity and sustainably manage natural resources;
• Avoid negative impacts on the living conditions, livelihoods and land tenure of communities;
• Ensure the health and safety at work of its own employees and require its subcontractors and partners
to implement measures to protect the health and safety of their employees at work;
• Condemn forced labour and child labour, prohibit discrimination, prohibit and combat harassment and
support the freedom of association and the right to collective bargaining of workers;
• Comply with all relevant environmental, social, health and safety as well as land acquisition policies,
laws and regulations of the countries of intervention and international standards.

1.4 Implementation of E&S policy principles


AGRA will implement its E&S Policy through its ESMS and all other key institutional policies including
the Safeguarding of Vulnerable Persons Policy, Ethics Policy and Partners Code of Conduct and ensure
compliance with the respective governing laws and regulations as well as international standards specified
in the ESMS. AGRA’s ESMS is designed to guide its implementation of the E&S commitments contained in
this E&S Policy.

In particular, AGRA will establish and maintain the following E&S operational requirements:
• Screen all projects requesting funding and activities by AGRA against AGRA’s Exclusion List ;
• Take informed grant-award decisions based on robust categorisation of projects according to E&S risk
levels, ascertained through various types of review processing including screening, E&S due diligence
(ESDD) and, if and where required commensurate with the scale of the Project and the Project risks,
environmental and social impact assessment (ESIA);
• Clearly define roles and responsibilities of implementation of the E&S activities across the entire
institution, as well as emphasise on management review and reporting procedures;
• Have measures in place to monitor compliance with all relevant E&S policies, laws, and regulations of
the country/-ies of intervention through AGRA’s work;
• Continuously develop and improve institutional capacity to understand, assess and manage E&S
impacts and risks associated with AGRA’s interventions;
• Implement the ESMS to deliver the commitments under this Policy and to monitor compliance with this
Policy across its portfolio and periodically report to its management as well as collaborate and share
information with development partners and Project/programme beneficiaries.
• Communicate this Policy with employees, partners and other external stakeholders;
• Establish key identified partnerships with external stakeholders to manage E&S risks and work with
partners, employees and contractors to raise awareness of E&S management risks and, if identified, to
ensure that they are treated appropriately.

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2. Acknowledgement

AGRA knowledges the financial and technical support from KfW. AGRA further recognizes the expertise
of the experts from Environmental Resource Management worked with AGRA teams to develop the
environmental management system. AGRA acknowledges the overall partnership framework with BMZ for
making this work possible.

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Contents

1 Environmental And Social Management Policy 2

1.1 Mission 2

1.2 Goal 2

1.3 Guiding Principles 2

1.4 Implementation Of E&S Policy Principles 2

2 Acknowledgement 4

3 Glossary Of Terms 7

4 Introduction 10

4.1 Overview Of Alliance For A Green Revolution In Africa (Agra) 10

4.2 Esms Structure 10

4.3 Applicable Environmental And Social Standards And Guidelines 11

5 Identification Of E&S Risk And Impacts 13

5.1 Potential E&S Risks Inherent To Agra’s Interventions 13

5.2 E&S Risks In Agra’s Grant Management Process 17

6 Esms Management & Organisation 18

6.1 Overview Of Agra’s E&S Organisational Structure 18

6.2 E&S Roles And Responsibilities 18

6.3 Developing E&S Capacity Within Agra 21

7 Esms Management And Monitoring 22

7.1 Management Of Potential E&S Risks At Country Level 22

7.2 Management Of E&S Risks At Grant Level 22

8 Esms Screening 24

8.1 Purpose Of The Esms Screening 24

Procedure For Esms Screening 24

8.3 Climate Mitigation And Adaptation Screening 24

9 Environmental And Social Impact Assessment (Esia) 27

9.1 Purpose Of An Esia 27

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Final Reporting And Close Out 32

11 Stakeholder Engagement 33

11.1 Stakeholder Engagement Plan (Sep) 33

Grievance Mechanism 33

12 Collaboration, Information Sharing And Reporting 36

13 Esms Review 37

14 Annexes 38

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3. Glossary of Terms
Acronym Term

AGRA Alliance for a Green Revolution in Africa

APO Associate Program Officer

EHS Environment Health and Safety

E&S Environmental & Social

ESAP Environmental & Social Action Plan

ESDD Environmental & Social Due Diligence

ESIA Environmental & Social Impact Assessment

ESMS Environmental & Social Management System

H&S Health and Safety

IFC International Finance Corporation

ILO International Labour Organisation

KfW Kreditanstalt für Wiederaufbau (German Credit Institute for Reconstruction)

PO Program Officer

PS Performance Standard of IFC

PS1 Performance Standard 1

SEP Stakeholder Engagement Plan

WBG World Bank Group

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List of Annexes

Annex 1: Strategic E&S Risk Assessment

Annex 2: Capacity Building and Training Plan

Annex 3: AGRA Exclusion List

Annex 4: Initial E&S Screening Checklist

Annex 5: E&S Categorisation Guideline

Annex 6: Template for a Request for Concept Notes

Annex 7: AGRA Project Proposal Submission Guidelines

Annex 8: Capacity Assessment & Pre-Funding Site Checklist

Annex 9: E&S Risk Assessment Toolkit

Annex 10: Grant Agreement Letter

Annex 11: Grant Commitment Checklist

Annex 12: E&S Monitoring Checklist

Annex 13: Template for an E&S Monitoring Report

Annex 14: Template for an E&S Performance Report

Annex 15: AGRA’s Enterprise Risk Management Framework (ERMF)

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Definitions

Term Meaning

EHS Guidelines World Bank Group Environmental Health and Safety Guidelines.

Environmental and For the sake of simplicity, the acronym E&S is used throughout this document,
Social (E&S) but the E&S Management System is developed to address all aspects of
“sustainability”, as encompassed by the IFC Performance Standards, i.e.
environment, social, health and safety, human rights and labour aspects.

Environmental & A plan that proposes measures to manage aspects identified in the ESDD to
Social Action Plan acceptable levels in line with the requirements of AGRA and its funding partners.
(ESAP)

Environmental & An assessment and analysis of environmental and social risks and opportunities
Social Due Diligence associated with a Project to ensure that such risks would not present a potential
(ESDD) liability to AGRA.

Environmental The process of identifying, predicting, evaluating and mitigating the biophysical,
& Social Impact social, and other relevant effects of Project proposals prior to major decisions
Assessment (ESIA) being taken and commitments made.

Environmental & The ESMS is the set of policies, procedures, tools and internal capacity at AGRA
Social Management to identify and manage the environmental and social risks posed by the funded
System (ESMS) interventions.

Excluded Activity Any business or activity listed on the AGRA Exclusion List (cf. Annex 3).

Financial AGRA receives financial contributions that are charitable in nature from various
Contribution institutions/funding partners.

Grant A financial contribution issued from AGRA to a grantee (either a single


organisation or a consortium of organisations) following a Project proposal
submitted by the grantee/consortium.

Grantee An organisation, agency, government institution, non-profit entity, farmer


organisation or private company that receives funding from AGRA.

Intervention Umbrella term to describe activities undertaken by AGRA to achieve its mission
to promote inclusive agricultural transformation in Africa and improve the lives of
smallholder farmers and their households in Africa.

Legal Register A compilation of applicable legislations.

Must Must is used to show that it is necessary or very important that something
happens in the present or future

Project Projects are interventions implemented directly by AGRA or through Grantees


and/or consortia of Grantees that are financed through grants provided by AGRA
with the aim of achieving AGRA’s mission.

Shall ‘Shall’ is used to indicate a requirement that is contractually binding, meaning it


must be implemented, and its implementation verified.

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Should ‘Should’ is used to indicate a goal which must be addressed by the design team but

Will ‘Will’ is used to indicate a statement of fact. Will statements are not subject to
verification.

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4. Introduction

4.1 Overview of Alliance For A Green Revolution In Africa (AGRA)


Alliance for a Green Revolution in Africa (AGRA) is an African-led non-for-profit organisation that seeks
to promote an inclusive agricultural transformation on the African continent. Founded in 2006, AGRA’s
mission is to improve the lives of smallholder farmers across Africa by significantly increasing yields and
incomes.

AGRA recognises that environmental and social (E&S) sustainability are central to the attainment of
development outcomes that are inclusive and equitable, hence the need to be mainstreamed into its core
activities. AGRA’s ESMS has been developed to underpin its resolve to reduce and/or avoid negative E&S
impacts as a result of its work and to ensure sustainable development outcomes.

AGRA uses a range of interventions in differing forms to impact agriculture value chains in focus countries
to achieve its objectives. AGRA will therefore screen all its interventions for E&S risks both at a country and
grant level; and will define their management and monitoring as outlined within this ESMS. The objective of
this ESMS is therefore to:
• Strengthen E&S outcomes
• Avoid negative impacts to people and their environment
• Manage, mitigate and minimise negative impacts
• Develop and strengthen AGRA’s and its partners’ capacities to manage E&S risks
• Develop and implement an effective stakeholder engagement.

4.2 ESMS structure


AGRA’s ESMS is designed to ensure that potential negative E&S impacts are minimised, while positive
effects on communities and the environment are enhanced. It follows the guidance of International Finance
Corporation (IFC) Performance Standards (PS) on the assessment and management of E&S risks and
impacts, in particular, Performance Standard 1 (PS1) and international best practices. Relevant elements
of PS1 constitute the main building blocks of this ESMS. This ESMS includes: an E&S Policy and Manual,
organisational capacities and competency needed, Stakeholder Engagement Plan (SEP) and a monitoring
and review process.

Figure 1.1shows the structure of AGRA’s ESMS, which reflects the integration of E&S assessments
into AGRA’s interventions. The ESMS Manual is structured along these elements and is focused on the
allocation of grants and other programme implementation modalities as AGRA’s main instruments to
achieve AGRA’s mission.

Figure 1.1
ESMS Structure
within AGRA’s
three main areas
of intervention

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4.3 Applicable environmental and social standards and guidelines


The ESMS is premised on the following requirements:
• National environment, social, health, safety and labor laws and standards in the host countries of AGRA
projects, including requirements for public disclosure and engagement established therein.
• Relevant international law including conventions and treaties adopted by host countries.
• AGRA’s ESMS also benefits from policies and guidelines that set out international best practice such as:
a. Sustainability Guidelines of KfW Development Bank (2019);
b. IFC Environmental and Social Performance Standards (2012);
c. World Bank Group’s General Environmental and Health and Safety (H&S) Guidelines (WBG EHS
Guidelines);
d. WBG Industry specific guidelines, as applicable (i.e. EHS Guidelines for Annual Crop Production,
EHS Guidelines for Perennial Crop Production);
e. Core labour standards of the International Labour Organisation (ILO);
f. UN Basic principles and guidelines on development-based evictions and displacement;
g. IFC Exclusion List for financial intermediaries of KfW;
h. Voluntary guidelines on the responsible governance of tenure of land, fisheries and forests in the
context of national food security (VGGT; FAO 2012);
i. BMZ Reference framework for development partnerships in the agri-food sector (RFDP); and
j. USAID – Pesticide evaluation report & safer use action plan (PERSUAP).

Under the implementation of this ESMS, AGRA will review and evaluate all grant allocations against these
standards.

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5. Identification of E&S risk and impacts

5.1 Potential e&s risks inherent to AGRA’s interventions


AGRA engages in a number of interventions that promote its mission. These interventions have associated
E&S risks at an aggregated and/or country and regional level. Such interventions include, but are not
limited to support of:
• Promotion of an integrated package and agronomic practices;
• Development and adoption of improved crop varieties;
• Integrated soil fertility management e.g. use of fertilizers;
• Crop protection technologies e.g. pesticides;
• Support of agricultural extension services;
• Promotion of enabling policy environment;
• Promotion of postharvest management technologies;
• Gender equality
• Inclusive finance; and
• Access to markets.

A list of potential E&S risks that result from the above mentioned interventions are identified and are
presented in the E&S risk assessment table below (Table.2.1). This E&S risk assessment serves as a
reference to be consulted during the assessment of E&S risks which are to be managed at the country
level.

An E&S risk assessment shall be in place for each country of operation and updated periodically along with
the country plans and their accompanying risk registers. Measures identified to manage these risks shall be
reflected within the risk register and implementation monitored through the annual project and country
progress review process.

Table 2.1: Key E&S Risks at the grant level

Key risk areas Description of risk

Overall E&S Management

E&S Governance and Inadequacy of the approach and experience/ competency of the grantee/
Management Systems consortium to manage and budget for E&S-related issues can have an impact
on the regulatory compliance and E&S performance.

Environment

Soil Conservation and Physical and chemical degradation of soils (may result from unsuitable
Management management techniques, extensive tillage from use of inappropriate
machinery, poor crop/soil cover, etc.).

Chemical degradation of soils (may result from insufficient or inappropriate


use of mineral fertilizers, etc.). Destruction of soil physico-chemical properties
contributes to disruption of soil microorganisms which play an essential role
in decomposing organic matter, cycling nutrients and fertilising the soil

Soil erosion and generation of sediments can be a significant pollutant


dependant on the physical and chemical properties.

Soil Nutrient Nutrient management strategies aimed at maintaining and/or improving soil
Management fertility to optimize crop yield could have off-site environmental impact (e.g.,
contamination of groundwater resources and eutrophication of surface water
resources from surface runoff and leaching of nutrients).

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Crop Residue and Solid Poor crop residue management i.e., export/burning vs retention can lead to
Waste Management loss of soil organic matter, soil erosion and overall loss of nutrients. This has a
negative impact on crop performance, soil quality and overall soil health.

Poor solid waste management can pollute groundwater

Water Management Inadequate water management for crop production could decrease water
availability.

Agrochemicals/ Agrochemicals/Pesticides use and potential contamination of soils, wildlife,


Pesticides Use and human health, groundwater, or surface water resources caused by accidental
Management spills during the transfer, mixing, storage, and appropriate application of
agrochemicals/pesticides.

Genetically Modified The use of plants, which DNA has been modified using genetic engineering
Crop methods, can lead to possible cross-breeding with related crops, giving them
advantages over naturally occurring varieties and thus creating the possibility
of long-term ecosystem damage by GM crop usage.

Biodiversity Habitat conversion or degradation, mono-cropping, introduction of invasive


species and reduced quality and/or availability of priority ecosystem services.

Improved crop varieties The use of improved crop varieties may cause a reduction of local crop
genetic diversity. This may present negative impacts in the event of an
epidemic, new disease or ability to fight back climatic shocks.

Air quality Atmospheric emissions are primarily associated with emissions of combustion
by-products—including carbon dioxide (CO2), sulfur dioxide (SO2), nitrogen
oxide (NOx), and particulate matter (PM) —resulting from the operation of
mechanized equipment or from combustion by-products from the disposal or
destruction of crop residues or processing by-products.

Greenhouse gas Emissions of greenhouse gas emissions resulting from the operation of
emissions mechanised equipment, crop production, animal manure, over use of
nitrogen-based fertilizers, land-use conversion or from the disposal or
destruction of crop residues or processing.

Occupational H&S and Labour Condition

Physical hazards Operational and workplace hazards (slips, trips, and falls).

Machinery and vehicles accidents (vehicle collisions; vehicle and machinery


roll-overs, etc.).

Confined and restricted space (entry for processing bins and silos, product
storage bins, areas treated with agrochemicals/pesticides,).

Exposure to organic dust: (threshing, handling, and storage of grain generate


potentially high concentrations of organic dust including particles from grain,
fungi, and bacteria, as well as inorganic material).

Risk of fire and Fires resulting from the combustion of stored oil or crop residues, which can
explosion lead to a loss of property or cause possible injury to or fatality people.

Biological hazards Contact with venomous animals, such as stinging insects, spiders, scorpions,
snakes, disease vectors (e.g., mosquitoes, ticks), and with certain wild animals.

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Child and forced labour Child labour, i.e. when someone (a member of the family of the out-grower,
or small-business owner) under the legal working age is employed and results
in harm to the child by depriving the child of an education, is economically
exploitative or is damaging to physical and mental development.

Forced labour, i.e. any work or service not voluntarily performed that is
exacted from an individual under threat of force or penalty.

Vulnerable or There are individuals or groups that will be disproportionally disadvantaged by


disadvantages Persons the intervention e.g. women, youth, disabled, ethnic groups, gender identity,
sexual orientation etc.

Community H&S

H&S Management Land use changes or to the loss of natural buffer areas/ecosystem services
(such as wetlands, mangroves, and upland forests that mitigate the effects
of natural hazards, such as flooding, landslides, and fire) due to expansion of
agricultural land into natural areas and/ or land degradation through poor
farming practice.
Potential exposure to agrochemicals/pesticides.

Increased risk of vehicle or machinery injuries on roads.

Land acquisition

Land acquisition Involuntary resettlement refers both to physical displacement (relocation


and Involuntary or loss of shelter) and to economic displacement (access to resources for
resettlement income generation or means of livelihood) due to land acquisition (including
rights-of-way) associated with a Project’s operations.

Inadequacy and appropriateness of the grantees’ approach to land acquisition


and to the extent relevant, stakeholder engagement (including grievance
management) on this issue, livelihood restoration and compensation may
result in long-term hardship and impoverishment for Affected Communities
and persons, as well as environmental damage and adverse socio-economic
impacts in areas to which they have been displaced.

Stakeholder Engagement

Stakeholder Lack of effective stakeholder engagement and grievance management.


engagement and Stakeholder engagement is the basis for building strong, constructive, and
grievance management responsive relationships that are essential for the successful management of
a Project’s E&S impacts. Inadequate stakeholder engagement may not fully
address E&S impacts in a Project.

If grievances are not addressed and recorded as part of the grantees


stakeholder engagement activities, these grievances could be related to
issues that could escalate into legal claims if unresolved.

5.2 E&S risks in AGRA’s grant management process


Grants awarded by AGRA vary in nature, number of partners, geographical coverage and amount. Potential
AGRA Grantees include among others:

• Governments and public sector organisations e.g. the Ministry of Agriculture; Ministry of Policy &
Planning, regulatory bodies (seed, fertilizers and market), regional and continental institutions etc.;

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• Not for Profit Organisations;


• Private sector organisations e.g. seed companies; processing companies; consulting companies;
• Universities and other educational institutions;
• Agro-dealers;
• Financial institutions;
• Farmers’ organisations;
• Marketing and farmer produce board e.g. grain councils; and
• Research institutions.

This ESMS describes a streamlined process of identification, assessment, management and monitoring of
E&S risks across the various types of grants and programme delivery mechanisms.

An overview of the key E&S risks associated with AGRA’s activities at grant level are provided in Table 0
1Table 2 1. Although these E&S risks are not applicable to all grant activities they provide an overview of
potential risks that may result from AGRA’s current Grants and other programme activities.

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6. ESMS management & organisation

6.1 Overview of AGRA’s E&S organisational structure

President

Board

Chief of Staff Chief of International


& Strategy Cooperation &
Strategic Initiatives

Vice President Vice President Vice President Chief Operating


Country support & Programme development Policy & state Officer
delivery & innovation capability

Resilience: climate,
Adaptation, Environmental
& Social management

Figure 3.1: ESMS within AGRA Structure (01.2019)

The Program Development and Innovation (PDI) Division will be responsible for managing all ESMS aspects
across the organisation through a designated E&S Officer. The implementation and management of the
ESMS will follow existing/approved operational and management structures, processes and procedures,
accountability and reporting as stipulated in AGRA’s governance and operational manuals.

6.2 E&S roles and responsibilities


This section presents an outline of the roles and responsibilities within AGRA to successfully implement
the ESMS. As the ESMS evolves, AGRA will continuously assess required capacities within the organisation
for effective implementation. Table 3 1 provides an overview of the ESMS roles and responsibilities.

Table 3.1: AGRA Staff Roles and Responsibilities for the Implementation of the ESMS

Role/Title Responsibility related to E&S Management

Board of Directors AGRA’s overall managing & governing organ, responsible for the overall
operationalisation of the ESMS.

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Management

President Accountability for ensuring ESMS implementation, monitoring and reporting


throughout AGRA operations.
Responsible for ensuring that country and regional operations have
sufficient capacities and resources to implement the requirements of this
ESMS.
Responsible for monitoring performance at a country level, and compliance
of all activities with ESMS requirements.

Vice President Responsible for ensuring the integration and compliance of ESMS across
Program AGRA’s interventions.
Development and
Responsible for the implementation of the ESMS, SEP and grievance
Innovation (PDI)
mechanism in AGRA.

Programmes

E&S Officer Overall responsibility for ensuring compliance and management of E&S
(headquarter-based; 1 issues/risks across AGRA.
person)
Manage resources (budget and staff) for E&S risk management procedures
Lead, monitor and provide ongoing feedback to Country Managers on E&S
topics.
Ensure the coordination and integration of E&S risk management
procedures with AGRA’s Grant Cycle.
Report any major E&S issues to the President and/or the Vice President
Program Development and Innovation (PDI) and secure the support and
approval of E&S risk management issues by the President and/or the Vice
President Program Development and Innovation (PDI)
Development/quality control of training materials for internal staff and for
grantees & Delivery of training on E&S to internal staff and grantees and
maintaining training records.
Development/quality control of training materials for internal staff and for
grantees & Delivery of training on E&S to internal staff and grantees and
maintaining training records.
Overall endorsements of E&S screening and assessments related to grantee
applications and proposals.
Review and approval of AGRA’s annual E&S performance report to
stakeholders (including lenders), E&S country assessments and action plans.

Country Managers

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(Regional/country Overall responsibility for ensuring compliance and management of E&S


level; 2 persons per issues/risks on a regional/country level.
country)
Directly report and provide feedback on regional/country level best
practices to the E&S Officer.
E&S country risk assessments and update of the strategic risk assessment
for the countries within the respective region.
Reporting ‘red flag’ E&S issues to the E&S Officer.
Lead, monitor and provide ongoing feedback to Program Officers (PO) and
Associate Program Officers (APO).
Responsible for E&S assessments for grantee applications and proposals.
Responsible for monitoring and evaluation of grantees on E&S performance
(including review of monitoring reports).
Support to the E&S Officer in delivering E&S training regionally and at
country level to internal staff and externally to grantees.

Program Officers (PO)/ Associate Program Officers (APO)

(Regional/country Conduct E&S assessments for grantee applications and proposals, including
level) initial risk screening, review of concept notes and proposals, site visits, and
E&S monitoring requirements in the grant agreement letter.
Ensure that appropriate environmental representations, warranties, and
covenants are incorporated in each grant agreement
Supervise portfolio grantees on-going compliance with the applicable
requirements on a regular basis, which may include:
Conducting site visits, monitoring the implementation of E&S action plan
(if any) by the grantees, reviewing grantees’ annual reports, and recording
grantees’ E&S ongoing performance
Resolving E&S issues in case of non-compliance, and where needed,
preparing a time-bound corrective action plan with specific follow-up
procedures
Support to grantees in identifying E&S risks and developing mitigation
measures
Support to the E&S Officer and Country and Deputy Country Managers in
delivering E&S training regionally and at country level to internal staff and
externally to grantees.

Heads of Unit and Ensure that ESMS is integrated and implemented within their Interventions.
Programs

Grants

Head of Grants Ensure that E&S risk screening and assessments are included in the grants
making process.
Ensure that E&S risk documentation is part of the grant review package and
being considered in grant review processes and decisions.

Grants Committee Discuss and ensure that E&S risk assessment is included in the grants
making process.
Determine the need for an Environmental and Social Impact Assessment
(ESIA) subsequent to receiving the screening report.

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Monitoring and Evaluation

Head of M&E Unit Responsible for ensuring that E&S risk monitoring is being undertaken in
accordance with the monitoring schedule.

Provide oversight on country E&S risk assessments and monitoring.


Support review of the ESMS policy as required.

AGRA Staff Support the implementation of ESMS in their various functions.

6.3 Developing E&S capacity within AGRA


AGRA will undertake ongoing awareness raising and training across the organisation, particularly for those
responsible and/or accountable for the implementation of the ESMS in order to enhance and maintain the
capacities of staff and to raise awareness of the E&S risks in the organisation.

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7. ESMS management & monitoring

7.1 Management of potential E&S risks at country level


At country level, E&S risk assessments will be undertaken within the context of AGRA’s enterprise risk
management (ERM) framework and using the E&S Risk Assessment, respective country’s legal register
and exclusion list. Monitoring will be conducted on an ongoing basis and the risk register will be updated
periodically, as necessary and in accordance with AGRA’s ERM Framework. Mitigation measures, if any, will
be implemented at country level with support of the E&S Officer and operational oversight provided by
the risk and compliance function as per enterprise risk management framework. Programme and technical
monitoring will be undertaken by the relevant program and M&E function and responsible officers. Annex
15 provides AGRA’s E&S risk assessment framework that will be managed at the country level.

The assessment at this level will also identify mitigation measures. Such mitigation measures will typically
include:
▶ Engagement with external partners (such as research organisations and NGOs) to ensure adequate
evaluation of project E&S risks and to benefit from external guidance;
▶ Regular project internal audits and monitoring visits;
▶ Tracking of NGO sentiments;
▶ Definition of clear selection criteria for Grantees and partners; and
▶ Training of Grantees and partners in the management of E&S risks.

7.2 Management of E&S risks at grant level


The identification of strategic risks at the country level as described in Section 4.1 forms the basis for
the management of E&S risks and needs to be considered for the E&S risk assessment of each individual
grant. AGRA’s ESMS is operationalised through a sequence of review steps which are explained below and
summarised in Table 4-1. These steps are integrated into AGRA’s grant management cycle established
under AGRA grants manual; these include:

1. Project/Grant conception (includes Grantee identification);


2. Proposal development;
3. Grant award;
4. Post-award monitoring; and
5. Close out

AGRA’s ESMS implementation involves the following key steps that are related to the respective phases in
AGRA’s grant management cycle:

ESMS implementation key steps Related grant management cycle steps

I. ESMS Review Procedures Step 1: Project/Grant Conception


1. ESMS Screening
Step 2: Proposal Development
a. Environmental and Social Due Diligence (ESDD)
b. Environmental and Social Impact Assessment
(ESIA)

II. Implementation and monitoring Step 4: Post-Award Monitoring

III. Reporting Step 4: Post-Award Monitoring


Step 5: Close Out

The ESMS implementation key steps are described in detail in the following section.

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8. ESMS screening

Proposed projects must comply with AGRA’s E&S Policy. For this purpose, screening of a project for
possible E&S risks will be realised at the project development phase and prior to its approval by the grants
committee.

8.1 Purpose of the ESMS Screening


The purpose of the screening is:

• to avoid, reduce or limit environmental pollution and environmental damage including climate-
damaging emissions and pollution;
• to consider probable and foreseeable impacts of climate change including utilising the potential to
adapt to climate change. In this context climate change is understood as
• climate variability and long-term climate change;
• to understand whether a project could lead to any negative social and environmental impacts;
• to determine the E&S risk level i.e. low, medium and high; and
• where risks have been identified, to determine the appropriate type and level of assessment needed to
ascertain the extent of the risks.

8.2 Procedure for screening


Following development of the project idea, an initial E&S and Climate Mitigation and Adaptation Screening
(preliminary assessment) will be conducted as part of the development of a project idea into a project
concept note. This screening, is a desktop assessment of expected E&S impacts undertaken by the
relevant Country Manager, Program Officers (PO), Associate Program Officers (APO) using the Exclusion
List (Annex 3) and Initial E&S Screening Checklist (Annex 4).

8.3 Climate mitigation and adaptation screening


AGRA subjects relevant Grantees/Projects to a systematic climate assessment within the ESMS Screening.
It determines what effects climate change could have on the success of the Grantee/Project and what
quantities of greenhouse gases will be emitted. On that basis it examines measures that can better adapt
the Grantee/Project to climate change and reduce its emission of greenhouse gases. The objective of the
climate assessment is also to recognise climate impacts that may impair the achievement of objectives
in due time so that, if applicable, required adaptation measures can be taken into consideration in the
conception of the Project. This applies equally to the early identification of potential to adapt to climate
change in order to leverage this potential.

Climate relevance is assessed by examining the relevance with regard to reducing greenhouse gas
emissions (climate protection relevance) and the relevance with regard to adapting to climate change
(climate change adaptation relevance). In terms of climate change protection relevance, checks are carried
out to establish whether a Grantee/Project can make a significant contribution towards the reduction
of greenhouse gas emissions and/or the sequestration of carbon in soils or vegetation. Furthermore,
the climate relevance assessment considers if positive impacts of climate change could be enhanced
(potentials) for the Grantee/Project goals, where appropriate. If it was found that the Grantee/Project
has climate relevance or it is still unclear whether or not, an in-depth climate assessment must be carried
out. If, during the screening, the climate relevance was evaluated for just one of the two aspects of climate
protection or adaptation, an in-depth climate assessment only needs to be performed for the aspect
classified as relevant (see ESIA, Step 2). The results of the climate mitigation and adaptation screening are
documented internally.

Results of the E&S and Climate Mitigation and Adaptation Screening will be used to determine the
preliminary category of the proposed project in line with the requirements of the IFC PS following the
criteria defined in the categorisation guideline (Annex 5). The following table provides an understanding of
the Project categories:

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

High Risk Medium Risk Low Risk

High Risk projects are those Medium Risk projects are those Low Risk projects are those
that are likely to have significant that are likely to have potentially that are likely to have no or only
adverse impacts and risks on adverse risks and impacts minor adverse environmental
the environment and/or the upon the environment and on and social impacts or risks.
social conditions of the affected the social conditions of those
population. Impacts and risks concerned. These impacts are
may potentially be significantly likely to be less adverse than
adverse because the complex those of the High Risk projects.
nature of the project, the scale Typically, the potential impacts
(large to very large), and the and risks of Medium Risk
sensitivity of the location of projects are limited to a local
the project or the impacts area, are in most cases reversible
and risks are irreversible or and are easier to mitigate
unprecedented. through appropriate measures.

In some cases, further consultation and engagement with potential Grantees will be carried out to obtain
additional information on potential E&S risks and impacts; and to evaluate the organisational capacity of
the Grantees to successfully manage E&S risks.

The E&S Officer, or the designated alternate, will review each screening checklist to verify the level of the
risk and significance of the impact based on the following criteria:

• Sensitivity of the existing bio-physical and social environment (i.e. people, social groups, vulnerable
persons, species, ecosystems etc.)
• Magnitude of potential impact considering severity, duration, scale and reversibility;
• Possibility of the impact occurring;
• Risk of non-compliance with E&S laws;
• Potential reputational risk for AGRA;

Site visits will be performed to verify information as provided by the Grantee/consortium on the ground
and to obtain additional information. Site visits will be conducted by the responsible PO/APO with support
by the E&S Officer, or designated alternate, as necessary, at project development phase. A pre-funding site
checklist (Annex 8) will used should the site visit be needed. The checklist will be reviewed and approved
by the E&S Officer.

Where there is any information missing following this screening that is deemed critical to determining the
level of E&S risks, or where there is any doubt about the significance of the identified potential impacts,
the E&S Officer will request for additional information. This could take the form of a general request
for information, a specific study or an Environmental and Social Impact Assessment (ESIA). However, in
consideration of the costs of an ESIA, the decision to assign a higher risk level should not be formed on
hypothetical impacts but on the basis of a certain degree of probability using evidence generated.

The screening results for each project will be endorsed by the E&S Officer and included in the grant
submission documents that shall be submitted to the grants committee.

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

9. Environmental and social impact assessment


(ESIA)

If the ESMS screening classifies a project as E&S medium or high risk, additional assessments varying in
comprehensiveness shall be required. Low risk projects shall not require any additional assessments.

In consideration of the costs of such an ESIA and the high level of E&S risk involved, the Grants Committee
may determine whether to proceed with the project or not. The E&S Officer shall participate in Grants
Committee meetings where deliberations regarding a project’s E&S risks (high and medium) are ongoing.

The scope of the ESIA process is proportionate to the nature and impact of the risks as follows:

High Risk Projects – Full ESIA: a comprehensive analysis of E&S impacts with all the elements described
under section 2 (b) (ii) below will be undertaken. Refer to Annex 9;
Medium Risk Projects – Partial ESIA: projects that are categorised here will only require an Environmental
and Social Due Diligence (ESDD) as described below and which forms the first step of the ESIA and an
Environmental and Social Action Plan (ESAP). Refer to Annex 9.

9.1 Purpose of an ESIA


The purpose of an ESIA is to:
1. predict and assess the type and scale of potential impacts to communities, vulnerable persons,
livelihoods and well-being and/or the physical, natural, social economic or cultural environment;
2. identify, analyse and compare feasible alternatives;
3. develop suitable mitigation measures documented in an ESAP; and
4. develop a sound project strategy in which adverse impacts are avoided or minimised to acceptable
levels.

9.2 Procedure for conducting ESIA


9.2.1.1 Step 1 – E&S Due Diligence (ESDD) & Report

The ESIA process shall commence with the E&S Officer conducting an ESDD and preparing the ESDD
Report using information collected from the Project Proposal, the Grantee’s Organisational Capacity
Assessment (OCA) and the Site Visit Checklist.

The site visits will be performed by the responsible PO/APO (with support of the E&S Officer, or a
designated alternate, as necessary) to verify information as provided by the Grantee/consortium and to
obtain additional information.

The due diligence assessment for high risk projects may require external technical support and assistance,
in line with the specific potential E&S risks. The need for specialised technical support and assistance will
be referred to management approval due to the cost implications related to it. It will therefore only be
undertaken if approved by management. Medium risk Projects will be assessed by the E&S Officer or may
require external assistance, subject to management approval and availability of resources.

The ESDD will identify any gaps of the information provided by the Grantee/consortium within applicable
national legislation and other international requirements. Specific actions needed to close these gaps will
be documented through the final project ESAP which is prepared by the E&S Officer in collaboration with
the Grantee and responsible PO/APO.

The ESDD and ESAP shall form part of the conditions incorporated into the grant award letter and may
form conditions precedent to disbursement of Project funds.

9.2.1.2 Step 2 – Environmental and Social Impact Assessment (ESIA)

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

The information gathered during the ESDD will be used to conduct the substantive ESIA for high risk
projects. The key elements of the ESIA are provided below:

ELEMENT OBJECTIVE

Project Description To define the Project, its major components, and its areas of influence,
geographic, ecological, social, and temporal context.

Policy, Legal and To clarify the framework within which the ESIA is carried out and applicable
Administrative compliance requirements.
Analysis

Environmental and To understand the prevailing physical, biological and socioeconomic conditions
Social Baseline with the Project’s area of influence.

Environmental To analyse E&S risks and predict and assess the Project’s potential positive and
and Social Impact negative direct and indirect impacts.
Assessment (ESIA)

In-depth Climate To determine what effects climate change could have on the success of the
Assessment Grantee/Project and what quantities of greenhouse gases will be emitted

Analyses of To identify other options to achieve project objectives and compare impact,
Alternatives including alternative of not implementing the Project.

Information To identify stakeholders, particularly groups that may be affected by the


Disclosure, project.
Consultation and To describe the process for engagement and information disclosure (including
Participation the type of information to be disseminated and the method of dissemination)
and the process for carrying out consultation with affected people and
facilitating their participation during Project implementation.
To highlight comments and concerns of affected groups and how these have
been addressed in the Project design.

Grievance Mechanism To provide an avenue for handling grievances (both informal and formal
channels), setting out the time frame and mechanisms for resolving complaints
regarding E&S performance.

Projects marked for full ESIA may be approved for award by the Grant Committee or Grants Review
Committee, depending on the investment amount, on condition that the ESIA is completed within a defined
timeframe and form conditions precedent to disbursement of the project funds either at the beginning of
the project or during implementation as ESAP targets are met.

9.2.1.3 In-depth Climate Assessment

The in-depth climate assessment analyses the greenhouse-gas reduction potential, adaptive capacity
of the Grantees and ecosystems as well as the use of the positive impacts of the climate change for
smallholder development, associated with the Project. The in-depth climate assessment is carried out with
the following relevant aspects, respective for each case:

• The in-depth climate adaptation assessment and consideration of the aspects related to climate
change adaptation (climate resilience) should ensure that despite the forecasted effects of climate
change, the desired developmental impacts of the Project are not threatened. Furthermore, the
assessment should analyse whether the Grantee’s climate adaptation capacity can be further increased
within the scope of the Project. In this regard the expected climate changes and their consequences
for the Project will be analysed. This includes both direct effects (e.g. more frequent flooding or drying
out of agricultural areas) and indirect effects of climate change (e.g. revenue losses in crop production).
The analysis examines the longer targeted period of impacts beyond the formal implementation period

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

of the Projects. On this basis, options, compatible with the climate strategy of the country, e.g. the
National Adaptation Plan as part of the United Nations Framework Convention on Climate Change,
will be developed and implemented to increase the climate adaption capacity of the target groups or
ecosystems.

• The in-depth climate mitigation assessment to consider the potential for greenhouse gas reduction
(emission saving) serves to avoid substantial greenhouse gas emissions and to identify potential
for reducing greenhouse gases. First, the greenhouse gas emissions associated with the Project
region and/ or specific product/crop type is described, and whether the planned Project contributes
to increasing or decreasing greenhouse gas emissions, is compatible with the climate strategy of
the country, e.g. the Nationally Determined Contribution as part of the United Nations Framework
Convention on Climate Change and, where necessary, if there is potential for reducing greenhouse
gas emissions. On this basis, options to contribute to greenhouse gas reduction will be developed and
if applicable – taking into consideration the developmental impacts and costs – integrated into the
Project.

Box 1 - Project Categories and subsequent E&S studies

High Risk Projects: In addition to ensuring applicable E&S legislation (for a template of a
Legal Register see Annex 9) are complied with, High Risk projects require additional relevant
E&S studies to be conducted by the grantee/consortium. These additional E&S studies should
include a comprehensive ESIA and ESMP and in case of physical or economic displacement, a
Resettlement Action Plan (RAP) respectively a Livelihood Restoration Plan (LRP). Also, where
there is considerable climate relevance, an in-depth assessment of the potential for greenhouse
gas reduction or the need for climate adaptation will be needed. Suggested outlines for an ESIA
are available in Annex 9. Guidelines for land acquisition and resettlement are provided in Annex 9.
During the process of relevant E&S studies preparation, it would be expected that consultation
with Project stakeholders be carried out. Relevant documents on public consultations should be
provided. Grantees/consortia should be encouraged to consider seeking support from experienced
environmental and/or social specialists for undertaking these E&S studies.

Medium Risk Projects: Medium Risk project risks and impacts are less significant compared to High
Risk projects and can usually be mitigated through comprehensive mitigation measures or standard
solutions.
The need for and the scope, of priorities and in-depth of appraisal required by a Medium Risk
project should be determined on a case by case evaluation of the E&S risks, while considering
the applicable national legislations. Simple appraisal (e.g. review of the Project E&S risks) can
be conducted to identify potential E&S gaps in lower-risk Medium Risk projects. The applicable
IFC PS would depend on the project type and aspects specific to the project, but they are likely
to be limited to PS 1-2 for the lower-risk Medium Risk Projects. In-depth E&S appraisal would be
needed for Medium Risk projects that anticipate higher E&S risks. The due diligence process for the
higher-risk Medium Risk projects will be similar to that for the High Risk projects, which involves
the detailed review of project E&S assessments and a site visit to verify the level of E&S risks as
necessary.

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

Low Risk Projects: Low Risk projects are projects with minimal or no impacts to E&S aspects.
The Low Risk projects will need to comply with the local laws and regulations related to E&S at
minimum but would not be expected to have additional or detailed E&S assessments in place.
Nevertheless, the E&S Officer would have identified E&S issues or gaps based on the outcome
from the internal project screening process and have discussions with the shortlisted grantee/
consortium. Mitigation actions of the identified E&S issues will be prioritised and documented
into an ESMP or similar document prepared by the grantee/consortium and implemented over the
project lifecycle.
All Projects will need to consider Emergency Preparedness and Response Planning. If significant
risk are identified during the due diligence, an Emergency Preparedness and Response Plan
will be developed by the grantee/consortium. This is important for AGRA and its grantees, to
be prepared to respond to accidentaland emergency situations associated with the Project in a
manner appropriate to prevent and mitigate any harm to people and/or the environment. This
preparation will include the identification of areas where accidents and emergency situations
may occur, communities and individuals that may be impacted, response procedures, provision
of equipment and resources, designation of responsibilities, communication, including that
with potentially Affected Communities and periodic training to ensure effective response. The
emergency preparedness and response activities will be periodically reviewed and revised, as
necessary, to reflect changing conditions. Where applicable, AGRA will also assist and collaborate
with the potentially Affected Communities and the local government agencies in their preparations
to respond effectively to emergency situations, especially when their participation and collaboration
are necessary to ensure effective response. If local government agencies have little or no capacity
to respond effectively, AGRA will play an active role in preparing for and responding to emergencies
associated with the Project. AGRA will document its emergency preparedness and response
activities, resources, and responsibilities, and will provide appropriate information to potentially
Affected Community and relevant government agencies.

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

10. Implementation and monitoring

10.1 Implementation
Implementation of ESMS will be done primarily through its various components – E&S risk assessments,
ESDD, ESIA, and the ESAPs throughout the project life cycle. The ESAPs will be the main instrument for
providing a strategy for managing risks and mitigating impacts and will form an integral part of the project
proposal and the grant award letter. The details of the ESAP may vary depending on the E&S risk level and
complexity. Such details may include mitigation measures and their timeframes, required resources (where
applicable), responsibilities and monitoring indicators.

10.2 monitoring and reporting


Monitoring of E&S aspects, following implementation of actions and mitigations, are fundamental elements
of an adequate management system. The E&S Monitoring Checklist (Annex 12) will be used as a guide
for monitoring E&S risks through the life cycle of a project and may be used for projects of any risk level.
AGRA will conduct the monitoring, depending on risk levels of a project and through either random spot-
checks and/or pre-scheduled monitoring of projects and interventions for the identification of potential
new ‘red flags’ which may arise during project implementation.

Under the ESMS, E&S reports will be submitted along with the other project reports by the Grantee/
consortium at the frequency as specified in the Grant Agreement Letter (technical reports, financial
reports, project implementation plan report, risk matrix report, milestone report). An E&S Monitoring
Checklist that serves as a basic template for E&S reporting during project implementation is provided in
Annex 12 and will be annexed to the Indicator Performance Tracking Table. The checklist, where necessary,
will be adapted to the specific requirements of the ESAP.

In addition to the review of the submitted E&S Monitoring Checklist, periodic site visits, performed by the
PO/APO and/or the E&S Officer, will be conducted to monitor the implementation of the ESAP and other
E&S studies and their recommendations.

Further, in addition to application of the E&S Monitoring Checklist and Reporting, periodic site visits
will be performed by the responsible PO/APO (and/or the E&S Officer) with support of M&E Officers to
monitor E&S indicators and implementation of ESAP (where applicable). The site visits will ensure the
correct implementation of all requirements as listed in the ESAP (where applicable).

In the event that there are any significant E&S deficiencies that are detected from the monitoring process,
the responsible PO/APO will discuss the issues with the responsible Grantee/consortium in order to clarify
uncertainties and define improvement actions, including introduction of new conditions, where needed,
precedent into the Grant Award Letter.

Should external factors (e.g. natural hazards, pests, political changes) influence the E&S performance of
the project, grant modifications can be considered to reflect these changes. This process may include
the modification of goals/objectives linked to E&S performance as outlined in the ESAP and the E&S
Monitoring Checklist. All modifications of E&S goals/objectives must be in line with AGRA policy on the
modifications of the Grant Agreement.

In the event of significant non-compliance with the E&S requirements of the project that could lead
to negative E&S impacts, the responsible APO/PO with support of the E&S Officer should escalate
the potential risks to management, who may at their discretion determine to terminate the project in
accordance with terms of the Grant Award Letter.

E&S implementation and monitoring will be mainstreamed into the overall project monitoring and
reporting as per AGRA grant management requirements. Where identified, all negative effects resulting
from AGRA’s interventions must have mitigation actions attached to them. Reports on E&S issues will, as
much as possible, take a learning approach. The M&E unit will review E&S risks monitoring indicators in
collaboration with the E&S Officer.

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

10.3 Final reporting and close out


Along with the final reporting on the project, the E&S Officer must approve and provide a Final E&S Report
in line with the Template as outlined in Annex 13. The final report must reference the close-out of all ESAP
items and requirements. Should open items remain, these need to be clearly assigned to the responsible
Grantee to ensure that they will be completed after grant termination. In this case, outstanding items need
to be included in the final closeout letter along with best-practice E&S management measures.

E&S information will be documented in line with the general AGRA filing system for a period of five years
after closeout of the last grant to the Grantee.

Table 4.1: Summary of ESMS Review Steps along AGRA’s Grant Cycle

AGRA Grant ESMS Review Steps Responsible Involved Parties ESMS Tool
Cycle

ESMS Screening and PO/APO E&S Officer Screening


risk classification Checklist

ESDD E&S Officer PO/APO/Grantee Organisation


Capacity
Assessment
(OCA)
Medium Risk
Projects Site Visit
ESDD Checklist
ESDD Report

Project ESAP E&S Officer PO/APO/Grantee ESAP


Development
Phase ESDD E&S Officer/ PO/APO/Grantee OCA
External
Site Visit
Expert
Checklist
ESDD Report
Low Risk
Projects Full E&S Officer/ PO/APO/Grantee/ E&S Risk
ESDD ESIA External E&S Officer/ Project Assessment
Expert Stakeholders Toolkit

ESAP E&S Officer/ PO/APO/Grantee/ ESAP


External E&S Officer/ Project
Expert Stakeholders

Implement mitigation Grantee APO/PO/E&S Officer Project Proposal


measures (where and/or ESAP (as
applicable) applicable)
Implementation
& Monitoring Monitor E&S indicators APO/PO E&S Officer/M& E Project Proposal
Unit/ Grantee and/or ESAP
and or ESIA (as
applicable)

Closeout and Closeout reporting Country E&S Officer E&S Closeout


reporting manager/APO/ report
PO

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

11. Stakeholder engagement

11.1 stakeholder engagement plan (SEP)


Stakeholders are persons or groups who are directly or indirectly affected by a project, as well as those
who may have interests in a project and/or the ability to influence its outcome, either positively or
negatively. They can include affected communities located near a project, particularly those subject to
actual or potential project-related risk and/or adverse impacts on their physical environment, health or
livelihoods.

AGRA will ensure stakeholders are engaged in a meaningful manner and will put in place systems and
processes to support stakeholder engagement at Grantee level and for all projects.

A SEP is required to be developed and implemented for medium and high risk projects on an appropriate
scale. A SEP should be scaled to the project risks and be tailored to the characteristics of the affected
persons or communities. A template of a SEP can be found in Annex 9.

The outcomes of the overall and country level strategic risk assessments should be formally taken into
consideration in the updating and planning of AGRA’s overall guidelines and strategy for engagement and
documented through minutes, and in any engagement guideline or programme plan updates.

11.2 Grievance mechanism


Stakeholder engagement measures will work pro-actively towards identifying and addressing issues before
they become grievances. However, when grievances are reported they need to be addressed in a consistent
and verifiable manner. The purpose of the Grievance Mechanism is to implement a formalised process
(identification, tracking and redress) to manage project-related complaints from communities, workers and
other stakeholders. A Grievance Mechanism needs to ensure that stakeholder comments, suggestions and
objections are captured and considered. The Grievance Mechanism is designed to be a transparent process
that is gender responsive, culturally appropriate, and readily accessible to all segments of the stakeholders
at no costs and without retribution. The Grievance Mechanism will be available at AGRA at both corporate
and country level; and at Grantee level. The Mechanism that is guided by the principles detailed in this
chapter (see also Figure 5-1).

A grievance is defined as an issue, concern, problem or claim (perceived or actual) that an individual or
community group wants the Grantee, its contractor or AGRA to address and resolve, e.g.
• Specific complaint about impacts, damages or harm caused by the project;
• Concerns about project activities during construction or operation, or perceived incidents or impacts.

The Grievance Mechanism should also consider positive feedback and suggestions. The Grievance
Mechanism is required to be:
1. Systematic: All forms of complaints related to the project need to be considered;
2. Transparent: Stakeholders must be informed that a grievance mechanism is in place, grievances
must be documented and registered;
3. Appropriate: Tailored to the Project scope, adapted to local conditions and culturally acceptable;
and
4. Lead to corrective actions: Grievances must be answered as relevant and the answers must be
documented. Timely resolution of grievances is vital to ensure successful implementation of the
project.

The Grantee is responsible to implement a formal grievance mechanism that addresses the requirements
described and that can be accessed at any moment by AGRA. In the event of serious complaints or those
that cannot be resolved promptly, the Grantees are obligated to inform AGRA of the details. In addition,
AGRA maintains a separate channel of communication both at corporate and country level open to local
stakeholders in the event that issues are not being properly addressed by the Grantees.

The Grievance Mechanism at AGRA level will be managed by AGRA’s Legal Offices using the following
address:

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

• Email: [email protected];
• Mailing:
Office of the General Counsel
Alliance for a Green Revolution in Africa
P. O. Box 66773-00800 Waiyaki Way
Nairobi, Kenya

As per AGRA’s Whistleblower and Ethics Policies, the Legal Office will be responsible for recording and
bringing issues raised/reported to the attention of the Board of Directors for action. They will also be
responsible for the report compilation of the incidents reported. At AGRA country level the Grievance
Mechanism organisation will be replicated through the Country Manager. AGRA’s grievance mechanism
aims to safeguard ethical standards captured across various institutional policies and procedures. including
the following:

• Environmental and Social Management Policy


• Partner Code of Conduct
• Safeguarding Policy
• Staff Code of Conduct
• Whistleblower Policy

AGRA encourages all staff, partners and vendors to report any suspected or observed wrongdoing under its
Whistleblower Policy, which sets out the Grievance Mechanism procedure and principles.

At Grantee Grievance Mechanism level, the Grantees should appoint one person as grievance mechanism
manager (usually the implementation supervisor) who will inform colleagues and contractors about
grievance mechanism procedures, gather grievance forms, report them to the grievance register and
provide input to the Project reporting to AGRA. The stakeholders must be informed on the existence of
such grievance mechanism and the Grantees must ensure that the process is considered by stakeholders to
be culturally appropriate, trustworthy and effective.

Grievances might be formulated in an informal way (not necessarily written complaint) during a
conversation, therefore Grantee’s employees need to be sensitized on this system. All grievances must be
documented by the Grantee’s employees and sent to the grievance mechanism manager and consigned
within a grievance log (paper or electronic).

The grievance log should at least include the following categories:


• Name and contact details of contact (unless requested to remain anonymous);
• Date and description of grievance;
• Response made to the grievance / corrective action implemented.

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

Figure 5.1: Grievance Mechanism Principles

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

12. Collaboration, information sharing and


reporting

AGRA strives for maximum transparency and invites collaboration from its development partners on
effectively managing E&S risks and mitigating negative impacts. In this regard, AGRA will aim to continually
be informed by its Grantees and keep its development partners informed of E&S issues arising from
implementation of its Projects. The information comprises the following elements:

1. Incident and regular reporting of E&S performance from Grantees to AGRA (semi-annually)
2. External and incident reporting of AGRA to financing organisations (annually)
3. External audit of the ESMS by an independent company (annually). The external audit ensures that the
practicability is up to date with the ongoing development of AGRA’s strategy and portfolio (Annex 15
Audit Checklist will be used through the audit).

In addition, where any of AGRA’s development partners wish to conduct ad-hoc visits to projects to
understand their potential E&S risks, AGRA shall cooperate with such partner accordingly.

AGRA will prepare an E&S Performance Report on a periodic basis and will share this report with its
funding partners, annually, where required.

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

13. ESMS review

The ESMS will be reviewed on a regular basis, at least every two (2) years, and updated if necessary to
reflect any changes in legislation, international standards as well as changes within the AGRA organisation.
The review will be done by the E&S Officer who will work with the AGRA management to assess the
effectiveness of the system and decide if any changes are necessary. The E&S Officer will also ensure that
changes do not result in deviation from international best practice and applicable legislation.

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

14. Annexes

ANNEXES

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ENVIRONMENTAL & SOCIAL MANAGEMENT SYSTEM

Alliance for a Green Revolution in Africa (AGRA),


West End Towers, 4th Floor,
Kanjata Road, off Muthangari Drive, Off Waiyaki Way,
PO Box 66773,
Westlands 00800, Nairobi, Kenya.

36

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